PRIVACY POLICY

 

Last updated July 18, 2022

 

This privacy policy applies to the processing of personal data that takes place within the framework of UBARGO LTD, that is, when you use the service UBARGO LTD at ubargo.com and in related digital applications ("the Services"). The service is provided by UBARGO LTD, with company number 13847331 ("UBARGO LTD ", "we" or "us").

 

UBARGO LTD is the controller of personal data as described in this policy, unless otherwise stated.

 

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@ubargo.com

To give you the world’s best price and product comparison service, we need to process personal data. In our privacy policy we explain what information we collect from our users, how we process it, and what we do to protect the integrity of our users.

 

1. WHAT INFORMATION DO WE COLLECT?

 

PERSONAL INFORMATION YOU DISCLOSE TO US

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

 

PERSONAL INFORMATION PROVIDED BY YOU.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. Personal data in this category could be name, address, phone number, email address, and other information depending on what you choose to submit to us.

 

SENSITIVE INFORMATION.

We do not process sensitive information.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in this Privacy Policy.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.

Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's camera, microphone, sms messages, calendar, contacts, social media accounts, storage, sensors, reminders, Bluetooth, and other features. If you wish to change our access or permissions, you may do so in your device's settings.

Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.

Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

 

INFORMATION AUTOMATICALLY COLLECTED

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies.

 

THE INFORMATION WE COLLECT INCLUDES:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).

Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect

geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

 

INFORMATION COLLECTED FROM OTHER SOURCES

To enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behaviour data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g. Facebook or Twitter), we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account's privacy settings.

 

PERSONAL DATA FROM OTHER SOURCES

We may from time to time receive personal data from other sources, that is, personal data that is not collected directly by us from you as a user. Such sources may be advertisers, advertising networks, authorities, or our partners. For example, one of our partners could provide us with information on how you acted after you clicked on a product in the Services. Another example is when our partners provide profiling information consisting of probability-based information about your interests, which helps us optimise our and our partners' marketing and campaigns.

 

2. WHY WE PROCESS PERSONAL DATA

In order for you as a user to understand why we process personal data, we have chosen to categorise our processing based on its purpose. We process personal data for a number of reasons, namely:

i) to fulfill our contractual obligations,

ii) to comply with legal requirements,

iii) to provide the Services, including customer support,

iv) to analyse the traffic on and to the Services,

v) to be able to show relevant marketing outside the Services,

vi) to send newsletters and similar communications to our users,

vii) to personalise our Services, including our partners' advertising, and

viii) to be able to troubleshoot the Services and investigate misuse.

 

 

More detailed information about purposes (iii) to (viii) are as follows.

 

We process personal data to be able to deliver a functional and user-friendly service, among other things by adapting the Services to your technical user situation and the choices you make on the Services. Processing of personal data for this purpose also include the processing we do for us to handle support issues and to respond to the feedback from our users.

The processing of personal data for this purpose is based on our legitimate interest in providing basic functionality and service related to the Services.

 

iv) To analyse the traffic on and to the Services

We want to be able to create the best possible conditions for improving the Services. Therefore, we collect information about the traffic on the Services and on the websites and apps that provide the Services. Such information helps us understand our users, understand market trends, identify improvement potential in the Services, and much more.

The processing of personal data for this purpose is based on our legitimate interest in analysing and improving the Services. You can nevertheless choose to turn off the analysis function and our processing of personal data for this purpose in our privacy settings.

 

v) To be able to show relevant marketing outside the Services,

We want to reach our users with relevant ads and other types of marketing even when you are on other websites and in other apps. In order to know what's relevant to you, we need to process personal data. This includes information about what you have shown interest in when you have used the Services, your geographical location, and your demographic profile. By sharing such information with marketing networks and marketing platforms such as Facebook, Google, and Appnexus, we can create a probability-based customisation of our marketing and measure its impact by marketing analysis.

Facebook and Google are personal data controllers for their respective processing for this purpose. Regarding Appnexus, their personal data liability varies depending on how and by whom the personal data is collected. Contact us if you want to know

more about their respective responsibilities and how you as a user can control their processing of personal data.

The processing of personal data to offer relevant marketing outside the Service is based on our legitimate interest. We share personal data with Facebook, Google, for this purpose. Please contact us to learn more about how we share personal data with Facebook and Google. You can at any time disable sharing of personal data with Facebook and Google in our privacy settings.

 

vi) To send newsletters, price alerts, and similar communications to our users

If you have an active user account with us, or if you subscribe to our digital mailings, we may send you emails with offers and marketing. These types of offers or marketing can also be sent via other digital contact paths, such as social media. You can choose to be exempt from these mailings at any time by contacting us.

The processing of personal data for this purpose is based on our legitimate interest if you have an active user account with us, or it is based on consent if you have actively chosen to subscribe to our newsletters and offers. You can withdraw your consent at any time by contacting us.

 

vii) To personalise our Services, including our partners' advertising

We want to create a personalised user experience of the Services, by amongst other things adapting the content of the Services according to the user's individual preferences. This also includes customising ads and marketing across UBARGO LTD properties.

The personal data processed for this purpose are user behaviours, IP addresses, purchase history, and approximate geographical position. With that information, the likelihood that you get relevant content and advertising increases when you are using the Services.

 

viii) To be able to troubleshoot the Services and investigate misuse

We process personal data relating to our users' activity on the Services in order to be able to troubleshoot our systems, which is a fundamental part of our security work on

the Services. We also process personal data in order to investigate misuse of the Services and the websites and apps where the Services are provided. Abuse refers to, among other things, creating fake profiles, harassment, acting in violation to our terms, or acting in violation of applicable law.

If we discover or suspect misuse of the Services, we may share personal data with others in order to investigate and combat such misuse. Processing of personal data for this purpose is based on our legitimate interest in offering a secure service.

 

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

 

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.

Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

Send users information about special offers and discounts on our products and services

Develop and display personalised and relevant advertising content for our users

Analyse how our services are used so we can improve them to engage and retain users

Support our marketing activities

Diagnose problems and/or prevent fraudulent activities

Understand how our users use our services so we can improve user experience

Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

 

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g. Google Maps API, Places API). To find out more about Google’s Privacy Policy, please refer to this link.

Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

Offer Wall. Our application(s) may display a third-party hosted 'offer wall'. Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our application(s) and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward.

We will not share, sell, transfer or otherwise disclose personal data other than as set out in this privacy policy.

 

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

The Services, including our offer wall, may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

 

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

 

7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

 

8. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose

in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

 

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided here in this Privacy Policy.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/info/law/law-topic/data-protection

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html

 

Withdrawing your consent:

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in in this Privacy Policy.

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

 

Opting out of marketing and promotional communications:

You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided in this Privacy Policy. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

 

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

Log in to your account settings and update your user account.

Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies:

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.

 

If you have questions or comments about your privacy rights, you may email us at info@ubargo.com .

 

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

 

12. DO WE MAKE UPDATES TO THIS NOTICE?

We may update this privacy notice from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

 

13. HOW CAN YOU CONTACT US

If you have questions or comments about this notice, you may email us at info complaint or detail info@ubargo.com or by post to:

 

61 Bridge Street,

Kington,

United Kingdom

HR5 3DJ

 

BARGAIN? UBARGO