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Privacy Policy

Effective date: February 21, 2020

Hugo Corporation ("us", "we", or"our") operates the www.hugo.team website and associated web application (collectively the "Service"). This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. We use your data to provide and improve the Service. By using the Service, you acknowledge that your personal data will be processed as described in this Policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from www.hugo.team.

Definitions

Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically either generated bythe use of the Service or from the Service infrastructure itself (for example,the duration of a page visit).

Cookies

Cookies are small pieces of data stored on a User’s device.

Data Controller

Data Controller means a person who (either alone or jointly orin common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data and are located at 1700 Montgomery St, Suite 108, San Francisco CA 94111.

Data Processor (or Service Providers)

Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

Data Subject

Data Subject is any living individual who is the subject of Personal Data.

User

The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

Information Collection And Use

We collect several different types of information for various purposesto provide and improve our Service to you.

Types of Data Collected

Personal Data

While visitor our website or using our Service, we may ask you to provide us with certain Personal Data. The Personal Data we may collect includes, but is not limited to:

·       Email address

·       First name and last name

·       Address, State, Province, ZIP/Postal code, City, Country

·       Company and job title

·       Profile picture

·       Cookies and Usage Data

We may use your Personal Data as further described in this Privacy Policy, such as to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Usage Data

We also automatically collect information how the Service is accessed and used. This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service. We and our Service Providers also use beacons and tags in HTML emails to our customers to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • We use Session Cookies to operate our Service.
  • We use Preference Cookies to remember your preferences and various settings.
  • We use Security Cookies for security purposes.

Use of Data

Hugo Corporation uses the collected data for various purposes:

  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our website and Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
  • To assist us in advertising on unaffiliated websites and in evaluating the success of our adverting campaigns (including our online targeted advertising and offline promotional campaigns)
  • To administer surveys and questionnaires, such as for market research or customer satisfaction purposes
  • To comply with legal obligations, as part of our general business operations, and for other business administration purposes
  • Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of our Terms of Use or this Privacy Policy.

Retention of Data

Hugo Corporation will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Hugo Corporation will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer Of Data

Your information, including Personal Data, may be transferred to— and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including PersonalData, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Hugo Corporation will take steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information, including entering into data transfer agreements, or for Personal Data being transferred from the European EconomicArea (EEA), using the EU Commission approved standard contractual clauses, orby relying on certification schemes such as the E.U. – U.S. Privacy Shield andSwiss – U.S. Privacy Shield for individuals located in Switzerland. You may have a right to details of the mechanisms under which your Personal Data is transferred outside the EEA..

Disclosure Of Data

Business Transaction

If Hugo Corporation is involved in an actual or contemplated merger, acquisition or asset sale, financing, or a restructuring, your Personal Data may be transferred to another company. We will provide notice before yourPersonal Data is transferred and becomes subject to a different Privacy Policy. As part of the business transfer process, we may share certain of your PersonalData with lenders, auditors, and advisors, including attorneys and consultants.

Disclosure for Law Enforcement

Under certain circumstances, Hugo Corporation may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Affiliates

We may disclose the information we collect from and about you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your Personal Data will be subject to this Policy.

Legal Requirements

Hugo Corporation may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Hugo Corporation
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Aggregate and De-Identified Information

We share aggregate, anonymized, or de-identified information about website visitors and Services users with others for marketing, advertising, research, or similar purposes.

Security Of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

"Do Not Track" Signals

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Rights

Hugo Corporation aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data as required by applicable law.

Whenever made possible, you can update your Personal Data directly within your account settings section. If you are unable to change your Personal Data, please contact us to make the required changes.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, under applicable law, you may have the right:

  • To access and receive a copy of the Personal Data we hold about you
  • To rectify any PersonalData held about you that is inaccurate
  • To request the deletion ofPersonal Data held about you
  • To object to any processing of your Personal Data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
  • To restrict the use of your Personal Data when (i) you contest the accuracy of the data; (ii) the use is unlawful but you do not want us to erase the data; (iii) we no longer need the Personal Data for the relevant purposes, but we require it for the establishment, exercise, or defense of legal claims; or (iv) you have objected to our Personal Data use where such use is justified on our legitimate interests and we must verify as to whether we have a compelling interest to continue to use your data. We can continue to use your Personal Data following a request for restriction, where: we have your consent; or to establish, exercise or defend legal claims; or to protect the rights of another natural or legal person.

You have the right to data portability for the information you provide to Hugo Corporation. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it. Please note that we may ask you to verify your identity before responding to such requests.

Data Subjects in the EEA have a right to lodge a complaint with their local supervisory authority if they have concerns about how we are processing their Personal Data. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

Service Providers

We may employ third party companies and individuals to perform functions on our behalf, including to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We recommend you review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy

Our Service does not address anyone under the age of 13 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy please contact us by email at privacy@hugo.team.

To learn more about Hugo's GDPR, Privacy Shield and SOCII compliance, visit our Security Center.

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