1. INTRODUCTION

HugOffers is committed to respecting and protecting individuals' privacy rights. This Privacy Policy explains how HUGOFFERS PTE.LTD (collectively, “ HUGOFFERS ” , ” HugOffers ” , " hugoffers " or "we", "us", "our") collect, use, secure, and/or disclose end users’ (“you” or “your”) device-related information when (i) you view ads served by HugOffers on third party websites, and (ii) you visit the HugOffers website at www. HugOffers .com .

Any content aggregation services or feature (such as displaying of stories, articles, pictures, blogs etc.) (whether through an app or other software integration) provided by HugOffers on a device will not be covered under this Privacy Policy, except to the extent the app or software promotes any interest based advertising by HugOffers . We urge you to refer the privacy policy of such services separately, as and when made available.

2. What information we collect and how we use it

“Personal Data” is any information relating to natural person, who can be identified directly or indirectly.

We collect the following Personal Data about you:

2 .1. Information we use to provide services

Contact Information. When you register / sign up for the Services, we may collect certain contact information from you, such as your first and last name, organization name, city, email address, and phone number or other similar contact details to help you with your experience.

Billing Information. When purchasing Services, you will be required to provide additional information that may include a credit card number or other banking or payment information. This information is required by us to verify your identity, to establish your company’s account, and set up your Services.

Service Information. In order to provide Services to you and to improve our Services, we may collect information that is created or provided by you in connection with your use of the Services, including order information, chat logs, email logs and information about your actions in various client areas on the Website.

Third Party Information. We may obtain information about you from other sources, which include [●], and add it to your account Contact Information. This combined information may be used by us to enhance our ability to provide Services to you, to ensure that we are paid for Services .

We will use your Contact Information and Billing Information to provide Services and to provide you with access to the Services you have ordered, as well as support services, technical updates or updates on changes in our usage policies. The legal basis for us to use your Contact Information, Billing Information and Service Information is the agreements you enter into with us in connection with the Services (the “ Terms of Services ”).

2.2 . Browsing Information and Cookies

“Cookies” are small files that the Website or its service provider transfers (if you allow) to your computer’s hard drive through your Web browser that enables the Website’s or service provider’s systems to recognize your browser and capture and remember certain information.

We may use Cookies, web beacons and other technical means to collect and analyze certain information about how you and other visitors use the Website. This technical information includes Internet Protocol (IP) addresses, browser information, and the preceding and succeeding websites you have visited, among other things. We may also keep a record of which pages of the Website you visit, and how long you spend on each page. Cookies can also be used to help us understand your preferences based on previous or current Website activity, which enables us to provide you with improved Services. We also use Cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better Website experiences and tools in the future. We use Google Analytics for collecting website browsing statistics.

We use Local Storage (HTML5), and our third party utility partner uses Local Shared Objects (Flash cookies) and Local Storage (HTML5) to store content information and preferences, and to display advertising based on your web browsing activity. Various browsers may offer their own management tools for removing HTML5.

You may set your browser to notify you or decline the receipt of Cookies; however, certain features of our Website or Services may not function properly or be available if your browser is configured to disable Cookies.

Legal basis for use of cookies and other information stored on your devices is your consent, which you may freely refuse to give.

2.3 WHAT ABOUT OTHER WEBSITES?

Our website and the ads we service may contain links to other websites. You should be aware that we are not responsible for the privacy practices of such other websites as those may have different privacy policies and terms of use and are not associated with us. You agree that we cannot control these links and we shall not be responsible for any use of such websites.

3. To whom we disclose your personal data

3.1. We use third party suppliers/vendors to perform the following business-related functions: data storage services, database maintenance services and payment processing. There suppliers and vendors may receive or have access to your personal data. When we employ such third party suppliers/vendors to perform services on our behalf, we will only provide them with access to Personal Data that they need to perform their specific function. We will put our reasonable efforts that each third party supplier/vendor will be required by contract to keep such Personal Data confidential and not to use it for any purpose other than providing services to us.

3.2. We may share Personal Data with the owner of intellectual property rights to the Website and software used on it and to the extent needed to perform certain business-related functions (e.g. updates, maintenance, support, etc.) for the purpose of providing Services to you.

3.3. We may disclose Personal Data to public authorities if required to do so by law or to comply with a legal obligation. If we are requested by law to disclose any of your Personal Data, we will use reasonable efforts to provide you with notice of that disclosure requirement, unless we are prohibited from doing so by statute, court or administrative order.

3.4. Our employees have access to your Personal Data only to the extent their functions are required to provide our service or otherwise act on our behalf as set forth in this Policy.

4. Data storage period

Personal Data will be stored for as long as the Personal Data is required to provide Services or requested Website functionality. Other types of Personal Data, which are not required for the provision of Services, shall be stored for a period of up to [●] or until (if) consent is withdrawn or other data subject’s rights are exercised. In some cases, Personal Data may be stored for a period longer than indicated or despite withdrawal of consent or request to erase Personal Data, if storage of Personal Data is required in order to protect our or third parties’ legitimate interests.

5. Security

We will maintain industry-standard physical, electronic and procedural safeguards designed to protect data in our possession from loss, misuse, and unauthorized access. When we transmit highly confidential information (such as a credit card number) over the Internet, we protect it through the use of encryption, such as the Secure Socket Layer (SSL) protocol. However, no method of transmission or method of electronic storage is 100% secure. We regularly test and update our technology to help protect your data. However, such precautions do not guarantee that our Website or the data stored during your use of the Services is invulnerable to hacking and will not be subject to a security breach. We make no warranty, guarantee, or representation that the Website or the Services are or will be protected from all viruses, security threats or other vulnerabilities or that your information will always be secure.

6. Links to Other Sites

For the convenience of our visitors and clients, the Website may contain links to other sites, such as those of our partners or vendors, which are subject to different privacy policies. The Policy will not apply to your use of other websites. While we generally try to link only to sites that share similar high standards and respect for privacy, we have no responsibility or liability for the content, products or services offered, independent actions, or the privacy and security practices employed by these other independent sites. We encourage you to ask questions and review the applicable privacy policies found on such other websites, services and applications to understand how your information may be collected and used on these independent sites before disclosing information to third parties.

7 . INTERNATIONAL TRANSFERS

HugOffers may share your information with clients, publishers and other third parties described above who are based in countries outside of your country of residence (for example, if you are an EU resident, we may share your information with our non-EU clients or publishers ), subject to any contractual or legal requirements.

While some countries may not have data protection laws that are equivalent to those of the country in which you reside, we will take reasonable measures to protect your information in accordance with this Privacy Policy.

8 . WHAT ABOUT CHILDREN?

HugOffers complies with the Children's Online Privacy Protection Act (COPPA) in the U.S. and does not knowingly collect personal information about users of sites directed to children under the age of thirteen (13).

9 .CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy at any time. The amended Privacy Policy will be displayed on our site. If we make any material changes we will notify you by means of a notice on this site prior to the change becoming effective. Please check our Privacy Policy regularly to ensure you have read the latest version.

10. CONTACTING US

If you have any questions regarding this Privacy Policy, or would like more information on our privacy practices, please contact us at support@hugoffers.com