ABOUT SUGA’S USE OF PERSONAL DATA

1.           THIS PRIVACY NOTICE

1.1         Our Privacy & Cookies Notice

Suga takes its obligations to protect privacy and personal information very seriously. Please read this Privacy & Cookies Notice (“the Notice“) carefully as it sets out important information relating to how we handle your personal information.

1.2         Suga companies issuing the Notice

In this Notice, references to “we”, “us”, “our” or “Suga” are references to Suga and all its group companies. This Notice sets out how we, as data controller, will collect and use personal information, and the choices and rights available to you in connection with our use of your personal information.

On occasion, the Suga group who is the data controller in the European Economic Area (EEA) will be a joint controller with another Suga group company. Where the other Suga group company is based outside the EEA, then the data controller responsible for responding to requests to exercise data subject rights will be the relevant company in the EEA. In all cases, any complaints and requests to exercise data subject rights should be addressed to the Data Privacy Liaison Officer and the Data Privacy Liaison Officer will arrange for the responsible joint controller to handle the complaint or request.

1.3         To whose personal information does this Notice apply?

This Notice describes our practices when using:

• the personal information of the business contacts, employees of clients (including customers of our clients) of, and suppliers to, all our group companies (“business contacts”); and
• other persons who (1) may visit our websites (“website users”) or (2) who may visit our Suga pages on social media sites.

This Notice will apply whether you have provided the information directly to us or we have obtained it from a different source, such as a third party.

2.           BUSINESS CONTACTS

2.1         Sources of business contact information

We collect personal information from our business contacts directly or from the following sources:

• Third party referrals;
• Client checking and verification processes such as due diligence checks;
• Social media sites such as LinkedIn and other public internet sites;
• Credit reference agencies, insurance information bureaus and government or financial institutions; and
• Other public resources such as telephone directories, newspapers, internet sites, commercially available marketing lists, registries or public records.

2.2         What personal information we collect about business contacts

The categories of information we collect about business contacts includes:

• Personal details including name, home address, employer, office address, personal and work telephone numbers and home and work email addresses;
• Financial details including payments made and received and VAT/sales tax;
• Goods or services provided or purchased;
• Communications with our business contacts;
• Where business contacts have online accounts, log-in and similar credentials and information about use of these services;
• Image capturing, such as photos taken at events, videos, and CCTV footage;
• In certain circumstances criminal proceedings, outcomes and sentences, subject to applicable law.

2.3         How we use the personal information we collect about business contacts

We use this information for certain activities, including:

• Facilitating smooth running of the business through communication with corporate customers and suppliers, for example, to communicate about the goods and services we receive from suppliers;
• Maintaining and building upon customer and supplier relationships;
• Business planning;
• To fulfil a transaction initiated by a business contact;
• To fulfil a transaction initiated by a member of the Suga Group such as the purchase of supplies or equipment;
• To fulfil a transaction with, or for, Suga customers;
• Keeping accounts related to any business or other activity carried on by Suga;
• Deciding whether to accept any person as a customer or supplier;
• Keeping records of purchases, sales or other transactions for the purpose of ensuring that the required payments and/or deliveries are made or services provided;
• Completion of customer satisfaction surveys;
• Research and development;
• Business development;
• Event management including inviting our business contacts to events and exhibitions;
• Database management;
• Running competitions;
• Security and crime prevention;
• For fraud and theft prevention or investigation, or other risk management purposes;
• Compliance with contractual, legal and regulatory obligations;
• Enabling business contacts to access their online accounts; and
• For internal analysis and research to help us improve our services

2.4         Why we use the personal information of business contacts

We use this information because:

• It is necessary for performing our obligations, or exercising our rights, under our contracts with customers or suppliers;
• It is necessary for compliance with any legal or regulatory obligations that we are subject to;
• We have a legitimate business interest to:
• Manage our business and brand;
• Provide and improve our services;
• Operate our business;

A legitimate interest will only apply where we consider that it is not outweighed by a business contact’s interests or rights which require protection of their personal data.

If a business contact requires further information regarding our legitimate interests as applied to their personal information, they may contact the Global Data Privacy Officer.

In limited circumstances, such as in the case of marketing, a business contact’s consent as required under applicable law. Where we rely upon a business contact’s consent, they will have the right to withdraw their consent by contacting the Data Privacy Liaison Officer.

In certain circumstances, where a business contact does not provide personal information which is required, we will not be able to perform our obligations under the contract with them or may not be able to provide them with products and services. We will make it clear if and when this situation arises and what the consequences of not providing the information will be for the business contact.

2.5         Recipients of business contact information

We may disclose personal information of business contacts to third parties as follows:

• Suga group companies in order to process the data for the above mentioned purposes;
• Business associates and other professional advisers;
• Third parties including for the purpose of event management;
• Claimants, beneficiaries, assignees and payees
• Suppliers and/or providers of goods and services and other third parties who work on our behalf to service or maintain business contact databases and other IT systems, such as suppliers of the IT systems which we use to process personal information, or who provide other technical services, such as printing;
• Third parties providing services to us, such as our professional advisors (e.g. auditors and lawyers);
• Competent authorities such as tax authorities, courts, regulators and security or police authorities where required or requested by law or where we consider it necessary; and
• Subject to applicable law, in the event that Suga is merged, sold, or in the event of a transfer of some or all of our assets (including in bankruptcy), or in the event of another corporate change, in connection with such transaction.

2.6         Further Information

Please see sections 4 to 8 below for further information concerning our use of personal data.

3.            WEBSITE USERS AND WEB-RELATED PRIVACY ISSUES

3.1         What personal data do we collect about website users and visitors to Suga social media pages?

The categories of information we collect about users of our website and Suga webpages on social media sites such as Facebook, Instagram, LinkedIn and Twitter include:

• Information users provide when they enter information on our website, such as when they provide contact details, answer online questionnaires, feedback forms or applications for employment or submit CVs
• Information provided when users subscribe to email newsletters such as name, email address, job title;
• Information users provide when registering for an online account through our website;
• Information users provide when posting content on social media sites.
• We also collect personal information about the use of our website from users, including:
•  
• Information captured in our web logs such as device information (e.g. device brand and model, screen dimensions), unique identification numbers (e.g. IP address and device ID), and browser information (e.g URL, browser type, pages visited, date/time of access);
• Advertising information (such as size/type of ad, ad impressions, location/format of ad, data about interactions with ad);
• Behavioural information (such as information on the behaviour or presumed interests of individuals which are linked to those individuals and may be used to create a user profile); and
• Information captured by our cookies (see Cookies section below).

If a website user does submit their data via one of our forms and they have cookies installed on their browser, all behavioural and web log data will be associated back to them. The website user will be informed of this when completing our forms.

Suga also uses cookie technologies (e.g. VWO) which fully anonymise your personal information (such as IP address or keystrokes) therefore the information cannot be traced back to a website user.

3.2         How do we use the personal information of website users and visitors to Suga social media pages?

We use personal information of users of our website and Suga webpages on social media sites such as Facebook, Instagram, LinkedIn and Twitter for certain activities, including:

• Personalizing the experience of our website;
• Providing products and services that website users have requested;
• Administering the website, investigating any complaints and providing customer services;
• Providing website users and individuals accessing our web pages on social media sites with information and offers on products or services that may be of interest to them;
• Monitoring social media content to manage relations with our customers and promote our business and brand.

We use personal information about the use of our website for certain activities, including:

• Administering the website;
• Performing statistical and trend analysis to improve the user experience and performance of our website.

3.3         Why do we use the personal information of website users and visitors to Suga social media pages?

We use personal information of users of our website and Suga webpages on social media sites such as Facebook, Instagram, LinkedIn and Twitter because:

• It is necessary for compliance with any legal or regulatory obligations we are subject to;
• We have a legitimate business interest to:
• Promote our brand and business through our website and through social media tools;
• Monitor, investigate and report any attempts to breach the security of our websites;
• In the case of marketing, a user’s consent as required under applicable law. Where we rely upon a user’s consent, they will have an option to “Unsubscribe” and will also have the right to withdraw their consent by contacting the Data Privacy Liaison Officer
• We use personal information about the use of our website because:

• It is necessary for compliance with any legal or regulatory obligations that we are subject to;
• We have a legitimate business interest to:
• Monitor, investigate and report any attempts to breach the security of our websites;
• Improve the performance and user experience of our websites;

A legitimate interest will only apply where we consider that it is not outweighed by a website or social media user’s interests or rights which require protection of their personal data.

If a website user or individual accessing our web pages on social media sites requires further information regarding our legitimate interests as applied to their personal information, they may contact the Global Data Privacy Officer.

In certain circumstances, where a website user does not provide personal information which is required (for example, in relation to our online services), we will not be able to perform our obligations under the contract with them or may not be able to provide them with products and services. We will make it clear if and when this situation arises and what the consequences of not providing the information will be for the website user.

3.4         Who are recipients of personal information of website users and visitors to Suga social media pages?

We may disclose website and social media users’ personal information to third party recipients, as follows:

• to Suga group companies in order to process the data for the above mentioned purposes;
• to third parties who work on our behalf to service or maintain Software as a Service platforms for our websites such as suppliers of IT systems which we use to process personal information, or third parties who provide other technical services, such as printing;
• to third parties providing services to us, such as our professional advisors (e.g. auditors and lawyers);
• to competent authorities such as tax authorities, courts, regulators and security or police authorities where required or requested by law or where we consider it necessary;
• subject to applicable law, in the event that Suga is merged, sold, or in the event of a transfer of some or all of our assets (including in bankruptcy), or in the event of another corporate change, in connection with such transaction.

3.5         Further Information

Our websites and online services are for individuals who are at least 18 years of age. Our online services are not designed to be used by children under the age of 18.

Please see sections 4 to 8 below for further information concerning our use of personal data.

4.           INTERNATIONAL TRANSFERS

Suga is a global company and, as such, we may transfer personal information to other Suga group companies or suppliers outside your home jurisdiction. Suga will take all reasonable steps to ensure that personal information is protected and any such transfers comply with applicable law.

Suga may transfer and maintain the personal information of individuals covered by this Notice on servers or databases outside the European Economic Area (EEA) and outside the UK. Some of these countries may not have the equivalent level of protection under their data protection laws as in the EEA and as in the UK.

The countries to which we transfer data outside of the EEA and outside the UK include:  Brazil, Canada, China, Hong Kong, Japan, Malaysia, Singapore, South Korea, Taiwan, Vietnam and the USA. We also transfer data outside of the UK to the EEA.

5.           RETENTION PERIODS

We will retain your personal information for as long as required to perform the purposes for which the data was collected, depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information. We may also retain personal information for the period during which a claim may be made in relation to our dealings with you.

In general terms, this will mean that your personal data will be kept for the duration of our relationship with you and:

• the period required by tax and company laws and regulations; and
• as long as it is necessary for you to be able to bring a claim against us and for us to be able to defend ourselves against any legal claims. This will generally be the length of the relationship plus the length of any applicable statutory limitation period under local laws

In certain circumstances, data may need to be retained for a longer period of time, for example, where we are in ongoing correspondence or there is a continuing claim or investigation.

If you wish to obtain further information about the retention periods as applied to your personal information, you may find this in the retention schedule maintained by Suga or can contact the Global Data Privacy Officer.

6.           DATA SUBJECT RIGHTS

You have the following rights in connection with your personal information, if they are applicable to you under local law:

• Right to access personal information.
• Right to rectify personal information.
• Right to restrict the use of personal information.
• Right to request that personal information is erased.
• Right to object to processing of personal information.
• Right to data portability (in certain specific circumstances).
• Right to lodge a complaint with a supervisory authority.

7.            MISCELLANEOUS

7.1         Security

We have put in place technical and organisational security measures to prevent the loss or unauthorised access of your personal information. We train our employees in the proper handling of personal information. However, whilst we have used our best efforts to ensure the security of your data, please be aware that we cannot guarantee the security of information transmitted over the Internet. If you have reasons to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us as set out below.

7.2         Links

Our Website may contain links to other “non-Suga” websites. We do not control and assume no responsibility for the content, security, or the privacy policies and practices on those websites.

Suga encourages all users to read the privacy policies of those sites to determine how they protect and use personal information.

7.3         Changes to this Notice

From time to time, we may change and/or update this Notice. If this Notice changes in any way, we will post an updated version on this website. We recommend you regularly review this website to ensure that you are always aware of our information practices and any changes to such. Any changes to this Notice will go into effect on posting to this page.

8.           COOKIES AND SIMILAR TECHNOLOGIES

A cookie is a small text file which includes a unique identifier that is sent by a web server to the browser on your computer, mobile phone or any other internet enabled device when you visit an on-line site. Cookies and similar technologies are widely used to make websites work efficiently and to collect information about your online preferences. For simplicity, we refer to all these technologies as “cookies”.

Some of our website pages may contain electronic images known as web beacons (also known as clear gifs, tags or pixels) that allow us to count users who have visited our pages. Web beacons collect only limited information, e.g. a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any information that could directly identify you.

8.1         How do we use cookies?

We use cookies and other tracking technologies to customize content and advertising, provide social media features and to see how our visitors move through our website. We use this information to make decisions about ways to improve the services we offer you.

We may engage third party tracking and advertising providers such as those named below to act on our behalf to track and analyze your usage of our website through the use of cookies. These third parties collect, and share with us, usage information about visits to our website and, sometimes by correlating this information with other information (e.g. your IP address), measure and research the effectiveness of our advertisements, track page usage, help us target our recommendations and advertising, and track use of our recommendations and advertisements.

8.2         Cookies and types of cookies what we use

The table below describes the cookies and similar technologies that we use and their functionality.

Google Analytics

__utma

__utmb

__utmc

__utmz

These cookies enable the function of Google Analytics. This software allows us to measure and analyze visitor information such as browser usage, visitor numbers, and which pages are used. We use this information to help improve our Website (suga.com.hk)

Google Analytics

_ga

The analytics.js library uses a single cookie named _ga to store a unique client identifier (Client ID), which is a randomly generated number. This ID is used by Google Analytics servers to calculate visitor, session, and campaign data. We use this information to help improve our Website (suga.com.hk).

Act-on

Act-On uses cookies to collect information about the use of this site. The Act-On Cookie tracks movement through all the sections of Suga’s site that are beaconed for marketing information and persists until browser policy time or cache clear. The session cookie gathers the information about the IP address to attach a unique identifier for the user, it does not collect any other personal identification. Although Act-On plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Act-On. Act-On’s ability to use and share information collected by Act-On about your visits to this site is restricted by the Act-On Terms of Use and the Act-On Privacy Policy. You can prevent Act-On from recognizing you on return visits to this site by disabling cookies on your browser.

Sumo

__smShown

__smListBuilderShown

__smSmartBarShown

__smScrollBoxShown

__smWelcomeMatShown

__smSubscribed

__smUser

__smToken

__smDashView

The __smShown cookie is set when any of the List Builder, Welcome Mat, Scroll Box, or Smart Bars are shown on your website. If you have any of your Popups/Mats set to “Don’t Show to a visitor until X days have passed,” and Sumo detects this cookie in the visitors browser, it will not show that certain Popup/Mat.

This cookie is unique to the email apps and will display in your browser cookie list like this:

The __smSubscribed cookie is set when a visitor subscribes via any of the List Builder, Welcome Mat, Scroll Box, or Smart Bars they are shown on your website. If you have any of your Popups/Mats set to “Not Show To Users Who Already Subscribed”, and Sumo detects this cookie in the visitors browser, it will not show that certain Popup/Mat.

The __smUser cookie is set when you login to Sumo on your website and the cookie value is your User ID.

The __smToken is set once you login to Sumo and is checked to verify whether you are logged into Sumo or not.

The __smDashView cookie restores the same tab you were last in when you go back into the “Dashboard” app. For example, if you close the Dashboard app while in the “Subscriber Stats” tab, the next time you open the app, the cookie will allow the app to be opened in the exact tab you were last in.

VWO (anonymised)

_vis_opt_exp_EXPERIMENT_ID_

_vwo_uuid

_vis_opt_exp_EXPERIMENT_ID_goal_GOAL_ID

_vis_opt_test_cookie

_vis_opt_exp_EXPERIMENT_ID_combi

_vis_opt_exp_EXPERIMENT_ID_exclude

_vis_opt_exp_EXPERIMENT_ID_split

_vis_opt_s

_vis_opt_out

EXPERIMENT_ID refers to the ID of the test, and GOAL_ID refers to the ID of the goal. The _uuid cookie generates a unique ID for every visitor and is used for the report segmentation feature in VWO. It also allows you to view data in a more refined manner. If you have a test running on multiple domains, you will notice test-specific UUID values. In the _combi cookie, the Control always has the value of 1, Variation #1 always has the value of 2, Variation #2 has the value of 3, and so on.

The GOAL_ID cookie is generated when a goal is created.

The test_cookie is a temporary session cookie generated to detect if the cookies are enabled on the user browser or not.

The _combi cookie is generated when users reach a particular combination. This cookie ensures that users see the same variation that they saw on their previous visit to the page.

The _exclude cookie is generated when a user is excluded from a test.

The _split cookie is generated during a Split URL test.

The _opt_s cookie detects if the user is new or returning to a particular test.

The _opt_out cookie indicates that the visitor is not part of the test. This cookie is valid for 10 years.

Other targeting cookies

We may use other cookies to target and re-target visitors to our websites with digital advertising that is most relevant to the user. These cookies are also used to limit the number of times you see an advert or particular content, as well as help measure the effectiveness of an advertising or marketing campaign. Using existing cookies from many sites already on your computer, we partner with 3rd party companies to deliver advertising to specific computers. For more information about digital advertising visit AdChoices at: www.youradchoices.com.

Social media cookies

These cookies allow users to share our websites on social media such as Facebook and Twitter. These cookies are not within our control. Please refer to the respective privacy policies of the social media provider for how their cookies work.

Performance cookies

These cookies collect information on how users use our websites to help us improve areas such as navigation and fix technical issues or errors. For example, we use these cookies to help us understand how you arrive at our website, browse or use our website, and highlight areas where we can improve our website.

Functionality cookies

These cookies help us customize our website content based on a user’s preferences. They remember the user’s choices such as identifying the user as a particular investor type (Retail, Professional, or Institutional), their language, the country pages visited, and any changes the user makes to text size or other parts of our website pages. The information these cookies collect may be anonymized and they cannot track browsing activity on other websites.

Essential cookies

These cookies are essential for parts of our website to operate. They enable users to move around our website and allow us to recognize a user within our website so that we can provide them with service they asked for such as remembering the user’s sign-in details.

You can find more information about cookies, behavioral advertising and online privacy at www.allaboutcookies.org or www.youronlinechoices.eu.

8.3         How do I reject cookies?

If you do not want to be tracked by Google Analytics cookies, you can opt-out by installing a browser plug-in here: https://tools.google.com/dlpage/gaoptout/.

At any time, you can prevent cookies from being set on your browser. For instructions on how to block, delete, or disable any cookies, please consult your browser’s ‘Help’ or ‘Support’ section. Please note that by deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of our website.

Please consult the following links for information on cookie management and blocking according to your browser:

Explorer: https://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11

Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Chrome: https://support.google.com/chrome/answer/95647?hl=en

Safari: https://support.apple.com/kb/PH19214?locale=en_GB

You can also find more information and manage cookie storage at www.youronlinechoices.eu.

How to Contact Us

Questions, comments, and requests regarding this Privacy Policy are welcomed and should be addressed to our colleague  through the following email address: general_enquiry@suga.com.hk.