The General Data Protection Regulation (GDPR) replaced the requirements of the Data Protection Act (DPA) 1998 in May 2018. The General Data Protection Regulation (GDPR) includes rules on giving privacy information to data subjects in Articles 12, 13 and 14. These are more detailed and specific than in the DPA and place an emphasis on making privacy notices understandable and accessible.
This Privacy Notice sets out how we may use, process and store your personal identifiable information (PII). We may get that information from you or our partners, through contracts or other legal arrangements you have with us or our partners on behalf of us, in order to deliver contractual/legal obligations. In other cases, we will get that information from you with your permission and consent, or we may receive your personal information from third parties who you have given consent to pass this information on to us.
Sugaura may collect information from you because we have a legal reason (allowed by law or under contract) to collect the information, or because you have consented for us to do so for a specific purpose.
You may give us information about you with your consent, for example:
- through Contractual agreements
- by filling in a form or sending us an e-mail
- marketing responses
This information may be personal, financial, business or related to your contractual history with us.
You may give us information for legal reasons, such as to enter into a contract with us, when you are buying goods or services from us, or when you are considering these options.
Information we collect about you
If you visit our website or member communities, we may automatically collect information about you, for example:
- Technical information
- IP addresses
- Information about what type of device you use to connect to our website
- How you interact with our website
Information we receive from other sources
We may receive information about you if you use any of the other websites we operate, any other services we provide, or from our business partners instructed to collect information on our behalf.
We also work with third parties, including, for example, business partners, sub-contractors, credit agencies, payment companies and may receive information about you from them as part of the service we provide you, or for legal reasons.
We use “cookies” to help you personalise your online experience. A cookie is a text file that is placed on your hard disk by a Web server. Cookies are not used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a Web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalise pages on our Websites, or register for the Subscription Service, a cookie helps us to recall your specific information on subsequent visits. When you return to the same Website, the information you previously provided can be retrieved, so you can easily use the customised features.
You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Sugaura website you visit. Sugaura keeps track of the websites and pages you visit within Sugaura.com, in order to determine what portion of the Sugaura website is the most popular or most used. This data is used to deliver customised content and promotions within the Sugaura and Service Portal to customers whose behaviour indicates that they are interested in a particular subject area.
Why does Sugaura collect Personal Identifiable Information (PII)?
Sugaura collects PII for the some or all of following reasons:
- To provide services and support to you after you have entered into a contract
- To provide information about products or services you have shown interest in, if you are already an existingSugaura customer
- To provide information to you about products or services you have purchased from us, or related products or services
- To provide goods or services to you under contrac
- For legal reasons, for example, if you have entered into a contract with us
- To provide information to you about our products and services if you have consented to receive it.
What legal basis does Sugaura have for processing PII?
Sugaura may process your information because:
- We have a contract with you
- You have given us permission to do so
- We must provide services to you after you have purchased something from us
- To comply with the law.
Who might Sugaura share PII information with?
Sugaura may share your personal information with third parties, either because you have consented to allow us to do so or for legal reasons. For example, we may share your personal information with:
- Sub-contractors and third parties for the purpose of providing or continuing to provide the products and services we are contracted to
- Third parties because you have given consent
- When Sugaura must comply with a legal obligation
- To protect the rights, property, or safety of Nicho Media Limited t/as Sugaura, our customers or others
- We will exchange information with other companies or organisations to prevent fraud or to reduce our credit risks
Sugaura may, from time to time, provide third parties with data that has been anonymised, which means that your personal information that could be used to identify you has been removed from the data.
Transmission and storage of personal data
Sugaura primarily store and process PII data electronically.
How long is PII retained?
Sugaura will not retain PII for longer than required and we will keep this;
For as long as required by law
Until we no longer have a valid reason for keeping it
Until you request us to stop using it i.e. Right to Erasure
Refusal to provide Sugaura with personal information?
If the personal information is necessary in order to supply goods or services to you under a contract between you and Sugaura, then we will not be able to enter into that contract or provide the products or services without that information.
Sugaura will respect individual’s legal rights to their data. These cover;
- The right to be informed – Sugaura is publishing this Privacy Notice to keep you informed as to what we do with your personal information. We strive to be transparent about how we use PII.
- The right to access – the right to access your information. Contact Sugaura if you wish to access the personal information Sugauraholds about you.
- The right to rectification – if the information Sugaura holds about you is inaccurate or not complete, you have the right to ask us to rectify it. If that data has been passed to a third party with your consent or for legal reasons, then we must also ask them to rectify the data.
- The right to erasure – sometimes referred to as ‘the right to be forgotten’. If you want Sugaura to erase all your personal data and we do not have a legal reason to continue to process and hold it, please contact us.
- The right to restrict processing – you have the right to ask Sugaura to restrict how we process your data. This means we are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future.
- The right to data portability – Sugaura must allow you to obtain and reuse your personal data for your own purposes across services in a safe and secure way without this effecting the usability of your data. The data must be held by us by consent or for the performance of a contract.
- The right to object – Data subjects have the right to object to Sugaura processing their data even if it is based on our legitimate interests.
- The right to withdraw consent – If you have given us your consent to process your data but change your mind later, you have the right to withdraw your consent at any time, and Sugaura must stop processing your data.
- The right to complain to a higher body – data subjects have the right to complain to the ICO if they feel that Sugaura is not meeting its obligations in terms of GDPR or has not responded to their requests to solve a problem. Contact details here: https://ico.org.uk/concerns/
Links to Other Websites
From time to time, our website may contain links to and from websites of our partner networks, advertisers, social media sites etc. If you follow a link to any of these websites, please note that these websites may have their own privacy notices and that we do not accept any responsibility or liability for any such notices. Please check these notices, where available, before you submit any personal data to these websites.
Changes to Our Privacy Notice
Sugaura may change this notice from time to time in the future. Any such changes will be posted here and, where appropriate, notified to you in writing. We advise you to check back frequently to see any updates or changes.