Privacy Policy

This Privacy Policy is designed to help you understand how Sugar (collectively with any subsidiaries, called “Sugar,” “we,” “us,” and “our”) collects, uses, and shares your personal information and to help you understand and exercise your privacy rights.

SCOPE

This Privacy Policy applies to personal information processed by us, through our websites, mobile applications, games that we operate, and any other services or interfaces owned or controlled by Sugar that link to this Privacy Policy (each a “Service” and together, the “Services”).

CHANGES TO OUR PRIVACY POLICY

We may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. We encourage you to periodically review this privacy statement to learn how Sugar is protecting your information. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services and the requirements of applicable law. We collect personal information that you provide to us, personal information we obtain automatically when you use our Services, and personal information from other sources such as third-party services and organizations, as described below.

A. Information You Provide to Us Directly

We may collect the following personal information that you provide to us.

Your Communications with Us. We may collect personal information, such as email address, phone number or mailing address when you request information about our Services, apply for a job or otherwise communicate with us.

B. Information Collected Automatically

We may collect personal information automatically when you use our Services such as:

Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your browser or device information, location information (including approximate location derived from IP address). We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.

Cookies and Other Technologies. We, as well as third parties that provide content or other functionality on our Services, may use cookies, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.

Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.

Our use of Technologies is limited to that which is strictly necessary to allow you access to our Services and to make use of our functionality.

Analytics. We may use tools to process analytics information on our Services. No personal information is collected by these tools. These technologies allow us to process usage data to better understand how our Services are used, and to continually improve our Services. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs may not be effective on mobile applications.

C. Information Collected from Other Sources

Third-Party Sources. We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and services, as described below.

If your personal information is subject to the General Data Protection Regulation or UK General Data Protection Regulation, our processing of your personal information will be under one of the following lawful bases:

Performance of a Contract. We may process your personal information to carry out our contract with you or to take steps at your request prior to entering into a contract. For further details, see Section 4(A). Legitimate Interest. We may process your personal information to further our legitimate interests, but only where our interests are not overridden by your interests or fundamental rights and freedoms. For a detailed list of our legitimate interests, see Sections 4(B). Compliance with Legal Obligations. We may process your personal information to comply with our legal obligations as detailed in Section 4(B). Consent. In some cases, we may also rely on your consent to process your personal information for a specific purpose as detailed in Section 4(C).

A. Processing Necessary for Us to Provide Our Services

We process your personal information to perform our contract with you and provide you with our Services including by:

• Managing your information;
• Providing access to certain areas, functionalities, and features of our Services;
• Answering requests for customer or technical support; and
• Communicating with you about your activities on our Services, and policy changes.

B. Administrative Purposes

We use your personal information for our legitimate interests, such as:

• Conducting network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in our Services; improving, upgrading or enhancing our Services; developing new products and Services;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities;
• Debugging to identify and repair errors with our Services;
• Managing your information;
• Providing access to certain areas, functionalities, and features of our Services;
• Answering requests for customer or technical support; and
• Communicating with you about your activities on our Services, and policy changes.

B. Administrative Purposes

We use your personal information for our legitimate interests, such as:

• Conducting network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in our Services; improving, upgrading or enhancing our Services; developing new products and Services;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities;
• Debugging to identify and repair errors with our Services;
• Auditing relating to interactions, transfers and other compliance activities;
• Sharing information with third parties as needed to provide the Services;
• Enforcing our agreements and policies; and
• Other uses as required to comply with our legal obligations, applicable laws, regulations, regulators and authorities.

C. With Your Consent

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information and for which you provide your consent.

D. Other Purposes

We also use your information for other purposes as permitted by applicable law.

De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de­-identified demographic information, de-identified location information, information about the device from which you access our Services, information about how you use the Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use, disclose, and retain such information as permitted by applicable laws including, but not limited to, for research, analysis, analytics, and any other legally permissible purposes.

HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We may disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide our Services

The categories of third parties with whom we may share your information are described below.

Other Users of the Services and Parties You Transact With. Some of your personal information may be visible to other users of the Services (e.g., information featured on generally accessible parts of the contracts or on a user profile). In addition, to complete transfers via the Services, we will need to share some of your personal information with the party that you are transacting with.

Third Party Websites and Applications. You may choose to share personal information or interact with third-party websites and/or third-party applications, including, but not limited to, third-party electronic wallet extensions. Once your personal information has been shared with a third-party website or a third-party application, it will also be subject to such third party’s privacy policy. We encourage you to closely read each third-party website or third-party application privacy policy before sharing your personal information or otherwise interacting with them. Please note that we do not control, and we are not responsible for the third-party websites’ or the third­-party applications’ processing of your personal information.

Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, customer service, and related services.

Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.

Affiliates. We may share your personal information with members of our corporate family.

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, to the extent permitted by law.

YOUR PRIVACY CHOICES AND RIGHTS

The privacy choices you may have about your personal information are determined by applicable law and are described below.

Your Privacy Rights. In accordance with applicable law, you may have the right (subject to certain limitations) to:

• Confirm Whether We Are Processing Your Personal Information (the right to know);
• Access to and Portability of Your Personal Information, including: (i) obtaining access to or a copy of your personal information; or (ii) receiving an electronic copy of personal information that you have provided to us, or, in certain circumstances, asking us to send that information to another company (aka the right of data portability);
• Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
• Request Deletion of your personal information;
• Request to Opt-Out of Certain Processing Activities including, as applicable, if we were to process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we were to engage in “profiling” in furtherance of certain “decisions that produce legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws). For clarity, we do not currently “sell” or “share” your personal information;
• Request Restriction of or Object to our processing of your personal information, including where the processing of your personal information is based on our legitimate interest or for direct marketing purposes;
• Withdraw Your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal; and
• Appeal our Decision to decline to process your request.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

INTERNATIONAL DATA TRANSFERS

All personal information processed by us may be transferred, processed, and stored anywhere in the world, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your personal information consistent with the requirements of applicable laws.

If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, we will use a valid data transfer mechanism to ensure that your personal information is transferred in accordance with this Privacy Policy and applicable data protection laws.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Policy only for as long as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

SECURITY OF PERSONAL INFORMATION

We employ appropriate technical and organizational measures designed to protect the security of all personal information we collect. These measures are aimed at ensuring the ongoing integrity and confidentiality of personal information. We will continue to evaluate these measures to ensure the security of the processing.

CHILDREN’S INFORMATION

The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information without your consent, you may contact us as set forth in “Contact Us” below. If we learn that a child has provided us with personal information in violation of applicable law, we will promptly take steps to delete such information, unless we have a legal obligation to keep it.

THIRD-PARTY WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

COMPLAINTS

If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as set forth in “Contact Us” below.

If you are located in the European Economic Area or Switzerland you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

EEA Data Protection Authorities (DPAs)

Swiss Federal Data Protection and Information Commissioner (FDPIC)

CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at [email protected].