i.
This Privacy Statement provides guidance and information to
SaGuLi Inc (“SABIMI”) customers
regarding the processing of personal data by SABIMI.
ii.
SABIMI ("us",
"we"
or "our")
is committed to protecting and respecting your privacy. This Statement together
with the Term and Conditions and Cookies Policy and the documents referred to in them
sets out the basis on which any personal data we collect from you or that you
provide to us (“Data”)
will be processed by us. Please read this Privacy Statement carefully to
understand our treatment and use of Data.
iii.
In this Privacy Statement, references to “you” means the
person whose personal information we collect, use and process.
iv.
We will use your personal data only for the purposes and in the
manner set forth below, which describes the steps we take to ensure the
processing of your personal data is in compliance with the Data Protection Acts
1988 and 2003 and any subsequent data protection and privacy legislation (the “Acts”), European Union
Law including the General Data Protection Regulation (the “GDPR”) and any
subsequent amendments (together the “Data
Protection Legislation”).
v.
If you do not agree with or are not comfortable with any aspect
of this Privacy Statement, your only remedy is to not become a customer of SABIMI.
vi.
We seek to maintain the privacy, accuracy, and confidentiality
of personal information (including your personal data) that we collect and use
concerning our customers.
For the purposes of the
Data Protection Legislation, the Data Controller is SaGuLi Inc. (operating as SABIMI)
is registered in (No. 1445 0003) Delaware, United States of America and has its
registered office 188 Grand Street Unit #201 New York, NY 10013.
The data protection
officer appointed in respect of your entity (if applicable) can be provided –
please see clause 13 for further contact information.
This Privacy Statement
applies to personal information that we collect, use and otherwise process
about you in connection with your relationship with us as a customer or
potential customer.
i.
As data controller, we may collect and
process the following categories of information about you:
a.
your personal information (e.g. name, gender, date of birth,
address, email and phone number);
b.
your authentication information (e.g. tokens); and
c.
your financial information (e.g. credit card number and billing
data).
i.
The legal basis for this use and other
processing will include (as relevant):
a.
process your account;
b.
provide services relating to your account and to work on
improving our services to you (including service communication, insight,
research, customer surveys and feedback);
c.
to provide you with relevant marketing communications;
d.
to support other administrative purposes;
e.
comply with all legal and regulatory requirements; and
f.
where you have given us permission, contact you from time to
time to keep you up to date with limited offers, new services, company news and
other promotions.
ii.
The main purposes for which we use your
personal information are:
a.
if you have provided us with your consent to the processing of
your personal data;
b.
to enable us to perform our obligations under any contract with
you;
c.
processing for legitimate interests provided these are not
overridden by your interests and fundamental rights and freedoms (this includes
our own legitimate interests and those of other entities in the SABIMI), in
particular this is relevant when we use and process your personal data in order
to respond to your enquiries and to address our good governance obligations;
and
d.
we may also disclose your personal information to governmental
and regulatory bodies and other third parties where required to do so by
applicable law, such as to comply with a court order or a request from a
regulator or similar legal process or where otherwise necessary to comply with
a legal obligation or for the administration of justice.
iii.
In addition, in the event of a merger, acquisition, or any form
of sale of some or all of our assets to a third party, we may also disclose
your personal information to the third parties concerned or their professional
advisors. In the event of such a transaction, the personal information held by SABIMI
will be among the assets transferred to the buyer.
iv.
The provision of personal data is a contractual requirement and
may also be a statutory requirement, and is necessary to process your
application or for the performance of a contract. If your personal data cannot
be processed this may have an impact on fulfilling our rights and obligations.
v.
We do not knowingly process personal data from persons under the
age of 13 years. If it comes to our attention that we are processing such
personal data, we shall delete such personal data immediately.
vi.
When you close your account, we may continue to process your
personal data, to the extent permitted by applicable law, for the purposes
detailed above.
i.
Due to the global nature of SABIMI, your personal data will be
transferred to SABIMI entities located in other countries, including outside
the European Economic Area (“EEA”).
These other countries may either have different data protection laws than your
country of residence or they may not have data protection laws. Steps will
however be taken to put in place safeguards (including around security) to
protect your personal data when it is in other countries. For example, in
respect of Europe, this includes use of European Model Clause contracts.
You can find out what these are online at the following address: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm. If you
have any questions or wish to be provided with a copy please see clause 13 for
further contact information. Please note commercially sensitive information may
be removed/blanked out from copies supplied to you.
ii.
Your personal information may be transferred, stored and
processed in one or more countries outside the European Economic Area (“EEA”), including the
United States of America.
iii.
For transfers of your personal data to third parties outside of
the EEA, we take additional steps in line with data protection laws. These
include EU Commission approved forms of contract with the relevant recipients
of your information, whether members of SABIMI or otherwise.
iv.
In addition, we take reasonable steps to ensure that your
personal information is adequately protected in accordance with the Acts and
the GDPR.
i.
Your personal data will not be kept for longer than is necessary
to fulfil the specific purposes outlined in this Privacy Statement and Cookies
Policy and to allow us to comply with our legal requirements, including,
without limitation, any tax and commercial obligations.
ii.
The criteria we use to determine data
retention periods includes the following:
a.
Retention in
case of queries
We may retain your personal data for a
reasonable period after you have enquired about Services, in case of follow up
queries from you.
b.
Retention in
case of claims
We may retain your personal data for the
period in which you might legally bring claims against us (this means we will
retain it for at least 7 years) if and to the extent this is relevant.
c.
Retention in
accordance with legal and regulatory requirements
We will consider whether we need to retain
your personal data after the period of retention in the case of queries or
claims (above) because of a legal or regulatory requirement. Some or all of
these criteria may be relevant to retention of your personal data collected
from you in connection with our Services.
d.
Retention
permitted under applicable law
We will continue to retain personal data
where necessary to provide our services to you and the retention of such
personal data is necessary for the purposes of pursuing our legitimate
interests or where it is necessary for public interest purposes.
iii.
Please note that, although reasonable
efforts will be taken, it may not always be possible to completely remove or
delete all of your personal information from our databases because of back-ups
and other technical reasons. Where this is the case, we will take steps
to ensure that your personal data is suppressed in order to render it unusable.
i.
You may have various rights under data
privacy laws in your country (where applicable). These may include (as
relevant):
a.
the right to withdraw your consent to the processing of your
personal data. However, we may continue to process your personal information if
there is an alternative legal basis for the processing;
b.
the right to request access to or a copy of the personal data we
hold about you. Please note that there is no fee for this request and any
request for a copy of your personal data will be processed within thirty (30)
days in accordance with the GDPR;
c.
the right to rectification including to require us to correct
inaccurate personal data;
d.
the right to request restriction of
processing concerning you or to object to processing of your personal data if:
§ processing
is based on legitimate interests or the performance of a task in the public
interest or exercise of official authority;
§ processed
for direct marketing; or
§ processed
for the purposes of scientific or historical research and statistics;
e.
the right to prevent further processing in
specific circumstances and where there is no other lawful ground for continuing
to process that information. These include for example:
§ where the
personal data is no longer necessary in relation to the purpose for which it was
originally collected/processed;
§ where you
withdraw consent; or
§ where you
object to us processing your information;
f.
the right to request the erasure of your personal data where it
is no longer necessary for us to retain it;
g.
the right to block or suppress processing of personal
information. While we are entitled to store your personal information, we
cannot further process it if you request it to be blocked;
h.
the right to data portability including to obtain personal data
in a commonly used machine readable format in certain circumstances such as
where our processing of it is based on a consent; and
i.
the right to object to automated decision making including
profiling (if any) that has a legal or significant effect on you as an
individual; and the right to withdraw your consent to any processing for which
you have previously given that consent.
ii.
You have the right to be informed of the identity of the privacy
local representative (if we are required by law to have a local
representative);
iii.
You also have the right to any details of any persons to whom SABIMI
disclosed your personal data (unless SABIMI is prohibited from providing such
information pursuant to applicable law)
iv.
Please see clause 13 if you wish to exercise any of these rights
(as relevant).
Without prejudice to any
other administrative or judicial remedy you might have, you may have the right
under data privacy laws in your country (where applicable) to lodge a complaint
with the relevant data protection supervisory authority in your country (i.e.
the Office of the Data Protection Commissioner in Ireland) if you consider that
we have infringed applicable data privacy laws when processing your personal
data. This means the country where you are habitually resident, where you work
or where the alleged infringement took place.
i.
We endeavour to use appropriate technical and physical security
measures to protect your personal data which is transmitted, stored or
otherwise processed by us, from accidental or unlawful destruction, loss,
alteration, unauthorised disclosure of, or access. These measures include:
storing personal data in a private database which is accessed via an internal
control panel protected with the username, password and IP address of our
authorized users; storing hashed information as opposed to passwords and using
secure cloud storage on AWS for database backups. Our service providers are
also selected carefully and required to use appropriate protective measures.
ii.
As effective as modern security practices are, no physical or
electronic security system is entirely secure. The transmission of information
via the internet is not completely secure. Although we will do our best to
protect your Data, we cannot guarantee the security of your Data transmitted to
our Site. Any transmission of Data is at your own risk. Once we receive your
Data, we will use appropriate security measures to seek to prevent unauthorised
access. We will continue to revise policies and implement additional security
features as new technologies become available.
iii.
In the event that there is an interception or unauthorised
access to your personal data, we will not be liable or responsible for any
resulting misuse of your personal information.
We reserve the right to
change this Privacy Statement at any time in our sole discretion. If we make
changes, we will send you an in app notification so that you can see what information
we gather, how we might use that information and in what circumstances we may
disclose it.
For further information or if you have any questions about this Privacy Statement, please contact https://sabimi.com/contact.
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