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 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 are small pieces of data stored on a User’s device.
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 is any living individual who is the subject of Personal Data.
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.
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 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
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:
Use of Data
Hugo Corporation uses the collected data for various purposes:
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.
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.
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).
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.
Hugo Corporation may disclose your Personal Data in the good faith belief that such action is necessary to:
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.
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.
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.
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:
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.
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.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
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.
The General Data Protection Regulation (GDPR) is a regulation by which the European Parliament, the Council of the European Union, and the European Commission intend to improve data protection for all individuals within the European Union (EU).
Hugo is aware of new GDPR requirements and restrictions and works with its customers to address GDPR compliance.
Some of the key actions we’ve taken to ensure compliance include:
Appointment of a Data Protection Officer (DPO) to ensure that our policies and practices remain in compliance going forward and that we embrace a policy of data protection by design and by default.
A complete review of our policies and practices surrounding storage of customer data to ensure that any Personal Data is kept in a way that enables us to comply with the rights of individuals as provided under the GDPR.
We will provide a data processing agreement upon request to our EU customers.
A current list of Hugo's Subprocessors, are available here.
If you have any further questions regarding Hugo's approach to the GDPR, please feel free to contact us at firstname.lastname@example.org.
Hugo adheres to the EU-U.S. Privacy Shield Framework by adopting and implementing the EU-U.S. Privacy Shield Principles, which include a set of Supplemental Principles. Hugo also commits to adhere to the Swiss-U.S. Privacy Shield Framework by adopting and implementing the Swiss Privacy Shield Principles. We will refer to the EU-U.S. and Swiss Privacy Shield Principles collectively as the “Principles.” Our certification can be found at www.privacyshield.gov/list.
We obtain and process Personal Information in different capacities.
As a data controller, we collect and process EEA and Swiss Personal Information directly from individuals, either via our publicly available websites, including, or in connection with our customer, partner, and vendor relationships.
As a data processor, we process and store EEA and Swiss Personal Information obtained from our customers when providing theHugo application and related services (“Services”). In that context, we only process Personal Information on behalf of and at the instructions of our customers, which are the data controllers.
Hugo commits to subjecting to the Principles all Personal Information received from the EEA and Switzerland in reliance on the Privacy Shield (which includes both types of activities).
When using our Services, customers determine the categories of data they upload into our systems and the purposes for which the data is processed. Accordingly, customers are responsible for providing notice to the individuals from whom they have collected Personal Information.
When we process Personal Information in the context of our Services, we process and retain Personal Information only as necessary to provide our Services, or as required or permitted under applicable law.
In case of disclosure to an agent, we remain responsible for the processing of Personal Information received under the Privacy Shield and subsequently transferred to that agent if it processes such Personal Information in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the inconsistent processing.
When we process Personal Information in the context of our Services, we disclose Personal Information as necessary to provide the Services and as authorized in our agreements with customers.
We use reasonable and appropriate measures to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. You can read more about our security processes and infrastructure by clicking one of the tabs in our Security Center.
Where appropriate, Hugo provides you with access to the Personal Information that we maintain about you and the ability to correct, amend or delete that information when it is inaccurate or has been processed in violation of the Principles by sending a written request as indicated in “Contact Information” below. We will review your request in accordance with the Principles, and may limit or deny access to Personal Information where providing such access is unreasonably burdensome or expensive under the circumstances, or as otherwise permitted by the Principles.
If we intend to use your Personal Information for a purpose that is materially different from the purposes listed in this policy or if we intend to disclose it to a third party acting as a controller not previously identified, we will offer you the opportunity to opt-out of such uses and disclosures where it involves non-sensitive information or opt-in where sensitive information is involved.
When we process Personal Information in the context of our Services, we only process and disclose the data as necessary to provide the Services. Our customers control how the information they upload to the Services is disclosed and used, and how it can be modified. Accordingly, if you wish to request access, to limit use, or to limit disclosure of Personal Information uploaded to the Services by our customer, please contact the customer who submitted your data to our Services. If you provide us with the name of our customer that is processing your Personal Information, we will refer your request to that customer, and will support the customer as needed in responding to your request.
In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection and use of your Personal Information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at the contact information provided below. We have further committed to refer unresolved Privacy Shield complaints to the JAMS Privacy Shield Program, an alternative dispute resolution provider in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to to file a complaint. The services of JAMS are provided at no cost to you. We will cooperate with JAMS pursuant to the JAMS International Mediation Rules, which are accessible on the JAMS website at http://www.jamsadr.com. For residual complaints not fully or partially resolved by other means, you may be able to invoke binding arbitration as detailed in the Principles.
Hugo is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
If you have any questions, concerns or complaint regarding our privacy practices, or if you’d like to exercise your choices or rights, contact us via: