Privacy Policy

This privacy policy applies between you, the User of this Website, and SayRug Website. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

This privacy policy should be read alongside, and in addition to, our Terms and Conditions, which can be found at: https://sayrug.eu/customer-service/terms-conditions/.

Please read this privacy policy carefully.

Definitions and interpretation

In this privacy policy, the following definitions are used:

Data collectively all information that you submit to SayRug Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
Cookies a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);
Data Protection Laws any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations and secondary legislation;
GDPR General Data Protection Regulation;
SayRug company, we or us Ahtri tn 12, 10151 Tallinn, Estonia;
Cookie Law the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 & the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2018;
User or you any third party that accesses the Website and is not either (i) employed by SayRug and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to SayRug and accessing the Website in connection with the provision of such services; and
Website the website that you are currently using, https://sayrug.eu, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

In this privacy policy, unless the context requires a different interpretation:

  1. the singular includes the plural and vice versa;
  2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
  3. a reference to a person includes firms, companies, government entities, trusts and partnerships;
  4. "including" is understood to mean "including without limitation";
  5. reference to any statutory provision includes any modification or amendment of it;
  6. the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

This privacy policy applies only to the actions of SayRug Website and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

For purposes of the applicable Data Protection Laws, SayRug Website is the "data controller". This means that the SayRug Website determines the purposes for which, and the manner in which, your Data is processed.

Data collected

We may collect the following Data, which includes personal Data, from you:

  1. name;
  2. date of birth;
  3. gender;
  4. contact Information such as email addresses and telephone numbers;
  5. demographic information such as postcode, preferences and interests;
  6. IP address (automatically collected);
  7. web browser type and version (automatically collected);
  8. operating system (automatically collected);
  9. a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);
  10. other information relevant to customer surveys and/or offers;

in each case, in accordance with this privacy policy.

How we collect Data

We collect Data in the following ways:

  1. data is given to us by you; and
  2. data is collected automatically.

Data that is given to us by you

SayRug Website will collect your Data in a number of ways, for example:

  1. when you contact us through the Website, by telephone, e-mail or through any other means;
  2. when you register with us and set up an account to receive our products/services;
  3. when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
  4. when you enter a competition or promotion through a social media channel;
  5. when you elect to receive marketing communications from us;
  6. when you use our services;

in each case, in accordance with this privacy policy.

Data that is collected automatically

To the extent that you access the Website, we will collect your Data automatically, for example:

  1. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
  2. we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies".

Our use of Data

Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

  1. internal record keeping;
  2. transmission by email of marketing materials that may be of interest to you;

in each case, in accordance with this privacy policy.

We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).

For the delivery of direct marketing to you via email, we'll need your consent, whether via an opt-in or soft-opt-in:

  1. soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out.
  2. for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide.
  3. if you are not satisfied with our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed "Your rights" below.

When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

We may use your Data to show you SayRug Website adverts and other content on other websites. If you do not want us to use your data to show you SayRug Website adverts and other content on other websites, please turn off the relevant cookies (please refer to the section headed "Cookies" below).

Who we share Data with

We may share your Data with the following groups of people for the following reasons:

  1. our employees, agents and/or professional advisors - communication regarding the customer's order, payment process and delivery terms;

in each case, in accordance with this privacy policy.

Keeping Data secure

We will use technical and organisational measures to safeguard your Data, for example:

  1. access to your account is controlled by a password and a username that is unique to you.
  2. we store your Data on secure servers.

Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this email address: info@sayrug.eu.

Data retention

Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.

Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

You have the following rights in relation to your Data:

  1. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
  2. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
  3. Right to erase - the right to request that we delete or remove your Data from our systems.
  4. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
  5. Right to data portability - the right to request that we move, copy or transfer your Data.
  6. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.

To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this email address: info@sayrug.eu.

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Links to other websites

This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes to this privacy policy

SayRug Website reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.

In case of any questions you can use the following email: info@sayrug.eu

This privacy policy was created on 12 March 2022.

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