In addition to our commitment to your privacy, we have invested heavily in the security of your data. Some measures are outlined here:
Last updated January 15, 2019
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:
● Email Hugo’s Privacy and Data Protection Officer at email@example.com; or
● Mail at Hugo, ATTN: Privacy and Data Protection Officer, 1700 Montgomery St, Suite 108, San Francisco CA 94111
Last updated March 22, 2018
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 will be fully compliant with GDPR when it comes into effect.
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 Personally Identifiable Information (PII) is kept in a way that enables us to comply with the rights of individuals as provided under the GDPR.
Strong data protection commitments are a key part of GDPR’s requirements. We will provide a data processing agreement upon request to our EU customers.
If you have any further questions regarding Hugo's approach to the GDPR, please feel free to contact us at firstname.lastname@example.org.