Privacy Policy of Shuggr

Summary

Your privacy is most important to us. This privacy policy should help you understand how we collect, process, use and safeguard your personal data.

You agree to this privacy policy when you use our products and services.
The English text of this privacy policy is the authoritative version.

This policy was last updated on November 20, 2019.

Who controls my personal data?

Shuggr Ltd. is the data controller of your personal data that we collect, use or otherwise process in connection with our products and services.

How can I contact you?

If you have any questions, please contact us:

Data Protection Officer (EU Representative according to GDPR Article 27)
Shuggr Ltd.
7 Bell Yard
London
WC2A 2JR
United Kingdom

hello@shuggr.com

What is personal data?

Personal data is any information that can be used to identify you personally, such as your name, age, address, location, ethnicity, sexualily, photos, comments, preferences, behavior, and more.

When is personal data handled?

We collect, use or otherwise process personal data when you use any of our products or services as a customer or potential customer, such as our mobile apps, our websites, when you contact us, or when you hold any other business relation with us. This also applies to third parties who provide products and services to you on our behalf.

The products and services provided are intended for adults only. You must be of legal age in your country to use our products and services. We do not knowingly handle personal data of minors.

Why is personal data collected?

Your personal data is collected to provide products and services to you, to improve your experience with these products and services, and to maintain our business relation with you.

Your personal data may be processed automatically to improve our products and services. Automatic processing may include automated decision-making and personalization of how our products and services are provided to you, such as the content that is being presented to you.

What personal data is collected?

The following personal data may be collected to provide products and services and may be shared with third parties who assist us in providing products and services to you or who provide products and services to you on our behalf.

  • Analytics data, such as product and service usage
  • App data, such as install date, installer, version
  • Advertising data, such as identifiers for advertising, advertisement interaction
  • User profile data*, such as age, weight, height, pictures, user follows, user blocks, location (geographic position), as well as data that may be considered sensitive data under applicable law, such as ethnic identity, sexual identity, sexual preferences
  • Account data, such as email address, phone number, registration date, account status, unique user identifier
  • Login data, such as last login date, session status, authentication tokens
  • Subscription and purchase data*, such as subscription status, purchased plan
  • User generated content*, such as chat messages, posts, likes, comments, accommodation offerings
  • Moderation data, such as terms and policy violations, user reports, content reports, moderation actions
  • Device data, such as operating system, network status, crash log, push notification token, time zone, locale
  • Network data, such as IP address, request date, client status
  • Support data, such as customer service communication via email and other channels
  • Product and service feedback*, such as feature suggestion, rating, review

Items with a star symbol (*) may be shared with other users of our products and services.

With whom is personal data shared?

Your personal data may be shared with third parties who assist us in providing you with our products and services, or third parties who provide products and services to you on our behalf.

These third parties are:

  • Government entities, law enforcement agencies, regulatory authorities and similar entities, for activities such as to respond to legal requests.
  • Judicial courts, law firms, and similar entities, for activities such as to enforce our terms and contracts.
  • Advertising agencies, advertising networks and similar entities, for activities such as to serve you ads and improve our business relation with you.
  • Analytics providers and similar entities, for activities such as to improve your experience with our products and services and improve our business relation with you.
  • Technology service providers, internet infrastructure providers, cloud service providers, cloud software providers and similar entities, for activities such as to assist us to provide you with products and services.
  • Customer service system providers and similar entities, for activities such as to process and answer your support requests.
  • Office services providers and similar entities, for activities such as to perform administrative office tasks, process incoming mail and manage schedules.
  • Credit rating agencies, financial service providers and similar entities, for activities such as to process payments, carry out anti-fraud screening, and verify credit rating.
  • Companies, subsidiaries, joint ventures or other companies under common control, for activities such as to improve our business relation with you.
  • Companies which acquire our company, assets or parts of our business and therefore become the data controller of your personal data as referred to in "Who controls my personal data?".

With whom is personal data not shared?

We will not share your personal data with any government or other third party which may cause harm to you based on your sexual identity or otherwise violate your human rights. We will base our decision on the recommendations of international organizations, such as the United Nations.

How is sensitive personal data handled?

Some of your personal data may be considered sensitive and require special protection, according to applicable law. Sensitive data is identified as described in "What personal data is collected?".

You may provide, edit and remove sensitive personal data in our products and services at any time. Sensitive data may be visible to other users of our products and services, such as your user profile. If you provide sensitive personal data you give consent to its collection, use and otherwise processing.

How do we secure personal data?

We secure your personal data with the greatest care. We use technological and organizational measures to safeguard and protect your personal data.

How can you secure personal data?

You can secure your personal data by not sharing account login information with others. In addition, you can secure your account by not sharing third party login information, such as:

  • email account login information, because it can be used to reset your account password of our products and services;
  • social media account login information, if you use a social media account to log into our products and services;
  • device password or biometric authentication mechanism, because it can be used to access your device and applications, where you may stay logged in from previous sessions.

Be aware of internet fraud, such as “phishing”, where someone pretends to be someone else to illegally gather information from you. They may send you a link to a website that looks familiar to you, such as your online banking or a Shuggr login site. They may pretend that you won a prize or money and need you to send them information.

Be aware of “catfishing”, where someone pretends to want a sincere relationship with you, but the person may be using fake pictures and stories to request money from you.

We will never ask you for your account password, bank details or other sensitive personal information. If you are unsure about the authenticity of a request, please contact us.

How long is personal data stored?

Your personal data is stored for as long as necessary to provide you with products and services and for as long as required and permitted by law.

When you terminate your products and services with us, your personal data will be deleted from our systems. In some cases, your personal data may remain stored for up to 5 years where it may be too impractical to delete it, for example in data archives. In some cases, your personal data may remain stored as long as necessary to comply with legal obligations, to resolve disputes, to maintain the integrity of our business, or to enforce our terms and contracts. In some cases, your personal data will be converted to anonymized data which cannot be used to personally identify you.

Where is personal data stored?

Your personal data may be stored by us and third parties outside of the country or economic union in which you are located. Shuggr is registered in the United Kingdom, but your personal data may be stored outside of the United Kingdom and outside of the European Union.

We operate globally, therefore your personal data may be transferred outside of the country you are located in, for example, when a user who is outside of the country you are located in views your user profile. If you are located in or are a citizen of a member country of the European Union we utilize standard contractual clauses approved by the European Commission and rely on the European Commission's adequacy decisions about certain countries, as applicable, for data transfers to other countries.

Most third parties that assist us to provide products and services to you operate globally, therefore your personal data may be transferred outside of the country you are located in. The third parties are described in "With whom is personal data shared?".

You may have fewer legal rights regarding your personal data outside of the country you are located in.

What is the legal basis for handling personal data?

The legal basis to collect, use and otherwise process your personal data depends on the applicable law in your jurisdiction. The following list describes the legal basis in most cases.

  • Your consent to collect, use and otherwise process your personal data.
  • Your personal data is necessary to provide you with products and services and to fulfill our agreements and contracts with you.
  • It is in our legitimate interest to collect, use and otherwise process your personal data to perform our business relation with you.
  • Your personal data is necessary to protect the vital interests of you or another person or entity.
  • Your personal data is necessary for compliance with legal obligations.

How to request a copy of personal data?

You may request a copy of your personal data that is stored by us under applicable law. You can request your personal data from inside our products and services or by contacting us, as described in "How can I contact you?".

To process your request we will verify your identity to ensure that your personal data is only provided to you. In most cases, a copy of your personal data is provided free of charge.

Some data may be removed from your copy of personal data to protect the personal data rights of other users.

If you have terminated your products and services with us, your personal data is already deleted from our systems, as described in "How long is personal data stored?".

How are marketing communications handled?

If you are required by law to opt-in to receive marketing communications, we will ask for your consent. All other users automatically get the benefit of receiving marketing communications from us. Be aware that marketing communications can reference products and services from us or from third parties.

You can select which type of marketing communications you want to receive. You can also unsubscribe from all marketing communications. Even if you are unsubscribed you may still receive service communications that are related to your current products and services or your business relation with us in general.

How is personal data controlled for linked products and services?

You may be provided access to forgein products or services that are not covered by this privacy policy. These foreign products and services may be offered via links or ads. Before using a foreign product you should ready the applicable privacy policy. We do not control the personal data that you provide to foreign product and service providers. Shuggr does not accept responsibility for how they collect, use or otherwise process your personal data.

What personal data rights apply?

Your personal data rights depend on the laws that apply to you. If you are located in or are a citizen of a member country of the European Union, you have the following personal data rights:

  • You are transparently informed about your personal data rights and how your personal data is handled.
  • You can access your personal data.
  • You can modify and delete your personal data at any time.
  • You can withdraw consent that your personal data is being processed.
  • You are informed about the status of your personal data related requests.
  • You can file a complaint with your responsible data protection authority, for example, for member countries of the European Union you can find a list here.

How are policy updates communicated?

We may change this privacy policy at any time at our discretion. We will inform you about changes to this privacy policy, therefore it is important that you keep your contact details with us up-to-date. You should check this privacy policy from time to time to inform yourself about any changes. Your continued use of our products and services indicates your agreement to those changes.