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Privacy Policy

(Last Updated: 4.15.2020)

1. Our Commitment to Privacy
We, Sugatan LLC, being the owner and operator of the sugatan.io website, respect the privacy of your personal information. This website is referred to in this Privacy Policy as “our website” or “our site”. We provide this explanation about our online information practices as a show of our commitment to protect your privacy.
We do not sell or rent personally-identifying information collected during your use of our website.
In accordance with this Privacy Policy or otherwise upon notification to you at the time of data collection or transfer, we may share your personally-identifying information with a third party. You will always have the option of not permitting the transfer by not using the particular services for which the information is collected or shared.

2. The Information We Collect
At the time you register on our site or otherwise provide information to us through our site, we may collect and store your name, email address, mailing address, phone number, and other personally-identifying information. The user information we collect is categorized as follows:
– Application Information — information that you provide to us through our website and through other means. Examples include your email address, mailing address, including zip code, and phone number.
– Transaction and Experience Information — information about your transactions with us, as well as information about our communications with you. Examples include your account history, requests for information, and our responses.
We need this information to provide services that you request from our website and to let you know of additional services about which you might be interested. We also use this information to customize your experience using our website.
We may ask you for personally-identifying information at other times, such as if you enter into a promotion, post information, register for a forum, complete a survey, or otherwise communicate with us. If you opt-in to receive information regarding a promotion or other service offered by a third party, you give us your permission to share your name and email address with the third party offering the promotion or other service.
In addition, we automatically gather general statistical information about our website and visitors, such as IP addresses, browsers, pages viewed, number of visitors, services purchased, etc., but in doing so we do not reference you by individual name, email address, home address, or telephone number. We use this data in the aggregate to determine how much our users use parts of our site so we can improve our site. We may provide this statistical information to third parties, but when we do so we do not provide personally-identifying information without your permission.
As part of our service, we use cookies and beacons to store and sometimes track information about you. Please see our Cookie Policy.
In addition, our retail partners, advertisers, and other third parties appearing at our site or linked to our site may use their own cookies and beacons and may collect personally-identifying information, including credit card information, in connection with your use of their websites. The privacy policy of such third parties may differ from ours. We encourage you to read the third party’s privacy policy before responding to the offer to determine how the personally-identifying information is used by that third party.
If your browser or similar mechanism gives our site a “do not track” signal, our may not be able to honor your settings. We do not make any promises or guarantees about the effects of any “do not track” choice that you may make because: (a) such nuanced treatment is not necessarily available or effective for all browsers, mechanisms, or tracking technologies, and our commercially reasonable attempts to honor your settings might not be effective to preclude tracking or behavioral advertising at all or over any particular period of time; (b) third parties may not honor your settings or our policies and may use cookies or other tracking technologies for behavioral advertising despite our commercially reasonable attempts to prevent them from doing so; and (c) tracking technologies, browsers, and access devices may change from time to time and our commercially reasonable attempts might not be effective for each technology or across all platforms.

3. The Way We Use Information
We use your personally-identifying information to improve our marketing and promotional efforts, to statistically analyze site usage, to improve our content and product offerings, and to customize our site’s content, layout, and services.
We may use your information to deliver information to you that, in some cases, is targeted to your interests, such as articles, targeted banners, new services, advertisements, and promotions. You may opt out of receiving this information by so indicating in your registration/preferences file or otherwise notifying us in writing. We may ask you to provide us voluntarily with additional information regarding your personal or business interests, experience, or requests, which we may use to customize our services for you.
We may use your email address, your mailing address, and phone number to contact you regarding administrative notices and communications relevant to your use of our site.
If you place a request for services, we use your information to deliver your order. Payments for services ordered from us through our site are handled by a third-party provider. This provider, as well as other providers, may collect additional information, including billing information, credit card number, expiration date, and security code, and tracking information from checks or money orders. If you obtain services directly from one of our retail partners or service providers, we may exchange with the vendor personally-identifying information about you for purposes of your transaction.
We may also use or disclose information to: (a) resolve disputes; (b), investigate problems; (c) enforce our Website Terms and Conditions; (d) protect our operations or those of any of our affiliates; (e) protect our rights, privacy, safety, or property, and that of our affiliates, you, or others; and (f) allow us to pursue available remedies or limit the damages that we may sustain. At times, we may review the status or activity of multiple users to do so. We may disclose or access information whenever we believe in good faith that the law so requires or if we otherwise consider it necessary to do so to maintain service and improve our services. In addition, as our business changes, we may buy or sell various assets. In the event all or a portion of assets owned or controlled by us or our affiliated entity are sold, assigned, transferred or acquired by another company, the information from and about our website users may be among the transferred assets.
We use your IP address to help diagnose problems with our server, to manage our website, and to enhance our site based on the usage pattern data we receive.

4. Security
We employ reasonable and current security methods designed to prevent unauthorized access, maintain data accuracy, and ensure correct use of information.
To use some of our services, you may be required to set up a password-protected account or profile on our website. We recommend that you do not divulge your password to anyone. It is your responsibility to keep your password protected. No data transmission over the Internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we try to protect your personal information, we cannot ensure or guarantee the security of any information you transmit to us, and you do so at your own risk.

5. European Union GDPR Rights
In this Section 5, we have summarized certain rights that you may have under the European Union General Data Protection Regulation 2016/679 (“GDPR”) if you are a data subject covered by the GDPR. Some aspects of GDPR are complex and not all of the details have been provided below. Therefore, you should read the GDPR and relevant guidance from the applicable regulatory authorities for a full explanation of these rights.
Your principal rights under GDPR are: (a) the right to access; (b) the right to rectification; (c) the right to erasure; (d) the right to restrict processing; (e) the right to object to processing; (f) the right to data portability; (g) the right to complain to a supervisory authority; and (h) the right to withdraw consent.
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of GDPR; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise, or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it with your consent; for the establishment, exercise, or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise, or defense of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To the extent that the legal basis for our processing of your personal data is (a) consent; or (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used, and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
If you consider that our processing of your personal information infringes data protection laws, we hope that we can resolve any query or concern you raise with us about our use of your information. However, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by written notice to us via any of the contact information described in Section 7.

6. California Residents – Your California Privacy Rights
California Civil Code Section 1798.83 permits California residents to request from us certain information regarding the disclosure of certain categories of personal information to third parties for their direct marketing purposes within the immediately preceding calendar year. A company may also comply with the law by disclosing in its privacy notice that it provides consumers choice (opt-out or opt-in) regarding sharing personal information with third parties for those third parties’ direct marketing purposes (as we do), and information on how to exercise that choice.
If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please send your request to us via the email address or the mailing address set forth in Section 7. You must put the statement “Your California Privacy Rights” in the subject field of your email or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and zip code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
If you are a California resident under the age of 18, and a registered user of our website, California Business and Professions Code Section 22581 permits you to request and obtain removal of content that you have publicly posted. To make such a request, please send an email with a detailed description of the specific content to us via the email address set forth in Section 7. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information that you have posted and there may be circumstances in which the law does not require or allow removal even if requested.
To the extent the California Consumer Privacy Act of 2018 is applicable to our collection of information that identifies or relates to you or your household, you may have a number of important rights free of charge. In summary, those rights include: (a) the right to know the categories of personal information to be collected and the purposes for which the information will be used (see above); (b) the right to know the categories of personal information that were actually collected in the preceding 12 months and sold or disclosed for business purposes in the preceding 12 months (see above); (c) the right to require us to respond to verifiable requests with disclosures about our collection, sale, or disclosure of your personal information (such requests may be made by contacting us as described in Section 7 below); (d) the right to access a copy of the specific pieces of personal information that we have collected about you (see Section 7 below); (e) the right to request that we delete, and request any third-party service providers to delete, any personal information collected about you (see Section 7 below); and (f) the right to opt out of the sale of your personal information to third parties (Note, we do not sell or rent personally-identifying information to third parties).

7. How You Can Update, Correct, or Delete Your Information
You may access the information that we collect online and maintain through normal updating methods. To access, update, correct, or request deletion of this information, you may contact us by email at [email protected] Your account can be deleted or deactivated, but doing so will result in you not being able to access certain services. During the normal course of doing business, we will continue to share your information among our business units, our affiliates, and unaffiliated third parties as necessary in order to service your accounts and fill any orders you place with us.

8. Children Under 16
We do not intentionally collect information from individuals under the age of 16. Our website is not directed to individuals under the age of 16 and we request that these individuals not provide personal information through our website. If a minor child has provided us with personally-identifying information without parental or guardian consent, the parent or guardian should contact us to remove the information and opt out of promotional opportunities or other applicable services.

9. Changes to Our Policy
We reserve the right to change, add, modify, or remove portions of our Privacy Policy at any time. Any changes to our Privacy Policy will be communicated through our website and will become effective immediately as of the last updated date set forth above. Please continue to check our Privacy Policy from time to time to learn about any changes to our privacy practices. Information collected before changes are made will be secured according to the previous Privacy Policy.

10. Your Consent
By using our website, you consent to the collection and use of this information in the manner described in this Privacy Policy.