Privacy policy - Sugi Wallet

At Sofitto NV we respect and protect your privacy. This Privacy Policy describes how we collect personal information when you download and use Sugi Wallet mobile app. Please read this policy before you register and access our service. 

When we process your personal data, we do so with your consent and/or as necessary to provide our services and products, fulfil our contractual and legal obligations, or other legitimate interests. Remember to revisit this page regularly to review updated versions of this Policy to ensure that you are aware of what information we collect, how we use it and how we might share it. We will also notify all registered users via the email that was used to register about any changes in our Privacy policy that go beyond smaller editing changes.  

When we process your personal data, we do so with your consent and/or as necessary to provide our services and products, fulfil our contractual obligations, or other legitimate interests. 

If you have any questions regarding this Policy or want more details on how we process your data, please contact us at privacy@sugi.io.

Which data we collect about you and how?

We collect information from you directly when you use our website and contact us about our products, make the order, apply for our newsletter, interact with us through social media, complete our surveys, submit an online referral or use the Sugi Wallet app. We collect name, surname, address, telephone number, email, payment data and other data you submit. When you choose to participate in a survey we do not process, use or keep any personal data about you in connection with your participation in a survey, unless you specifically agree to provide that information. We hold the responses only for anonymous statistics.

Some data may be also collected from time to time indirectly when you browse our website or open our email (tracking tools, pixel tags...) in order to improve and personalize your experience and measure our marketing activities. We will collect following information:

1. Which pages you visited immediately before, and after our site;
2. Which device, browser and operating system did you use;
3. How long were you browsing our site;
4. Where did you access it from (IP address, type of device and browser, time zone settings, language settings, bowser version, operating system, …);
5. If you opened our email/ notification and took the desired action.

 How is your information used?

We may use your information to:

1. Respond to your requests or questions;
2. Process orders that you have submitted;
3. Seek your opinion on the services we provide;
4. Send you information about new products, special offers, referral programs, promotions you have requested to opt-in;
5. Verify referral discount eligibility;
6. Verify referral program refund/ payment eligibility;
7. Send you our newsletters or bulletins to provide key announcements and updates;
8. Improve our products and services;
9. To comply with legal, regulatory, audit, security requirements, including checking your identity against money laundering, terrorist financing or similar watch established or enforced by government regulators;
10. Monitor for fraud and manage risk;
11. Notify you of changes to our terms, conditions, and policies;
12. Otherwise with your consent or as permitted or required by law.

Please note that we collect and aggregate information at the user level for buyers of the Sugi Card, users of the Sugi Wallet, subscribers of the Sugi newsletters and referral program participants only. 

With whom we share your data?

We share information with third parties who are performing various services on our behalf:

1. Business partners (such as distributor who will deliver you a package or customize a product as you order).
2. Analytics and search engine providers that assist us in the improvement of optimization of our site, products and services (Google analytics, Crashlytics…).
3. Third parties to verify your identity, protect against fraud, comply with anti-money laundering laws and to confirm your eligibility to use our products and services.
4. Social media plugins (Facebook, Twitter, Linkedin, Medium, Reddit, ...) – functions of this social media companies are integrated into our website. If you decide to take action and are logged in to specific social media account, the data will be transmitted to this company.
5. Remarketing providers (Google).

 They are obliged to use the data only to perform agreed services. They are not authorized by us to use the information for their own activities.

We may also share data about you if we are required to do so by law.

How we protect your data?

We maintain high administrative, technical and physical safeguards to protect personal data against unauthorized access, use or disclosure as well as unlawful destruction, loss or alteration. These measures include computer safeguards and secured files and buildings.

Does Sofitto NV transfer European Customer Personal Data outside the European Union?

Personal data of European (and other) customers can be transferred and processed in one or more other countries than Belgium, within or outside the European Union (EU). Sofitto NV shall only transfer personal data of customers outside the EU to those countries which the European Commission believes offers an adequate level of protection, or where Sofitto NV has put in place appropriate safeguards to preserve Customer privacy.

How long we store your data?

As long as you let us or is needed for the relevant activity or by the law.

What are your rights?

At any time you can give free of charge a request:

1. To receive information about personal data we are storing about you, its origin and the purpose of data processing;
2. To correct, block or delete your personal data;
3. To stop processing of your personal data;
4. To cancel consent about using your data which you have previously given us.

You have the right to file a complaint with the Supervisory Authority, in the Member State of your habitual residence, place of work or where the alleged infringement happened.

The above rights are subject to legal restrictions, as provided by the applicable EU privacy law.

Some general remarks:

Under this privacy policy, you may not transfer any of your rights to any other person. We may transfer our rights under this privacy policy where we strongly believe that your rights will not be affected and if we have a legitimate reason to do so.

If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

This Agreement will be governed by and interpreted according to the law Belgium. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the Belgian courts.