Sugarmate Privacy Policy

THIS SUGARMATE PRIVACY POLICY IS EFFECTIVE AS OF AUGUST 13, 2020

This Privacy Policy of Sugarmate, LLC ("Sugarmate", "we", or "us") applies to the Sugarmate website located at https://sugarmate.io/; Sugarmate software applications, and the services we provide through our website and apps (collectively, our "Products and Services").

We refer to each user of our Products and Services as "you" or as a "User". Capitalized terms not otherwise defined in this Privacy Policy shall have the meaning ascribed to such terms in the Sugarmate Terms of Use.

Type of Information We Collect

We collect information about you from different sources and in various ways when you use our Products and Services, including information you provide directly, information collected automatically, third-party data sources, and data we infer or generate from other data. The information we collect about you (which we refer to as your "Personal Data") includes Registration Information, Health Information, Behavior Information, Demographic Information, Feedback Information, Online Identifiers and Metadata, Geolocation Information, Use Information, Voice Data, and Derived Information:

Information you provide directly:

Information we collect automatically:

When you use our Products and Services, we collect some information automatically. For example:

Information we create or generate:

Information we obtain from third-party sources:

When you are asked to provide Personal Data, you may decline. And you may use app or device controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain products or features, those products or features may not be available or function correctly.

Use and Disclosure of Information

We will use the Personal Data we collect for purposes described in this Privacy Policy or otherwise disclosed to you and we may share Personal Data with our subsidiaries, affiliates, and/or parent companies. We may also use and disclose Personal Data for the following purposes:

Designated Recipients

With your consent, we share your Personal Data (including Health and Behavior, and Geolocation Information) with Designated Recipients. Additionally, your Designated Recipients may share your Personal Data with Sugarmate for purposes relating to their use of Sugarmate Products and Services, and we will use such Personal Data of yours in accordance with this Privacy Policy. If your Designated Recipients have your Personal Data, you hereby authorize them to provide such Personal Data to us as each determines.

Your Rights Concerning Your Personal Data

Access, correction, and deletion: If you wish to request access to, or correction or deletion of, Personal Data about you that we hold, or if you are a California resident and wish to request information about whether we have disclosed your personal information to any third parties for the third parties' direct marketing purposes, please email your request to privacy[at]sugarmate.io.

To the extent permitted by applicable law, we reserve the right to decline requests that we are not required to honor, unreasonable or excessive, where providing the data would be prohibited by law or could adversely affect the privacy or other rights of another person, or where we are unable to authenticate you as the person to whom the data relates.

Communications preferences: You can choose whether to receive promotional communications from us by email, SMS, physical mail, and telephone. If you receive promotional email or SMS messages from us and would like to stop, you can do so by following the directions in that message. These choices do not apply to mandatory service communications that are part of certain of our products, or to surveys or other informational communications that may have their own unsubscribe method.

Choices for Cookies and Other Technologies: See the Cookies section for choices about cookies and other analytics and advertising controls.

EUROPEAN DATA PROTECTION RIGHTS

If the processing of Personal Data about you is subject to European Union data protection law, you have certain rights with respect to that data:

To make such requests, contact us at privacy[at]sugarmate.io. When we are processing data on behalf of another party that is the "data controller", you should direct your request to that party. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.

We rely on different lawful bases for collecting and processing Personal Data about you, for example, with your consent and/or as necessary to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests such as performing internal system audits, diagnosing and correcting technical problems; understanding how site visitors use our website; optimizing our website’s design and users’ experience, and making sure we’re providing you with relevant content.

Cookies and Other Technologies

We use cookies, web beacons, mobile analytics and advertising IDs, and similar technologies to operate our websites and online services and to help collect data, including other identifiers and device information and usage data.

Cookies: Cookies are small text files stored directly on your device that can be recalled by a web server in the same domain that placed the cookie. The text in a cookie often consists of a string of numbers and letters that uniquely identifies your device, but it can contain other information as well.

Web beacons: Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website. When your browser opens a webpage that contains a web beacon, it automatically connects to the web server that hosts the image (typically hosted by a third party). This allows that web server to log information about your device and to set and read its own cookies. In the same way, third-party content on our websites (such as embedded videos, plug-ins, or ads) results in your browser connecting to the third-party web server that hosts that content. We also may include web beacons in our promotional email messages or newsletters to tell us if you open and act on them.

Mobile analytics and advertising IDs: Mobile analytics and advertising IDs are generated by operating systems for mobile devices (iOS and Android) and can be accessed and used by apps in much the same way that websites access and use cookies. Our apps contain software that enables our third-party analytics partners to access the mobile IDs.

We and our analytics partners use these technologies in our websites and Products and Services to collect Personal Data (such as browser type, mobile device identifier, the IP address of your device, the cookies stored on your browser, time spent on the Services, pages visited, language preferences, and other anonymous traffic data) when you visit our website or use our Products and Services. We and our partners also use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience while using the Services. We also use cookies and similar technologies to gather statistical information about use of the Products and Services in order to continually improve their design and functionality, to understand how they are used, and to assist us with resolving questions regarding them. Cookies and similar technologies further allow us to fulfill other legitimate purposes. We and/or our partners may also share the information we collect of infer with third parties for these purposes.

The third-party analytics providers we use on our websites include:

Company/Service Privacy Notices Manage Settings (opt-out)
Google Analytics https://www.google.com/policies/privacy/partners https://tools.google.com/dlpage/gaoptout
Google Tag Manager https://www.google.com/policies/privacy/partners https://policies.google.com/technologies/partner-sites
New Relic https://newrelic.com/termsandconditions/services-notices Email requests to PersonalDataRequests[at]NewRelic.com

To learn about their privacy practices and how to opt-out from some types of their uses of cookie data, click on the links above.

Many of these companies are also members of associations, which provide a simple way to opt out of analytics, which you can access at:

Cookie controls: If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. If, however, you do not accept these cookies, you may experience some inconvenience in your use of the Products and Services. For example, we may not be able to recognize your computer, and you may need to log in every time you visit.

Mobile advertising ID controls: iOS and Android operating systems provide options to limit tracking and/or reset advertising IDs.

Email web beacons: Most email clients have settings which allow you prevent the automatic downloading of images, which will disable web beacons in the email messages you read.

Do Not Track: Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our Products and Services do not currently have the ability to recognize or honor browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls described above.

Privacy of Children and Adults with Guardians

Children's Online Privacy Protection: Sugarmate does not permit any person under 18 to subscribe directly to Sugarmate Services or Software Apps or to directly purchase Sugarmate Products. A parent or legal guardian may subscribe for a User who is under 18, but no person under 18 is permitted to use Sugarmate Products or Services without the express consent of a parent or legal guardian to the collection and use of the data and to the Sugarmate Terms of Service which require, among other things, that the parent or legal guardian is responsible for designating Designated Recipients, connecting the User Device to Sugarmate Products and Services, interacting in all ways with Sugarmate Products and Services, and ensuring that all communications with us come from the parent or legal guardian and not from the person under 18.

Adults With Guardians, Conservators or Other Legal Supervision: Sugarmate does not permit any person to subscribe directly to Sugarmate Products and Services or to directly purchase Sugarmate Products and Services if that person lacks the legal competence. A legal guardian, conservator or other person with the legal right to do so may subscribe for a User who lacks the legal competence, but no such User is permitted to use Sugarmate Products and Services without the express agreement of a legal guardian, conservator or other person with the legal right to provide such agreement to the Sugarmate Terms of Service, which require, among other things, that such legal guardian or other person is responsible for designating Designated Recipients, connecting the User Device to Sugarmate Products and Services, interacting in all ways with Sugarmate Products and Services, and ensuring that all communications with us come from the such legal guardian or other person and not from the User who lacks legal competence.

Our Retention of Personal Data

We retain Personal Data for as long as necessary to provide the products and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations.

Terminating Your Account

You may terminate your Sugarmate account by following the instructions in the Sugarmate Software App.

When you terminate your account, we may retain your Personal Data, and we may continue to use your Personal Data as authorized in this Privacy Policy. You may contact us at the email or mailing address listed in the "Contact Us" section below to request that we delete your Personal Data, and we will seek to remove your information from our active systems expeditiously.

Cross-Border Transfer

Sugarmate Products and Services are controlled and operated by us from the United States. The Personal Data we collect may be stored and processed in your country or region, or in any other country where we or our service providers maintain facilities. Currently, we primarily use data centers in the United States. We take steps designed to ensure that the data we collect under this Privacy Policy is processed according to the provisions of this Privacy Policy and applicable law wherever the data is located.

Location of Processing European Personal Data: We transfer Personal Data from the European Economic Area and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do so, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections. To learn more about the European Commission's decisions on the adequacy of Personal Data protections, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.

How We Protect Your Information

We take reasonable and appropriate steps to help protect Personal Data from unauthorized access, use, disclosure, alteration, and destruction.

To help us protect Personal Data, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts.

If you feel that your interaction with us is no longer secure, please immediately notify us in accordance with the "Contact Us" section, below.

Phishing: We do not and will not, at any time, request Personal Data in a non-secure or unsolicited email or telephone communication. Identity theft and the practice currently known as "phishing" are of great concern to us. Safeguarding information to help protect you from identity theft is a priority for us. For more information about phishing, visit the Federal Trade Commission website

Changes

We may change this Privacy Policy by posting a new version of this Privacy Policy at https://sugarmate.io/privacy. When we update this Privacy Policy, we will update the legend at the top of this page to indicate the date that this Policy was last updated. Any changes will become effective when we post the updated Policy on our Website. Your use of our Products and Services following these changes means that you accept the updated Policy. If you do not agree with any change, you may terminate your account as provided above and may choose not to submit any further Personal Data.

Contact Us

If you have any questions about this Privacy Policy or wish to "opt-out" of Solicitations, please: (1) send us an email at privacy[at]sugarmate.io; or (2) write to us (and include your email address) at the following address:

Sugarmate, LLC
11075 Roselle Street
San Diego, CA 92121
Unites States of America

Because email communications are not always secure, please do not include credit card information or sensitive information in your emails to us.

Version

This Privacy Policy is dated August 13, 2020.

Terms of Service Privacy Policy