PRIVACY & DATA PROTECTION POLICY FOR CUSTOMERS AND WEBSITE VISITORS
SUPERHOG Limited (“SUPERHOG”) is a registered company in England & Wales (Company no. 10254155). Our registered address is Unit 2 Nine Mile Water, Stockbridge, Hampshire, SO20 8DR and our website address is www.superhog.com.
SUPERHOG is a wholly-owned subsidiary of GUARDHOG Technologies Ltd which is a registered company in England & Wales (Company no. 10784606). Our registered address is Unit 2 Nine Mile Water, Stockbridge, Hampshire, SO20 8DR.
THE PURPOSE OF THIS NOTICE
This notice provides you with information on how SUPERHOG will process your personal data, acting independently as a data controller in its own right.
Furthermore, SUPERHOG would like to inform you, as (i) a contact person at one of SUPERHOG’s (potential) customers or (ii) a visitor of the website www.superhog.com (the “Site”), about your rights regarding your personal data and how you can get in touch with SUPERHOG in order to enforce them.
WHAT IS PERSONAL DATA?
Personal data is information relating to an identified or identifiable natural person. Examples include an individual’s name, age, address, date of birth, their gender and contact details.
Personal data may also contain data relating to criminal convictions and offences, where we comply with the specific data processing requirements that relate to the responsible handling of this category of data.
1. Processing of your personal data as a contact person at one of SUPERHOG’s customers
SUPERHOG does not and will not sell, or pass on for any other type of gain, personal data to any third party.
If you are a contact person at one of SUPERHOG’s (potential) customers, SUPERHOG will process your personal data for the following purposes:
- to inform you about SUPERHOG’s products and services;
- to be able to communicate with SUPERHOG’s (potential) customers;
- to provide a self-service portal to SUPERHOG’s customers (customer portal);
- to be able to provide SUPERHOG’s customers with SUPERHOG’s products, support and services;
- for customer relationship management purposes;
- to conduct satisfaction and marketing surveys among (potential) customers;
- to comply with legal obligations; and
- to comply with the requirements of the Payment Card Industry Data Security Standard (PCI DSS).
For these purposes, SUPERHOG will process the following categories of data:
- Personal data such as an individual’s name, address, date of birth, gender, contact details and details of historic claims.
- Data relating to criminal convictions and offences such as details of driving offences or insurance fraud.
SUPERHOG collects this data either from you directly when you provide SUPERHOG with your personal data by e.g, sending SUPERHOG an email, providing SUPERHOG with your personal data on the phone or through SUPERHOG’s customer portal. SUPERHOG may also collect some of your personal data in the course of SUPERHOG’s business relationship with SUPERHOG’s customers.
If you object to the collection, sharing and use of your personal data we may be unable to provide you with our products and services.
For the purposes of meeting the Data Protection Act 2018 territorial scope requirements, the United Kingdom is identified as the named territory where the processing of personal data takes place.
For UK Hosts and Guests:
You authorise your mobile phone / wireless network operator to disclose your mobile number, name, address, email, network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status and device details, if available, to our third-party service provider, solely to verify your identity and prevent fraud for the duration of the business relationship.
For US Hosts and Guests:
You authorise your wireless operator (AT&T, Sprint, T-Mobile, US Cellular, Verizon, or any other branded wireless operator) to disclose your mobile number, name, address, email, network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status and device details, if available, to our third-party service provider, solely to verify your identity and prevent fraud for the duration of the business relationship.
For non-UK and non-US Hosts and Guests:
You authorise your wireless operator to disclose your mobile number, name, address, email, network status, customer type, customer file, billing type, mobile device identifiers (IMSI, MSISDN and IMEI) and other subscriber status and device details, if available, to our third-party service provider, solely to verify your identity and prevent fraud for the duration of the business relationship.
If you require more information about our processes or further details on how we collect personal data and with whom we share data with, please contact our data privacy officer by e-mailing email@example.com.
2. Processing of your personal data as a visitor of the Site
2.1 Personal and pseudonymized information
SUPERHOG collects both “personal information” and “pseudonymized information” about Site users. For purposes of this section, “pseudonymized information” is information that SUPERHOG cannot directly associate with a specific person without the aid of additional information. By contrast, “personal information,” is information such as a name or email address that SUPERHOG can directly associate with a specific person or entity without additional information.
Personal information. You can visit the Site without submitting any personal information. However, if you use certain features on the Site, you will be required to provide personal information. Such information could include, for example, your name, email address, telephone number, postal address, company, job title, and/or industry.
There is no obligation to provide the information that we ask you for on the Site. However, if you do not provide your personal information, you will not be able to make use of all functionality of the Site.
We may combine personal information collected through the Site with other information that we or third parties collect about you in other contexts—such as our communications with you via email or phone, or your customer service records. We will treat such combined information as personal information and protect it in accordance with this Policy.
2.2 Web technologies
Web log data. When you use the Site, we automatically receive and record the following information from your computer (or other device) and your browser: your IP address and domain name, the pages you visit on the Site, the date and time of your visit, the files that you download, the URLs from the websites you visit before and after navigating to the Site, your software and hardware attributes (including device IDs), your general geographic location (e.g., your city, state, or metropolitan region), and certain cookie information (see below). To obtain such information, we may use web logs or applications that recognize your computer and gather information about its online activity.
Web beacons. The Site or the emails that you receive from SUPERHOG may use an application known as a “web beacon” (also known as a “clear gif” or “web bug”). A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information, which could include personal information. For example, it allows an email sender to determine whether a user has opened a particular email.
Third-party online tracking and behavioural advertising. We also may partner with certain third parties to collect, analyse, and use some of the personal and pseudonymized information described in this section. For example, we may allow third parties to set cookies or use web beacons on the Site or in email communications from SUPERHOG. This information may be used for a variety of purposes, including online behavioural advertising, as discussed below (see the section entitled “How we share personal and pseudonymized information with third parties”).
What are cookies? Cookies are small files that are stored on your computer by your web browser. A cookie allows the Site to recognize whether you have visited before and may store user preferences and other information.
How are cookies used? For example, cookies can be used to collect information about your use of the Site during your current session and over time (including the pages you view and the files you download), your computer’s operating system and browser type, your Internet service provider, your domain name and IP address, your general geographic location, the website that you visited before the Site, and the link you used to leave the Site.
What kind of cookies are used on the Website? Our website primarily uses the following types of cookies:
|Cookie Name||Cookie Type||Purpose|
|__ga||Persistent cookie||This cookie is used to distinguish users and expires after 2 years.|
|__gat||Session cookie||This cookie is used to throttle the request rate and expires after 10 minutes.|
“Session cookies” are temporary bits of information that are deleted when you exit your web browser. Session cookies are typically used to improve navigation and to collect web statistics.
“Persistent cookies” are more permanent bits of information that are stored and remain on your computer until they are deleted by you. This type of cookie stores information on your computer for a number of purposes, such as saving your passwords. Persistent cookies delete themselves after a certain period of time but are renewed each time you visit the website.
How do you avoid cookies? If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the Site may not operate correctly.
2.4 How we use the personal and pseudonymised information that we collect on the Site
SUPERHOG uses the information that we collect on the Site for a variety of purposes. If we have personal information about you, we may use it to: respond to your questions or requests concerning the Site or other services offered by SUPERHOG or our partners; to fulfil the terms of any agreement you have with us; to fulfil your requests for our services or otherwise complete a transaction that you initiate; to send you information about our services and other topics that are likely to be of interest to you, including newsletters, updates, or other communications; to deliver confirmations, account information, notifications, and similar operational communications; to improve your user experience and the quality of our products and services; and to comply with legal and/or regulatory requirements.
We use the pseudonymized information that we collect for: counting and recognizing visitors to the Site; analysing how visitors use the Site and various Site features; improving the Site and enhancing users’ experiences with the Site; creating new products and services or improving our existing products and services; and enabling additional website analytics and research concerning the Site. SUPERHOG may link pseudonymized information gathered using cookies and web beacons with personal information.
2.5 How we share personal and pseudonymized information collected on the Site with third parties
We share your personal information and pseudonymized information with other parties for a variety of purposes, as described below.
The Site also enables third-party tracking mechanisms to collect your pseudonymized information for use in online behavioural advertising. For example, third parties may use the fact that you visited the Site to target online ads for SUPERHOG services to you on non-SUPERHOG websites. In addition, our third-party advertising networks might use information about your use of the Site to help target non-SUPERHOG advertisements based on your online behaviour in general. For information about behavioural advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.
The use of online tracking mechanisms by third parties is subject to those third parties own privacy policies and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance program by opting out here. Although our website currently does not respond to “do not track” browser headers, you can limit tracking through these third-party programs and by taking the other steps discussed above.
Third-party service providers and business partners. SUPERHOG also uses other third-party service providers to help us manage and improve the Site and other SUPERHOG services. These service providers may collect and/or use your personal or pseudonymized information to assist us in achieving the purposes discussed above in the section entitled “How we use the personal and pseudonymized information that we collect.” For example, we use third parties to help us target and implement our email communications and direct mailings. We also use third-party platforms to help us manage our relationships with the people and companies that use our services.
We also may share your personal or pseudonymized information with other third parties when necessary to fulfil requests for services; to complete a transaction that you initiate; or to meet the terms of any agreement that you have with us or our partners.
Your direct sharing of personal information through third-party websites and services. The Site may enable you to share directly personal information with websites or online services operated by third parties. For example, the Site contains links to third-party websites that incorporate comment and social media features. The Site also contains a Facebook “like” button and a Twitter “follow” button. If you choose to use these features, you may disclose your personal information not just to those third-party websites and services, but also to their users and the public more generally. Because these third-party websites and services are not operated by SUPERHOG, SUPERHOG is not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your personal and pseudonymized information will be subject to the privacy policies of the third-party websites or services, and not this Policy.
Legal purposes. We also may use or share your personal or pseudonymized information with third parties when we have reason to believe that doing so is necessary:
- to comply with applicable law or a court order, subpoena, or other legal process;
- to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third-party;
- to establish, protect, or exercise our legal rights or defend against legal claims; or
Aggregated information. From time to time, SUPERHOG may also share anonymized and aggregated information about Site users, such as by publishing a report on trends in the usage of the Site.
2.6 Children’s online privacy
The Site is not directed to children under the age of 13, and SUPERHOG will never knowingly collect personal or other information from anyone it knows is under the age of 13. We recommend that persons over 13 but under 18 years of age ask their parents for permission before using the Site or sending any information about themselves to anyone over the Internet.
3. Legal basis of the processing
SUPERHOG processes your personal data on the basis of Superhog’s prevailing legitimate interest according to Article 6(1)(f) General Data Protection Regulation (“GDPR”) to achieve the purposes set out above under Sections 1 and 2. SUPERHOG may ask you for your consent to process your personal data with SUPERHOG in a separate process. In case you provide your consent, SUPERHOG will be processing your data on the basis of this consent (Article 6(1)(a) GDPR). You may withdraw such consent previously granted at any time. However, withdrawing your consent does not affect the lawfulness of any processing based on your consent before your withdrawal.
If you opt in to receive marketing emails from us, we also may use the personal data that we collect to send you promotional communications, including emails or postal mail about the products and services offered by SUPERHOG or our partners. Although we hope you will find our promotional emails of interest, you may opt out of receiving them by sending an email to andrew@Superhog.com with “optout” in the subject line. Promotional emails will also have instructions for opting out of that type of communication in the future.
4. Transfer of your personal data
As far as this is necessary to achieve the purposes set out above and in addition to the transfers described in Section 2.5, SUPERHOG will transfer your personal data to the following recipients:
- IT service providers that SUPERHOG uses;
- companies that are part of SUPERHOG’s corporate group;
- public authorities;
- auditors for the performance of audits;
- contract partners or business partners who are participating in the performance of SUPERHOG’s service delivery.
By agreeing to this policy, you authorise any third-party service providers and their partners who assist SUPERHOG to verify your account information and process other personal data to do so under its legitimate interests such as for the purpose of identity verification and fraud prevention and detection for the duration of our relationship.
Some of the recipients referred to above or in Section 2.5 may be located in or process personal data outside of your country. The level of data protection in another country may not be equivalent to that in your country. However, SUPERHOG only transfers your personal data to countries where the EU Commission has decided that they have an adequate level of data protection or SUPERHOG takes measures to ensure that all recipients provide an adequate level of data protection. SUPERHOG does this for example by entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EC and/or 2004/915/EC). Such agreements are accessible upon request from privacy@Superhog.com.
5. Retention periods
We will retain your personal data at the end of any contractual agreement for a period of 7 years. Where you have contacted us for details of our services and products, we will retain your personal data for 7 years. Where you make a complaint, we will retain the data for 7 years. Where you or law enforcement agencies inform us about any active investigation or potential criminal prosecution, we will comply with legal requirements when retaining this data.
The retaining of data is necessary where required for contractual, legal or regulatory purposes or for our legitimate business interests for statistical analysis (profiling) and product development and marketing purposes.
Sometimes we may need to retain your data for longer, for example, if we are representing you or defending ourselves in a legal dispute or as required by law or where evidence exists that a future claim may occur.
If you have subscribed to our newsletter, we will store your email address as long as you are subscribed to the newsletter. Moreover, we will store information related to any request you send us and any following communication for as long as necessary to respond to and fulfil your request.
SUPERHOG uses commercially reasonable physical, electronic, and procedural safeguards to protect your personal and pseudonymized information against loss or unauthorised access, use, modification, or deletion. This includes when sharing your data within our firm, group of companies, business, including affiliates, subsidiaries and authorised third parties.
However, no security program is foolproof, and thus we cannot guarantee the absolute security of your personal or other information.
7. Your rights in connection with your personal data
Individuals are provided with legal rights governing the use of their personal data. These grant individuals the right to understand what personal data relating to them is held, for what purpose, how it is collected and used, with whom it is shared, where it is located, to object to its processing, to have the data corrected if inaccurate, to take copies of the data and to place restrictions on its processing. Individuals can also request the deletion of their personal data.
These rights are known as Individual Rights under the Data Protection Act 2018. The following list details these rights:
- The right to be informed about the personal data being processed;
- The right of access to your personal data;
- The right to object to the processing of your personal data;
- The right to restrict the processing of your personal data;
- The right to rectification of your personal data;
- The right to the erasure of your personal data;
- The right to data portability (to receive an electronic copy of your personal data);
- Rights relating to automated decision making including profiling.
Individuals can exercise their Individual Rights at any time. As mandated by law we will not charge a fee to process these requests, however, if your request is considered to be repetitive, wholly unfounded and/or excessive, we are entitled to charge a reasonable administration fee.
In exercising your Individual Rights, you should understand that in some situations we may be unable to fully meet your request, for example, if you make a request for us to delete all your personal data, we may be required to retain some data for taxation, prevention of crime and for regulatory and other statutory purposes.
You should understand that when exercising your rights, a substantial public or vital interest may take precedence over any request you make. In addition, where these interests apply, we are required by law to grant access to this data for law enforcement, legal and/or health-related matters.
If you require further information on your Individual Rights or you wish to exercise your Individual Rights, please contact our data protection officer by e-mailing firstname.lastname@example.org or by writing to SUPERHOG, Unit 2 Nine Mile Water Business Park, Stockbridge, Hampshire, SO20 8DR.
8. Changes to this Notice
Technology and the Internet are rapidly changing. SUPERHOG, therefore, needs to revise this Policy to reflect those changes. SUPERHOG will post all such changes on the Site, so you should review this page periodically. If we make a material change to the Policy, you will be provided with appropriate notice. If we maintain your email address, we also may email you a copy of the revised Policy at your most recently provided email address. It is therefore important that you update your email address if it changes.
9. YOUR ACCEPTANCE OF THESE TERMS
By using this Website and/or mobile app, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Website and/or mobile app. Your continued use of the Website and/or mobile app following the posting of changes to this policy will be deemed your acceptance of those changes.
If you wish you opt out of consent to have your data and personal information processed by us in accordance with this policy, then you can withdraw your consent at any time by contacting our Data Protection Officer (email@example.com) in order to do so.
10. SUPERHOG’s contact details
If you have any questions regarding this Notice, the use of your data and your Individual Rights please contact our data protection officer at SUPERHOG, Unit 2 Nine Mile Water Business Park, Stockbridge, Hampshire, SO20 8DR or by e-mailing firstname.lastname@example.org.