If you have questions regarding this policy or our handling of your personal information, please email us at firstname.lastname@example.org.
Our legal status under UK data protection law is that of a “controller”, and in this capacity we will securely store and process your personal information which you have provided to us. Controller is a legal term used in data protection legislation to signify the person who controls what to do with any given personal information. As controller we have registered with the Information Commissioner’s Office and our registration number is ZA218199.
collection of information
- your first and last names;
- your date of birth;
- your email address;
- your mobile phone number;
- metadata relating to any messages you send using the Huggg Service; and
- the content of any messages you send using the Huggg Service.
This information (and any payment information) may be collected by us or on our behalf by our third-party partners (such as payment services providers and other software services, including telecommunications services) from time to time.
If you use the Huggg Service to buy somebody a Huggg, we may send them a text message to let them know. Wereceive their mobile phone number from you and you confirm that you have their permission to share this with us for this purpose.
how is your personal information used?
We will only use your personal information when permitted to do so in accordance with data protection laws, which means that we will only process your personal information where we have a lawful basis for doing so. In respect of your personal information, these bases are as following: (i) where you have given your consent for us to use your personal information for a particular purpose; (ii) where the processing of your personal data is necessary for the performance of a contract to which you are a party; (iii) where the processing of your personal data is required to comply with a legal or regulatory obligation; or (iv) where the processing of your personal data is in our (or a third party’s) legitimate interests and your freedoms and fundamental rights do not override those interests.
Specifically, the following are a list of the purposes for which we process your personal information and the lawful bases on which we rely to carry out such processing:
|To notify you that our app is enabled for you to download.||Necessary for the performance of the contract we have with you.|
|To enable you to download our app.||Necessary for the performance of the contract we have with you.|
|To provide you with our services which you have signed up for.||Necessary for the performance of the contract we have with you.|
|To provide occasional updates, including marketing messages from us.||Consent for marketing messages.
We may send you other (non-marketing) messages where this is in our legitimate interests, for example to notify you of a problem with our service or to notify you that you have received a Huggg.
|To provide personalized communications from us||Legitimate Interests (of us, so we can ensure the Huggg Service is as useful and enjoyable as possible).|
|To enable you to receive Hugggs.||Legitimate Interests (of us, to enable us to fulfil our contract with the person who has bought you a Huggg).|
|To restrict the purchase of age-restricted items to persons over the required age.||Necessary for us to comply with legal or regulatory obligations.|
|Consent to place cookies on your device (if you do not want us to place cookies on your device you can change your browser settings. Further information about how to do this is set out below).
Legitimate Interests to display adverts targeted at you (of us and our advertising partners, to ensure adverts which are likely to be of most interest to you are displayed to you).
|To better understand how you interact with and use the Huggg Service.||Legitimate Interests (of us, so we can understand how our customers use the Huggg Service to help us make improvements in future).|
|To develop our offering and the layout of the Huggg Service.||Legitimate Interests (of us, so we can ensure the Huggg Service is as useful and enjoyable as possible).|
|To share your personal information with our third party service providers (as set out in the ‘with whom is your personal information shared’ section below).||Legitimate Interests (of us, so we can benefit from the expertise of third party service providers to deliver the Huggg Service and for service efficiencies).|
with whom is your personal information shared?
We will never sell, trade, or rent your personal information to others, however we may share your information with selected third parties including:
- advertisers and advertising networks that require the data to select and serve adverts about our services to you and others. It will only be passed to third party advertisers in order to provide services on our own behalf; and
- third party data, service and software providers that assist us in the function, improvement and optimisation of our applications.
We may also disclose depersonalised data (such as aggregated statistics) about the users of the Huggg Service in order to describe our sales, customers, traffic patterns and other information to prospective partners, advertisers, investors and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifying information.
We may occasionally be required by law, court order or governmental authority to disclose certain types of personal information. Examples of the type of situation where this would occur are:
- in the administration of justice; and
- where we have to defend ourselves legally.
Finally, in the event of a reorganisation, sale or takeover we may need to disclose personal information to new entities within our group or potential acquirers and our and their advisers.
how long do we retain your personal information?
We will retain your personal information for so long as you are registered with the Huggg Service and for up to 6 years thereafter. Where such personal information is no longer necessary we may delete it sooner.
the requirements of data protection law
We regard the lawful and correct treatment of your personal information by us as very important to our successful operation, and to maintaining confidence between us and our users. We ensure that our organisation treats personal information lawfully and correctly. To this end we fully endorse and adhere to our obligations under data protection laws. In particular:
- we will only collect sufficient personal information for the uses set out above;
- we will endeavour to keep your personal information up-to-date;
- we will not retain your personal information longer than necessary unless required to do so by law;
- we will operate appropriate technical and organisational processes to protect your personal information against unauthorised or unlawful access or processing and against accidental loss or destruction; and
- we will not transfer your personal information outside the European Economic Area to a country which does not offer the same level of protection as that offered by data protection laws which apply to us, such as the GDPR, unless safeguards are in place to protect your personal information to the standards that apply within the EEA.
We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorised access, use, or disclosure. For example, we procure the storage of personal information you provide on cloud storage facilities, access to which is limited using password protection.
Under certain circumstances, by law you have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal data (commonly known as a “right to be forgotten”). This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data where we are relying on a legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground, and provided that we do not have compelling legitimate interests to override such objection.
- Object to processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If at any time you do not want your information used for direct marketing purposes please contact us at email@example.com or follow the instructions to unsubscribe within the marketing message. Please note that if you opt out of any marketing we will retain a record of your personal data to ensure that you do not receive future marketing messages from us.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to another party.
- Complain to a relevant supervisory authority in respect of our processing of your personal data, which will be the Information Commissioner’s Office in the UK. However, if you have any concerns about how we handle your personal data, we encourage you to contact us in the first instance so that we can work with you to resolve them.
If you want to review, verify, correct, request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please send us an email at firstname.lastname@example.org.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
Please be aware that the rights above are not absolute and there may be circumstances where we are unable to (or are not obliged to) comply with your request (either wholly or in part). In such cases we will explain why we cannot comply with the request.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is to ensure that personal data is not disclosed to any person who has no right to receive it.
right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to. Please note, however, that in most cases we do not rely on your consent to process your personal data.
informing us of changes to your personal data
We are required to ensure that the personal information we hold about you is accurate and up-to-date. Therefore we request that you notify us as soon as possible of any changes to your personal information.
We do not knowingly collect information from children and do not target or direct our site to children. Where we do collect information from children we will ensure that all processing and information provided is appropriate to the age of the child.
Cookies are small files that websites save to your hard disk or to your browser’s memory. You have the ability to accept or decline cookies. Most Internet browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies or to notify you when a cookie is being placed on your computer. If you choose to decline cookies, you may not be able to fully experience the features of the Huggg Service or other websites that you visit and apps that you use. To learn more about cookies and how to disable them we recommend you visit the Information Commissioner’s website at http://ico.org.uk/for_the_public/topic_specific_guides/online/cookies.
The types of cookies used on the Huggg Service are set out below.
Promotional cookies collect information about your browsing in order to deliver promotions relevant to you and your interests as well as your IP address in order to determine your geographic location and for fraud filtering. They are usually placed by third party advertising networks. They remember that you have visited a website and this information is shared with other organisations such as media publishers.
These organisations do this in order to provide you with targeted adverts more relevant to you and your interests. This type of advertising can include targeting you based on what pages of our applications you have visited and online behavioural advertising based on your browsing history. You can learn more about third party marketing cookies and how to delete them at https://www.youronlinechoices.com.
We may from time to time use this type of cookie on our applications to deliver promotions relevant to you. Promotional cookies may also be used to limit the number of times you see a promotion as well as help measure the effectiveness of the promotion.
When we send you an email, we may track whether you have opened that email and whether you have clicked any links it may contain. This helps us measure and improve the performance of our email campaigns.
Our applications use Google Analytics, a web analytics service provided by Google, Inc. (‘Google’). The cookies used by Google Analytics are third party cookies referred to above, and help our applications analyse how you use them. The information generated by the cookie about your use of our applications (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information to provide us with reports on application activity and other services relating to application activity. For more information about how Google uses your data please see Google’s Privacy & Terms at https://policies.google.com/technologies/partner-sites?hl=en-GB&gl=uk. You can opt out of Google Analytics cookies by using this Google Analytics Opt-Out Add-on at https://tools.google.com/dlpage/gaoptout?hl=en.
Social Sharing Cookies provide you with additional functionality to share content from our applications to social media websites and email using the social media widgets or buttons found on our applications. Use of these widgets or buttons may place a cookie on your device to make their service easier to use and to ensure your interaction is displayed on webpages (e.g. the social share count cache is updated). We encourage you to review each provider’s privacy information before using any such service.
The cookies we use, including analytics cookies, are used solely in relation to the provision of the Huggg Service, advertising and so as to better understand how you interact with the Huggg Service. They allow us to:
- monitor the number of people using our websites and applications and monitor their activities;
- see how people arrive at our website and applications;
- gather technical information about people using our websites and applications, such as their geographic location and the type of web browsers they are using; and
- display adverts on other websites and applications, to people who have previously accessed our websites and applications. We cannot identify individuals to whom adverts may be displayed.