Here’s a summary of the most important things you might want to know:
- We only use the most basic tracking functionality of Google Analytics and cookies that are required to make our site, plugins and social media links function.
- We do not share or sell any information about you with any third parties.
- We use some of the best enterprise-grade security tools on the market across all our computer systems, servers and render nodes.
- All our computer systems and render nodes are protected by very strong passwords containing a mixture of characters, numbers and symbols.
- In the event that we need to replace a Hard drive – it will be securely erased and destroyed before being disposed of.
- Your data is only stored for as long as necessary to comply with law, complete a project or for legal matters.
- We use secure, cloud-based email and accounting packages that are protected by very strong passwords and 2-factor mobile authentication. No local copies of your emails are stored on our computer systems.
- No client data of any kind is stored on our desktops systems. This is instead stored on our secure server and backup hard drives. Backup hard drives are stored in a separate location to our computer systems and are not connected to the internet.
- Our server uses an advanced RAID system comprising of multiple hard drives. This means that no single hard drive ever contains a complete set of data and once dismounted from the RAID (due to failure or for upgrade purposes) the data contained on this hard drive will become unreadable.
Table of Contents
- Definitions used in this Policy
- Data protection principles we follow
- What rights do you have regarding your Personal Data
- What Personal Data we gather about you
- How we use your Personal Data
- Who else has access to your Personal Data
- How we secure your data
- Information about cookies
- Contact information
Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being Processed.
Child – a natural person under 16 years of age.
We/us (either capitalized or not) – Shoga Ltd
Data Protection Principles
We promise to follow the following data protection principles:
- Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
- Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
- Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
- Processing is limited with a time period. We will not store your personal data for longer than needed.
- We will do our best to ensure the accuracy of data.
- We will do our best to ensure the integrity and confidentiality of data.
Data subject’s rights
The Data Subject has the following rights:
- Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
- Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
- Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
- Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
- Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
- Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
- Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
- Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
- Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
- Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
- Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.
Data we gather
Information you have provided us with
This might be your e-mail address, name, billing address, home address etc – mainly information that is necessary for delivering the service you have commissioned us to provide or to enhance your customer experience with us.
Information automatically collected about you
This includes information that is automatically stored by cookies and other session tools. This information is used to improve your customer experience. When you use our services or look at the contents of our website, your activities may be logged.
Publicly available information
We might gather information about you that is publicly available.
How we use your Personal Data
We use your Personal Data in order to:
- provide our service to you. This includes for example registering your account; providing you with other products and services that you have requested; providing you with promotional items at your request and communicating with you in relation to those products and services; communicating and interacting with you; and notifying you of changes to any services.
- enhance your customer experience;
- fulfil an obligation under law or contract;
We use your Personal Data on legitimate grounds and/or with your Consent.
On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purposes:
- to identify you;
- to provide you a service or to send/offer you a product;
- to communicate either for sales or invoicing;
On the ground of legitimate interest, we Process your Personal Data for the following purposes:
- to send you personalized offers* (from us and/or our carefully selected partners);
- to conduct questionnaires concerning client satisfaction;
As long as you have not informed us otherwise, we consider offering you products/services that are similar or same to your purchasing history/browsing behaviour to be our legitimate interest.
With your consent we Process your Personal Data for the following purposes:
- to send you newsletters and campaign offers (from us and/or our carefully selected partners);
- for other purposes we have asked your consent for;
We Process your Personal Data in order to fulfil obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymised. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law, but not longer than 6 years.
We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:
- the link between purposes, context and nature of Personal Data is suitable for further Processing;
- the further Processing would not harm your interests and
- there would be appropriate safeguard for Processing.
We will inform you of any further Processing and purposes.
How we secure your data
We do our best to keep your Personal Data safe and employ safe protocols for communication and transferring data (such as HTTPS). We use anonymising and pseudonymising where suitable. We monitor our systems for possible vulnerabilities and attacks and have enterprize-grade security suites (including anti-virus and firewalls) in operation at all times across all our computer systems, servers and render nodes.
Bank details and specific contact information may be present on purchase orders and invoices received from you. This data will be used for the purposes of both submitting and receiving payments and filing tax / vat returns. This data will be stored in accordance with business regulations on our server and within our secure online accountancy package. This system is protected by industry-strength encryption, strong passwords and 2-factor mobile authentication. Where possible, this data will be also be archived (using encryption) and moved to an external HDD or memory stick after two years. This device will not be connected to the internet and will be stored in a secure location at all times. At this point this data will be removed from our server.
- We use a secure, cloud-based email service that is protected by industry-strength encryption technologies, very strong passwords and 2-factor mobile authentication.
- Copies of emails are not stored or archived on any of our computer systems.
- Emails are never forwarded to third parties under any circumstances. In the event that information or screenshots need to be forwarded to a third party to allow them to complete a task, this will be copied into a new email originating from a Shoga account.
- Emails are only stored for as long as necessary to complete a project, to comply with business law or for potential legal matters. Exceptions to this include emails that may contain important reference materials relating to ongoing projects.
Even though we try our best we can not guarantee the security of information. However, we will do everything reasonably possible to prevent security breaches and will notify you immediately should one occur and in any way affect you.
We do not intend to collect or knowingly collect information from children. We do not target children with our services.
Cookies and other technologies we use
A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.
- Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.
- Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible.
- Analytics cookies – these cookies are used to track the use and performance of our website and services. The majority of these cookies are created by third-party social media content providers, such as YouTube and Twitter.
You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.