Privacy

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.

Hugo Corporation (“Hugo”) has created this Privacy Shield Privacy Policy to help you learn about how we handle Personal Information that is collected in the European Economic Area (the"EEA") and Switzerland and transferred to Hugo in the US.

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.

This Privacy Shield Privacy Policy supplements the Hugo Privacy Policy. Unless specifically defined in this policy, the terms in this Privacy Shield Privacy Policy have the same meaning as in our Privacy Policy. In case of conflict between our Privacy Policy and this Privacy Shield Privacy Policy, this Privacy Shield Privacy Policy prevails. In case of conflict between this Privacy Shield Privacy Policy and the Principles, the Principles will govern.

1. How we obtain Personal Information

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).

2. Notice

We provide information in our Privacy Policy regarding our privacy practices.

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.

3. Data Integrity and Purpose Limitation

We may use any Personal Information we obtain for the purposes indicated in our Privacy Policy or as otherwise notified to you. We will not process Personal Data in a way that is incompatible with these purposes or as subsequently authorized by you. We take reasonable steps to limit the collection and usage of Personal Information to that which is relevant for the intended purposes for which it was collected, and to ensure that such Personal Information is reliable, accurate, complete, and current. We will adhere to the Principles for as long as we retain the Personal Information collected under the Privacy Shield.

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.

4. Data Disclosures

We disclose Personal Information as described in our Privacy Policy. If we disclose it to a third party acting as a data controller or as an agent, we will comply with, and protect the Personal Information as provided in, the Accountability for Onward Transfer Principle.

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.

As stated in our Privacy Policy, we may also share your Personal Information that we control or process in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

5. Data Security

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.

6. Choice and Access

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.

7. Recourse and Enforcement

We conduct an annual self-assessment of our Personal Information practices to verify that the attestations and assertions made in this Privacy Shield Privacy Policy are true and have been implemented as represented.

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).

8. Changes to the Privacy Shield Privacy Policy

This Privacy Shield Privacy Policy maybe changed from time to time, consistent with the requirements of the Privacy Shield. You can determine when this Privacy Shield Privacy Policy was last revised by referring to the "Last Updated" legend at the top of this page. Any changes to this Privacy Shield Privacy Policy will become effective when we post the revised version on our website.

9. Contact Information

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 privacy@hugo.team; or
• Mail at Hugo, ATTN: Privacy and Data Protection Officer, 1700 Montgomery St, Suite 108, San Francisco CA 94111