SUGARBEET

Privacy

Sugarbeet Privacy Policy

Welcome to the Sugarbeet Labs Privacy Policy. Whether you’re ready to put yourself out there and start dating or just looking for a new friend, at Sugarbeet, we believe every relationship and opportunity should start with respect and equality… especially when it comes to your personal information.

Sugarbeet was originally founded to challenge the outdated rules of dating.

And now, we’ve evolved into a tool that empowers users to connect with confidence.

When we talk about Sugarbeet Labs, we refer to Sugarbeet Holding Limited, Badoo Trading Limited and Sugarbeet Trading LLC (also known simply as “Sugarbeet”, “we”, “us”, or “our” in this policy). This Policy explains how we process your personal information. It applies any time you’re using the Sugarbeet mobile application or desktop version (“App”), and to your use of our “Sites”, which includes our websites like Sugarbeet.com, microsites, and other digital products and services, like our competitions or surveys. We also suggest you read our Terms and Conditions of Use.

Have any questions about this Policy?

Just Contact Us and we’ll be happy to help.

GOOD TO KNOW

We will need to change this Policy from time to time, but the most current version (at http://sugarbeet.com/privacy-policy) controls how we use your information. Be sure to regularly check for updates, but we will let you know by email or notice of any material or significant changes.

What do we collect?

You Make the First Move by using the Sugarbeet App or Sites, which is when we collect some information about you. While enjoying our App and Sites, you can also choose to share information with people you connect with, such as other members or your friends and contacts.

We are responsible for taking care of all the personal information we collect and you share with us. According to the General Data Protection Regulation (“GDPR”) of 27 April 2016 and other applicable personal data laws, we are the data “controller” for all personal information collected and processed through our App and Sites.

What you’ll find in this section

  • 1. Registration Information
  • 2. Linked Social Media Information
  • 3. Profile Verification and ID Verification Information (including biometric information)
  • 4. Purchase Information
  • 5. Geolocation Information
  • 6. Device Information
  • 7. Photo Information
  • 8. Link Information
  • 9. Messages
  • 10. Sugarbeet Success Stories, Surveys, and Other Contributions Information
  • 11. Customer Support Contact Information
  • 12. Cookies and Similar Technology Information

The type of information collected or shared depends on the specific situation and what exactly you are doing.

You will not be able to change your date of birth and, if you give Sugarbeet access to your location in your device settings, your location is automatically updated based on the location of your device. Others using the App might be able to see some of your Registration Information when they view your profile page, such as your sexual preference, name, and username.

1. Registration Information

When you download the App and create a Sugarbeet account, we collect certain information about you to help enhance the App and verify the people using it. This can include:

  • Name
  • Username
  • Gender identity
  • Location
  • Email address
  • Date, time and location of birth
  • Photographs
  • Mobile number
  • Sexual preference
  • Login information for social media accounts you connect to your Account, like Facebook or Instagram

After you register, you can change this information at any time through your account. You are responsible for making sure your account details are kept up to date, particularly if your phone number changes.

2. Linked Social Media Information

We want to help simplify and enhance your connecting. One way we do this is by making it possible for you to use your other social media accounts during your Sugarbeet experience. Just be aware that it means sharing with Us some of the personal data you shared with these social networks.

Using social media accounts to register or sign in to Sugarbeet

Facebook: If you choose to register or sign in using your Facebook account, you give Facebook permission to share your name and profile picture with us. And, unless you choose to opt-out of sharing these details, you also give Facebook permission to share your:

  • email address (if there is one associated with your Facebook account)
  • date of birth
  • other profile photos
  • gender
  • pages you like
  • current town or city

Apple ID: If you choose to register or sign in with your Apple ID, you give Apple permission to share with us:

  • your Apple login
  • a name (which you can edit)
  • an email that will be linked to your Sugarbeet account and used to retrieve it

You can choose to use your personal email, or Apple will create and use a random email address so your personal email can stay private.

We will then use the personal information we receive from Facebook or Apple to form your Sugarbeet account. If you remove the Sugarbeet app from your Facebook settings or Apple ID, we will no longer have updated access to this information.

Linking social media accounts to your Sugarbeet account

You can link your Sugarbeet account with your Instagram, Facebook, or Spotify accounts. This allows you to share some information from those accounts directly to Sugarbeet, like your Instagram photos or top Spotify artists.

You decide with Instagram/Facebook/Spotify what limited information we receive when you first link these accounts to your Sugarbeet account.

If you want to disconnect any linked social media accounts from Sugarbeet, just visit your settings in Instagram, Facebook, or Spotify and follow the instructions to remove the Sugarbeet App access permissions.

GOOD TO KNOW

If you unlink a social media account, this does not automatically delete the information that was already added to your Sugarbeet account. If you’d like this information removed, you must also delete it within your Sugarbeet account.

3. Profile Verification and ID Verification Information (including biometric information)

We want to ensure the safety and security of everyone on our App and Sites, and give people the best possible user experience. To do this, we require every person using our App and Sites to verify their accounts.

This means we might ask for your phone number and, in some cases, ask that you carry out a photo verification or ID verification. This allows us to make sure the people on Sugarbeet are actually people, that are of age, avoid fake accounts that can be used for malicious activities and cybercrime, and prevent fraud – all of which can threaten the Sugarbeet network and spoil things for everyone.

You can also choose to (i) verify your photo voluntarily, which will allow you to add a grey “verified” badge to your profile, and (ii) verify your identity with your ID document, which will allow you to add a blue “verified” badge to your profile. If you choose to verify your profile photo, we will scan each photo that you submit. This scan can include the use of facial recognition technology to compare the submitted photo(s) to your profile photo, which helps us make sure you are who you say you are. If you choose to also verify your ID, our third party partner called Veriff will carry out the ID check on our behalf. Veriff will compare a selfie you take to your ID document. This scan can include the use of facial recognition technology, but you also have the option to request a manual review if you do not want facial recognition technology to be used.

When you choose to verify your photo, we do not add verification photos to your profile, but we do keep the scans to verify you in the future and for our records. We will only keep the scans as long as we need them for these purposes, but never longer than 3 years after your last interaction with us. Once we no longer need the scans or the 3 years have passed, we will take reasonable business steps to permanently and securely delete the scans from our systems. When you choose to also verify your ID, your selfie and your ID are compared by our third party partner, Veriff. Veriff will retain your selfie and the picture of your ID for up to 72 hours. You can read more about Veriff’s privacy practices here. For members in South Korea, ID verification will be conducted manually. Before submitting your government-issued document, please ensure that all information is redacted other than your name, photo, date of birth, sex, and document expiry date. For members in countries where the collection of identification numbers is not permitted, Sugarbeet’s verification process automatically redacts any individual identification code from government-issued ID documents immediately upon receipt. The original image is permanently deleted after redaction, ensuring that the code is neither stored nor viewed by a human as part of a manual verification process.

GOOD TO KNOW

If your account is blocked for any reason, our anti-fraud and anti-spam procedures might also block your account(s) on our other platforms and applications, such as Badoo.

4. Purchase Information

If you decide to purchase any of our premium services, we will process your payment information and securely keep it for audit/tax purposes and to prevent fraud.

To prevent fraudulent payments from being processed, we use automated decisions and our systems check payment information and transactions for behaviour that might violate our Terms and Conditions of Use. We may automatically block any transaction that is likely to be fraudulent and meets the relevant criteria suggesting a violation. If a transaction is blocked, the relevant person will be notified that their transaction cannot be processed and can contact us to contest the decision.

GOOD TO KNOW

You can always turn off geolocation if you ever change your mind about giving Sugarbeet access to your location by:

  • iPhone – go to settings > security and privacy > location services > Sugarbeet
  • Android – go to settings > location > Sugarbeet > permissions > location

5. Geolocation Information

If you give Sugarbeet access to your location in your device settings, we will collect information about your location when you use your mobile device. We do this to personalise your App experience and make it easier for you to make connections and interact with others.

This can include information about WiFi access points and your longitude/latitude, and we can save your device’s coordinates to offer certain features to you.

For example, by enabling your general location information to appear to people seeing your profile and show you the profiles of people who are near you.

6. Device Information

When you use the App, we can collect information about your device for the purposes described in this Policy. This can include your device’s unique identifier, model, and operating system, as well as log and usage data. You can also choose to give our App access to your device’s address book, which will only be used when you want to add someone to your contacts.

7. Photo Information

We want to help you put your best foot forward, so we collect data about your profile photos that allows us to arrange them in a way that is favourable to you. This includes data such as which photos people spend the most time looking at or which have the best lighting, etc. You can opt-out of this feature through our app settings at any time.

8. Link Information

You might come across some links while using our App or Sites. If you use them, we can keep track of how you interact with links, including to third-party services that we are not responsible for, by monitoring redirecting clicks or other methods.

9. Messages

We review the content of messages sent in the App to identify topics, sentiments, and trends across our Users. We will take steps to remove personally identifying information from such messages, prior to reviewing them. We will not share the content of User messages or information we derive from them with any third party.

10. Sugarbeet Success Stories, Surveys, and Other Contributions Information

From time to time, we may contact you to see if you would like to take part in a research survey, provide feedback or a testimonial, or be part of a marketing campaign. For example, if you let us know you found a match on the App, we might ask if you want to be featured in Sugarbeet advertising. We will provide you with more information when we contact you with any such request.

You can always say no and your participation is completely optional, but if you don’t want to be contacted regarding these requests, just tell our Customer Support Team via our Feedback Page.

11. Customer Support Contact Information

If you contact our Customer Support team via our Feedback Page, we can track your IP address and will receive your email address and the information you share with us to help resolve your request.

We keep records of our communications with you for 6 years after your account is deleted, including any complaints from you about other people using the App or Sites.

12. Cookies and Similar Technology Information

When you use our App or visit our Sites, we can collect personal data from you automatically by using cookies or similar technologies.

Some cookies are necessary for the App and Sites to function and cannot be switched off, but you do have choices for others. Check out our Cookie Policy to learn more about cookies, how we use them, and your options for these technologies.

What’s a cookie?

A cookie is a small file placed on your device or internet browser that allows us to recognise and remember your preferences. Cookies generally help us better personalise and improve your experience on our App and Sites.

How do we use your information?

Our main goal: give you an enjoyable Sugarbeet experience as you connect.

What you’ll find in this section

  • 1. Using Your Information
  • 2. Our Matching Algorithms
  • 3. Moderation Practices
  • 4. Lawful Basis

GOOD TO KNOW

We will only use your information for email direct marketing if you consent when creating your account or in the App settings. If you ever change your mind, you can always withdraw from marketing in the App settings or by using the opt-out tools and links provided in our communications.

1. Using Your Information

To achieve our goal of giving you an enjoyable connection experience, we use your personal information to:

  • offer our services and features to you
  • contact you with information about the App, such as updates and new features
  • personalise the App, Sites, and content we deliver to you
  • carry out research and analysis about how you use and interact with the App and Sites
  • test new technologies and processes meant to enhance and improve the App and Sites
  • resolve disputes, troubleshoot problems, and enforce our Terms and Conditions of Use
  • investigate fraud and protect our legal rights
  • protect third parties and the people on our App and Sites from harm
  • if you’ve signed up for our communications or otherwise consented, send you information by direct marketing and other communication methods about our promotions and offers, such as letting you know the types of goods, services, and offers we provide.

This allows us to understand how close you are to others and show you profiles of people nearby.

2. Our Matching Algorithms

We want to ensure the safety and security of everyone on our App and Sites, and give people the best possible user experience. To do this, we require every person using our App and Sites to verify their accounts.

We want to help you find the best possible connections, so we developed matching algorithms to predict your compatibility with others and show you people we think are a good match for you.

To predict your compatibility with others and recommend profiles, our matching algorithms use:

  • the information you share about yourself in your profile
  • information about your activity on the App
  • whether you’ve verified your photo
  • your device coordinates

To be clear: If you post anything that is inconsistent with our Terms and Conditions of Use, we can restrict your account access or terminate it altogether.

3. Moderation Practices

Safety on our App and Sites is very important to us, so we take steps to make sure every person follows our Terms and Conditions of Use while connecting. We use a combination of automated systems and a team of moderators to monitor and review accounts and messages for content that suggests a violation of our Terms and Conditions of Use. This process involves some personal information, such as photos and any other information uploaded to a profile or shared in messages.

We will issue a warning to the relevant account if any account or message meets the relevant criteria suggesting a likely violation. We can also restrict or block the relevant user’s access, who can contact Sugarbeet to contest the decision.

GOOD TO KNOW

If the legal basis is consent, you can withdraw your consent at any time. If the legal basis is legitimate interests, you have a right to object to how we use that information. How? Just contact us or follow the instructions provided in the relevant sections of this Policy.

4. Lawful Basis

According to European Union (“EU”) and United Kingdom (“UK”) data protection laws, processing personal information must always have a specific lawful basis – meaning there must always be a legal reason, which is defined by the GDPR and other relevant laws. Here you will find the legal basis for all of the personal information we collect, use, and process.

What about the CCPA categories? You will see some of the CCPA’s specific categories of personal information mentioned under the section for Californian residents. You can find more information about these categories here.

Students

To understand which of our users might be in college or university in order to improve services for students. (This only applies to people who use the App and identified themselves when registering as being from the United States or Canada (except Quebec) and 18-24 years old.)

What exactly does this mean?

What we’re doing. We do this by using recent location data of where you opened the App to see if your device’s coordinates match a general university or college area. It’s then a simple “are they at campus? yes/no” result based on what we find.

Why we’re doing this. We combine these results with other relevant information we have so that we can:

  • send the right offers, events, and features to the right users
  • understand which Sugarbeet events are popular with students or not working so well
  • improve the App design to meet the needs of students

What we don’t do. We do not:

  • track your live, real-time movements as part of this activity
  • identify or store information about where you are studying

To be clear: to protect your privacy, we do not keep any of the location data used for this activity. It is permanently deleted once we have the “at campus? yes/no” result.

RootRallies

Offer the chance to join Rallies, which are groups of local events, challenges  and social groups based on specific location or topics, and automatically recommend events for you to join based on your location, activities, and “my life” and “my interests” information.

We get location information from the device you use to access the Sugarbeet social networking service. Our legitimate interests (for profile and activity information) in recommending relevant Hives to you. Contractual necessity (for location data).

WHAT INFORMATION CAN OTHERS SEE?

We think every person deserves meaningful connection, so we have built certain features to help you share what makes you unique with the world. Our App is specifically designed to make it easier for you to connect and interact, which involves making certain information about you available to others on the App.

What you’ll find in this section

  • 1. Important things to know when sharing information
  • 2. RootRallies Profile Sharing

Because of this and the nature of this type of connecting, we encourage every person on our App and Sites to think carefully about the information you share about yourself with others. Be careful about posting information that may eventually be made public when using the App. You should always assume that anything you post or submit may be publicly-viewable and accessible to people on or off the App.

The information you post about yourself, put on your profile, or share with others is at your own risk – we are not responsible for the information you choose to share with others.

IMPORTANT THINGS TO KNOW WHEN SHARING INFORMATION

We recommend not putting sensitive information that could be used for abuse or misuse on your profile for others to see, such as:

  • email addresses
  • URLs
  • instant messaging details
  • phone numbers
  • full names
  • addresses
  • credit card details
  • national identity numbers
  • driver’s licence details
  • any other sensitive information

Be careful when posting sensitive details about yourself on your profile or by adding certain Sugarbeet badges to your profile, such as your religious denomination, political leanings, sexual preferences, and health information. Although you can voluntarily choose to provide us with this information when you create your profile, sharing these sensitive details is not required. And remember the photographs you post on Sugarbeet can also reveal information about yourself.

When using the Sugarbeet App, you should assume that anything you post or submit on the App may be publicly-viewable and accessible, both by Users and non-users of the App. We want our Users to be mindful about posting information that may eventually be made public. This includes certain information added to your profile by third-party accounts like Facebook, Instagram, or Spotify.

For example, Sugarbeet’s safety feature ‘Share Date’ allows Users to share their match’s Sugarbeet name, photo, time and location of their date with their trusted contact. Also, a person using the App might recommend you as a match to their Facebook friend by sharing a screenshot of your profile picture, whether or not that friend also uses the App.

Some countries (currently only South Korea) might require that people have the option to download a copy of their conversation history. In this case, we have no control over how this information might then be used or shared after we are required to provide it.

Remember to log out of any app or third-party account you use to log in to or access our App when you are done to keep others from accessing your Sugarbeet account.

TAKE CONTROL OF YOUR DATA

When you choose to share sensitive information about yourself with us, including by adding badges to your profile, to discover others and be discovered, you are explicitly consenting to us processing this information and making it public to other people on the App.

ROOTRALLIES

If you use RootRallies, you should assume that whatever information you share in RootRallies can be seen by any RootRallies member. This includes information like which Hives you’ve joined and those conversations. RootRallies members can only see Hive discussions after they join the specific chat, which then gives them access to the full chat history.

You can choose to provide information like your beliefs, sexuality, and political leanings, but it’s not required. Just know that when you choose to share sensitive information like this about yourself with us for RootRallies, you are explicitly consenting to sharing that information with other RootRallies members.

RootRallies Profile Sharing

If you use RootRallies and are in a region where our separate RootRallies app is available, your RootRallies profile will automatically be visible both in RootRallies mode on the main Sugarbeet App and on the separate RootRallies app. We do this to provide you with a richer pool of potential friends to connect with. If you do not want your RootRallies profile to be shown on the RootRallies app, just check out this help page.

Do we share your information?

In order to help you make connections and provide an enjoyable Sugarbeet experience, it might sometimes be necessary to share some personal information with others. But rest assured: we will only ever share your personal information in the limited circumstances described in this Policy.

What you’ll find in this section

  • 1. Our commitments to you

GOOD TO KNOW

With this in mind and under these restrictions, you should be aware that some of these trusted third parties might also use the personal information they collect for their own purposes. For example, by aggregating your personal information with other data they hold to inform advertising-related services provided to their other clients.

OUR COMMITMENTS TO YOU

We investigate and verify (also known as carrying out due diligence) all of the trusted third parties we work with, or “Service Providers”, to make sure they have adequate data protection and information security measures in place.

We take steps to make sure the personal information we share is as unidentifiable as possible.

We hold our Service Providers to extensive contractual requirements, including strict limits on keeping personal information.

What is aggregating? Aggregating personal information and data means combining information from multiple people and sources in a way that does not personally identify you or anyone directly.

When we share information, with who, and why

Service Providers

To offer some of our functions and services that are made possible by working with our trusted Service Providers. The specific Service Provider we share personal information with depends on various factors, such as which of our App, Sites, and other services a person is using.

We will only share your personal information with Service Providers when necessary to perform these functions and provide such services.

Each Service Provider will only have access to the personal information necessary for the specific service they are providing.

For example, in order to provide our services, we typically use Service Providers like:

  • Billing services to allow customers to purchase paid features of our App (for example, Google Play)
  • Authentication services to allow customers to authenticate their account (for example, Twilio)
  • Social media providers to allow customers to create and connect their Sugarbeet account with their social media accounts (for example, Facebook, Instagram, or Spotify)
  • Customer support services to help us respond to your enquiries (for example, Zendesk, Sierra)
  • Product improvement and market research by working with third-party platforms and agencies to carry out customer surveys and research to improve our products and services (for example, Typeform or Kantar)
  • IT services by working with third-party software providers used in operating our business for technical support (for example, if a person using our App or Sites contacts us via social media with a support inquiry, their inquiry is processed by Khoros, our community management software provider)

Moderators

To monitor activity on the App and approve content.

  • Name
  • User registration details
  • Profile information
  • Message content
  • Photographs

Payment Processing and Telecommunications Companies

To facilitate payments for our premium services.

  • Cardholder name
  • Cardholder address
  • Card number
  • Payment amount
  • Transaction date/time

Marketing Service Providers

To partner with Service Providers focused on marketing services to market and advertise our App and services on third-party websites and applications, and measure the effectiveness of our advertising campaigns.

For example, this can involve:

  • excluding people who already have a Sugarbeet account from advertising campaigns aimed at finding new users
  • showing Sugarbeet ads to people who have visited our App or Sites but haven’t created an account yet
  • creating an advertisement audience of other potential users with similar characteristics to you based on a Marketing Service Provider’s information (also known as a “lookalike audience”)
  • sending you specific Sugarbeet advertising content by including you on a list of people we think are most likely to be interested in a particular advertisement (also known as a “custom audience”)

Facebook

To partner with Facebook as a Marketing Service Provider to measure the effectiveness of our advertising, improve our marketing practices, and deliver more relevant advertising to you and people like you, including on social media.

When we share personal information with Facebook in this specific context, such as through the Facebook “Like” function, we are considered “Joint Data Controllers” with Facebook Ireland for this data processing.

What does this mean? We tell you about this processing of your personal information here in this Policy, but you should contact Facebook if you want to exercise your data protection rights for this processing. To learn more about how Facebook processes your personal information as an independent data controller and allows you to exercise your rights, check out Facebook Ireland’s Data Policy. If you want more information about our relationship with Facebook, just email [email protected].

Legal Enforcement and Preventing Harm

To ensure everyone using the App behaves appropriately and follows our Terms and Conditions of Use. To work with third parties to enforce their intellectual property or other rights. To cooperate with legal requests for information from law enforcement when we are required by law, which can include an investigation into alleged criminal behaviour or to protect a person’s vital interests.

What does this mean? We can save or share any of your personal information discussed in this Policy if we believe in good faith that it is necessary to:

  • follow a law or regulation, binding court order or direction, or lawful request
  • protect the safety of any person
  • address fraud, security, or technical issues, such as by working with anti-spam providers to protect the App and Sites from criminal activity
  • protect a third party’s rights or property, or our own

In any of these cases, it is our decision alone whether or not to act on any right available to us, such as rejecting a request for information when possible.

Our Business Transfers

To help bring a smooth changeover in the event one of our companies, a Sugarbeet Labs entity, or any of our affiliates goes through a business transition or change of ownership. For example, this can include:

  • merger
  • acquisition by another company
  • re-organisation
  • sale of all or a part of its assets
  • insolvency or administration

Anti-Spam and Anti-Fraud Procedures

To apply our anti-spam and anti-fraud procedures by sharing your personal information with our other companies (Sugarbeet Labs companies). For example, to block accounts and suspected fraudulent payment transactions.

  • Email address
  • Phone number
  • IP address
  • IP session information
  • Social network ID
  • Username
  • User agent string
  • Transaction and payment data

Aggregated Information

To carry out analysis of our industry and demographic profiling by sharing aggregated information with third parties for this purpose. For example, we can share aggregate click statistics, such as how many times a particular link was clicked.

What Are Your Rights?

With all of this in mind, let’s talk about how you can take control of your privacy.

What you’ll find in this section

  • 1. Right to be informed
  • 2. Right to access
  • 3. Right to rectify
  • 4. Right to data portability
  • 5. Right to erase
  • 6. Right to restrict or object
  • 7. Right to complain
  • 8. Rights related to automated decision-making, including profiling
  • 9. How Do You Enforce Your Rights
  • 10. Do You Live in California?

You generally have the following rights regarding your personal information, depending on the specific circumstances:

Right to be informed

Your right to know what personal information we process and why.

Right to access

Your right to request a copy of the personal information we have about you.

Right to rectify

Your right to correct the personal information we have about you if it’s inaccurate.

Right to data portability

Your right to retrieve your personal information from us to easily transfer it to another location.

Right to erase

Your right to have your personal information deleted, except if we have compelling reasons to keep it (like following the law).

Right to restrict or object

Your right to limit or stop how we use your personal information. If processing is restricted, we can still store the information but can’t use it further.

Right to complain

Your right to complain to us or your country’s data privacy authority if you don’t agree with how we handle your data or address your concerns. If you have a concern about how we handle your personal information or a request, we encourage you to first contact us.

Rights related to automated decision-making, including profiling

Your right not to be affected by automatic decisions made without any human involvement, especially if those decisions have significant or legal effects on you. For example, this includes situations like automatic denial of an online credit application or hiring decisions made entirely by computers.

If you live in the UK, you can make a complaint to the Information Commissioner’s Office (ICO).

If you live in the EU or European Economic Area (“EEA”), you can get in touch with your local Data Protection Regulator.

If you live outside the UK, EU, or EEA, reach out to your local privacy data protection regulator.

If you want to learn more or exercise your rights, just visit our Feedback Page, email our Data Protection Officer at [email protected], or contact us. To protect you and everyone on the App and Sites, we might need to ask you for specific information to help us confirm your identity before we answer your request.

GOOD TO KNOW

Your particular rights depend on your country and this list does not apply everywhere or include every single possible right that might exist around the world. You should always be aware of the rights you have under the privacy laws that apply in your country.

US State Privacy Rights

DO YOU LIVE IN CALIFORNIA?

If yes, there’s a bit more information you need to know. In addition to the rights we just described, people living in California have the following rights under the California Consumer Privacy Act (“CCPA”):

Right to exercise your rights

Your right to exercise your rights under the CCPA without being unlawfully discriminated against for doing so.

Right to know

Your right to ask us to share what personal information we have about you and details about how we collected, used, and shared it over the past 12 months.

Right to delete

Your right to have us delete your personal information, unless an exception applies (like following the law below).

Shine the Light Law

Under California’s “Shine the Light” law (Civil Code section 1798.83), California customers can ask certain businesses to share details about their practices related to disclosing or sharing personal information. If you want to find out how this might apply to you and what rights you might have, just email us at [email protected].

Joint promotions

From time to time, as part of a joint promotion with a third party, we may, if you participate in such promotion, disclose your contact information to the third party to allow them to market their products or services to you. Where this is a condition for participation in a promotion, we will always let you know before when you enter the promotion. Please follow the instructions provided to you by third parties to unsubscribe from their messages.

Do not track signals

Some internet browsers allow you to set up a “do not track” signal or similar tools, which can tell websites and online services that you don’t want to be tracked for advertising or analytics purposes. These signals allow people online to make general choices about the collection of their personal information over time and across third-party online services.

At this time, we do not track the personal information of those using our App or Sites over time or across third-party online services. We also do not knowingly allow third parties to collect personal information about someone’s activities over time and across different online services when using our App.

US State Privacy Rights

Some US states have their own privacy laws, regulations, and rights. If you see your state listed here, we have some extra information to share with you. Please read this information along with our Privacy Policy.

What you’ll find in this section

  • 1. California
  • 2. Colorado
  • 3. Connecticut
  • 4. New Jersey
  • 5. Oregon
  • 6. Texas
  • 7. Utah
  • 8. Virginia

And don’t forget:

  • Profile Verification Information: if you verify your profile, we only keep any biometric scans we receive so that we can verify you in the future and for our record-keeping purposes until we no longer need them for such purposes or for three years after your last interaction with us, whichever occurs first.
  • Customer Support Contact Information: we keep records of our communications with you for 6 years after your account is deleted.

GOOD TO KNOW

Even after you remove information from your profile or delete your account, copies of that information may still be viewable or accessible if it was previously shared, copied, or stored with or by others. We cannot control this and we are not legally responsible or liable for this.

If you give third-party apps or websites access to your personal information, their own terms of service or privacy policies control how they handle your personal information.

What happens when you delete your account?

If you delete your account, we make sure it is no longer viewable on the App. Just in case you delete by accident or change your mind, it’s possible to restore your account for up to 28 days after deleting. We will also begin the process of deleting your personal information if you are no longer actively using your account, i.e. after 4 years of no activity on your account.

For Example

  • If you make purchases within the App, we might need to keep some personal information for tax and accounting purposes
  • If an account is blocked, we might need to keep some account information and a record of the behaviour that resulted in blocking the account as evidence for possible queries or legal claims
  • If there is a payment dispute for a paid feature, we might need to keep personal information to resolve it
  • If a user was banned for unsafe behaviour or security incidents, we might need to keep information to prevent them from opening a new account

After these 28 days, we start the process of deleting your personal information, unless:

  • we must keep it to follow applicable law
  • we must keep it to prove we followed applicable law
  • there is an outstanding issue, claim, or dispute that requires us to keep the relevant information until it is resolved
  • the information must be kept for our legitimate business interests, such as fraud prevention and enhancing safety and security for people using our App and Sites

Connecting you around the world

Our App and Sites are global – we want you to be able to access Sugarbeet and make connections wherever you happen to be in the world. To make this possible, we operate a global network of servers to provide the App and Sites, and store your personal information. Our network includes servers in the US, UK, and the EU. Here are some points to keep in mind:

  • We own the hardware for the servers, even if they’re physically located in a third-party data centre.
  • Your personal information will be sent to and used in the US and UK, no matter what country you live in.
  • The personal information collected by our trusted Service Providers and advertising partners might also be held outside the UK and EEA.

In any case, we make sure your personal information is adequately protected – especially when transferred overseas. We make sure that valid, legal mechanisms are in place, such as the EU approved model clauses, and enforce strong contractual standards. If you want more information about the protections we have in place, just email [email protected].

Security

Unfortunately, using a website or the Internet is never 100% secure and even we can’t guarantee that unauthorised access, hacking, data loss, or other breaches will never happen. We can’t guarantee the security of your personal information while it is being transmitting to us, so any transmission is at your own risk.

This being said, here are some tips to help keep your data secure:

  • Always log out of your account when you’re done.
  • Never share your password with anyone else.
  • Regularly change your password.
  • If you ever think someone has access to your password or account, now or in the past, just follow these steps.

Age Restriction Policy

Although we want as many people as possible to enjoy our creation, you must be at least 18 years old to use Sugarbeet.

We do not knowingly collect any information or market to children, minors, or anyone under 18 years old. If we become aware that someone under 18 has registered a Sugarbeet account and shared personal information with us, we will take steps to terminate that person’s registration.

GOOD TO KNOW

Wherever you live, we care about your privacy. You can make a request for your data either through our app or by contacting our support team.

Your US State Privacy Rights

Some US states have their own privacy laws, regulations, and rights. If you see your state listed here, we have some extra information to share with you. We encourage you to review this information carefully, along with this Privacy Policy so you can understand your options and make the choices that are best for you.

1. California

California Notice at Collection

This Notice explains how we collect, store, protect, and share your information, and with whom we share it. Please note that not all of the items listed below may be relevant to you. For example, we would not have your financial information, unless you made a purchase from us.

1. Categories of Personal Information

When accessing or using Sugarbeet on the website or App, we may collect the following categories of “personal information,” and “sensitive personal information” as defined by the California Consumer Privacy Act (CCPA) (as amended):

  • Identifiers, such as name and location;
  • Personal information, as defined in the California customer records law, such as contact (including email and telephone number) and financial information;
  • Characteristics of protected classifications under California or federal law (if you choose to provide them), such as age, gender identity, marital status, sexual orientation, race, ancestry, national origin, religion, and medical conditions;
  • Commercial information, such as transaction information and purchase history;
  • Biometric information;
  • Internet or network activity information, such as browsing history and interactions with our Sites and App;
  • Geolocation data, such as mobile device location;
  • Audio, electronic, visual and similar information, such as photos and videos;
  • Professional or employment-related information, such as work history and prior employer;
  • Non-public education information; and
  • Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics. The categories of sensitive personal information are account log-in and password, financial data, or other credentials allowing access to your account, biometric information, and any other sensitive personal information you may provide in your account or post about yourself.

2. Purposes for Collection

  • To provide you with the Sugarbeet social networking service
  • To facilitate networking opportunities on the Sugarbeet App
  • To verify your identity and prevent fraud and to ensure the safety and security of Users
  • To take payment for premium services (not applicable for Users making payments via the Apple App Store)
  • To send you marketing information about our events, offers and services
  • To carry out research and analysis to help us improve the App and to test new technologies and processes designed to enhance and improve the App/Sites
  • To respond to correspondence and queries that you submit to us, including social media queries
  • To investigate and block Users for reported infringements of our Terms and Conditions of Use
  • To improve your experience on the App
  • To enable Users to create and enhance their Sugarbeet profile and log into the App via third party accounts
  • To block payment transactions as part of our anti-fraud procedures
  • To serve promo cards and advertisements on the App
  • To serve advertisements on third party networks and measure the effectiveness of such ads
  • To contact you in order to run surveys for research purposes and to obtain feedback, and to find out if you want to take part in marketing campaigns
  • To enable video and audio call functions, and the sending of images and video
  • To defend legal claims, protect legal rights and to protect people from harm

3. Selling or Sharing Personal Information

The CCPA requires businesses that “sell” personal information, as the term “sell” is defined under the CCPA, to provide an opt-out from such sales. Some people have taken the position that when a website uses third parties’ cookies or similar technology for its own analytics or advertising purposes, the website is engaged in a “sale” under the CCPA if the third parties have some ability to use, disclose or retain the data to improve their service or to take steps beyond the most narrowly drawn bounds of merely providing their service to the website/app. Some take this position even when the website pays the third party (not vice versa), and in most cases merely provides the third party with an opportunity to collect data directly, instead of providing personal information to the third party. As part of these analytics and advertising services, these technologies may access identifiers (like IP addresses), internet or other electronic network activity information (like information regarding an individual’s browsing interactions on our Services), and commercial information (like the fact that a browser visited a page directed to people who are considering the use of our Services) to those sorts of companies. While we do not believe these are “sales” as that term is defined under the CCPA, you can opt out of this activity. You can opt out of these activities by visiting this link: Do Not Sell or Share My Personal Information. The CCPA also requires businesses that “share” personal information to provide an opt out from such sharing. Under the CCPA, “sharing” is defined as the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites. We “share” information for these purposes to provide more relevant and tailored advertising to you regarding our Services. As part of this advertising, we may “share” identifiers (like IP addresses and email addresses), internet or other electronic network activity information (like information regarding an individual’s browsing interactions on our Site), and commercial information (like the fact that a browser visited a page directed to people who are considering a subscription to the Services) with advertising platforms and advertising networks. You can opt out of any activities that may be considered selling or sharing by clicking “Do Not Sell or Share My Personal Information” on the bottom of the website homepage or in the Privacy Settings on the app.

4. Data Retention

We keep your personal information only as long as we need it for the legal basis relied upon and as permitted by applicable law.

California Privacy Rights

If you’re a California resident, the California Consumer Privacy Act (CCPA) requires us to disclose information regarding the categories of personal information and sensitive personal information that we have collected about California consumers, the categories of sources from which the information was collected, the business or commercial purposes (as those terms are defined by applicable law) for which the information was collected, and the categories of parties to whom we disclose personal information.

Throughout this Policy, we describe the specific pieces of personal information and sensitive personal information we collect, the sources of that information, and how we disclose it. Under the CCPA, we also have to provide you with the “categories” of personal information and sensitive personal information we collect and disclose for “business or commercial purposes” (as those terms are defined by applicable law). For Users who are California residents, the data we may collect falls within the following categories of “personal information”, as defined by the California Consumer Privacy Act (CCPA):

  • Identifiers, such as name and location;
  • Personal information, as defined in the California customer records law, such as contact (including email and telephone number) and financial information;
  • Characteristics of protected classifications under California or federal law (if you choose to provide them), such as age, gender identity, marital status, sexual orientation, race, ancestry, national origin, religion, and medical conditions;
  • Commercial information, such as transaction information and purchase history;
  • Biometric information;
  • Internet or network activity information, such as browsing history and interactions with our Sites and App;
  • Geolocation data, such as mobile device location;
  • Audio, electronic, visual and similar information, such as photos and videos;
  • Professional or employment-related information, such as work history and prior employer;
  • Non-public education information; and
  • Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

The categories of sensitive personal information are account log-in and password, financial data, or other credentials allowing access to your account, biometric information, and any other sensitive personal information you may provide in your account or post about yourself.

The purpose for which we use your personal information, and the sources of that information, are described in the main Privacy Policy, including the “Lawful Basis” subsection. We describe our information disclosure practices, including disclosure of information to third parties (as defined by the CCPA) in the Policy.

Right of California Residents

For Users who are California residents, you have the following rights (in addition to those listed in the Policy) under the California Consumer Privacy Act (CCPA), and you have the right to be free from unlawful discrimination for exercising your rights under the Act:

  • You have the right to request that we disclose certain information to you and explain how we have collected, used and shared your personal information over the past 12 months.
  • You have the right to request that we correct inaccurate personal information that we maintain about you.
  • You have the right to request that we delete your personal information that we collected from you, subject to certain exceptions.

Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the App and Sites to you. If you ask us to delete it, you may no longer be able to access or use the App and Sites.

If you want to exercise any of your rights listed above please visit our Feedback Page or email our Data Protection Officer at [email protected]. You may be required to verify your identity before we fulfil your request. We may request additional information from you to match with our existing records to verify your identity, depending on the nature of the request and the sensitivity of the information sought. You can also designate an authorised agent to make a request on your behalf. To do so, you must provide us with written authorisation or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

“Sales” & “Sharing”

The CCPA requires businesses that “sell” personal information, as the term “sell” is defined under the CCPA, to provide an opt-out from such sales. Some people have taken the position that when a website uses third parties’ cookies or similar technology for its own analytics or advertising purposes, the website is engaged in a “sale” under the CCPA if the third parties have some ability to use, disclose or retain the data to improve their service or to take steps beyond the most narrowly drawn bounds of merely providing their service to the website/app. Some take this position even when the website pays the third party (not vice versa), and in most cases merely provides the third party with an opportunity to collect data directly, instead of providing personal information to the third party. As part of these analytics and advertising services, these technologies may access identifiers (like IP addresses), internet or other electronic network activity information (like information regarding an individual’s browsing interactions on our Services), and commercial information (like the fact that a browser visited a page directed to people who are considering the use of our Services) to those sorts of companies. While we do not believe these are “sales” as that term is defined under the CCPA, you can opt out of this activity by visiting this link: Do Not Sell or Share My Personal Information.

The CCPA also requires businesses that “share” personal information to provide an opt out from such sharing. Under the CCPA, “sharing” is defined as the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites. We “share” information for these purposes to provide more relevant and tailored advertising to you regarding our Services. As part of this advertising, we may “share” identifiers (like IP addresses and email addresses), internet or other electronic network activity information (like information regarding an individual’s browsing interactions on our Site), and commercial information (like the fact that a browser visited a page directed to people who are considering a subscription to the Services) with advertising platforms and advertising networks. To opt out of such “sharing,” please visit this link: Do Not Sell or Share My Personal Information

Please note that we also respond to and abide by opt-out preference signals sent through the Global Privacy Control. Any opt out preferences you have exercised through these methods will only apply to the specific device/browser on which you made them. For more information on how to use the Global Privacy Control, see www.globalprivacycontrol.org.

We do not knowingly “sell” or “share” the personal information of children under 16.

Sensitive Personal Information

The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for purposes for which you cannot opt out under the CCPA.

Retention of Your Personal Information

See policy

Notice of Financial Incentive

We may provide certain rewards or incentives for providing your email address or referring friends and contacts and may occasionally run sweepstakes and contests where participants may provide personal information in return for a chance to win or compete to win certain prizes. In addition, from time to time, as part of a joint promotion with a third party, we may, if you participate in such a promotion, disclose your contact information to the third party to allow them to market their products or services to you. Where this is a condition for participation in a promotion, we will always let you know before you enter the promotion. Please follow the instructions provided to you by third parties to unsubscribe from their messages.

You can opt into these incentives, sweepstakes, contests, or promotions by taking the requested action. Your participation is completely voluntary, and you have a right to withdraw from these incentives at any time. If you decide you don’t want to participate in these financial incentives, you can refrain from taking the requested actions.

The specific reward or incentive offered, if any, is made available to you when you provide the information requested or submit a review. The monetary value of the reward or incentive is a reasonable approximation of the monetary value of the information you provide us. We have arrived at this estimate based on consideration of multiple factors, including the following: (1) revenue generated by us in developing insights on our customers; (2) expenses incurred by us in operating the incentives; and (3) our reasonable assessment of revenue we may generate as a result of the referrals or other personal information provided to us by our users.

Shine the Light

California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. If you wish to find out about any rights you may have under California Civil Code section 1798.83, you can write to us at [email protected].