Privacy Policy

LAST UPDATED: August 2024

We are committed to protecting your privacy, and we have created this Privacy Policy as part of our Terms of Service to explain what Personal Information we collect, how your Personal Information is collected, and how we may use it.

Definitions

When we say, “we,” “our,” or “us,” we’re referring to Tugger Limited, a limited liability company registered in England and Wales with company number 13220093, together with our employees, directors, officers, affiliates, and subsidiaries.

When we say “you” or “your,” we are referring to the person or entity that’s registered with us to use the Tugger Services.

When we say “Websites,” we mean our website located at Tuggerapp.com, including all subdomains and sites associated with those domains, and other websites that we operate now and in the future.

When we say “Services,” we mean our Websites, Application Programming Interfaces (APIs), applications, our content, and various third-party services that make up Tugger.

When we say “Tugger,” we mean our Websites and Services collectively.

When we say “Personal Information,” we mean all of the different forms of personal data that you provide us and that we collect from you from your use of the Services, your software, and your devices, as described below.

How We Collect Your Personal Information

• Personal Information you provide to us: When you register for and use Tugger, you are providing us with Personal Information, which we collect. This Personal Information may include your name, billing and mailing address, email address, phone number, and credit card information. We use a third-party intermediary to manage credit card processing. This intermediary is not permitted to store, retain, or use your billing information for any purpose except for credit card processing on our behalf.
• Personal Information from your use of Services: This Personal Information may include IP Address, location information, date and time, browser type, and any other action you might have taken to use and while using the Services.
• Cookies: When you use Tugger, we store "cookies," which are strings of code, on your computer. We use those cookies to collect Personal Information about when you visit our Website, when you use the Services, your browser, your operating system, and other similar information. Most browsers allow you to block and delete cookies. However, if you block our cookies, our Services may not work properly.
• Third Party Cookies: The use of cookies by third parties is not covered by our Privacy Policy. We do not have access or control over these cookies. Third parties use session ID cookies to make it easier for you to navigate our Websites. We use third-party services to provide the necessary hardware, software, networking, storage, and related technology required to run and improve our Services.
• Web Beacons: Our third party partners may employ web beacons to track online user movement to help us better understand what content is effective. Web beacons are tiny graphics with a unique identifier that are embedded in websites and in newsletter emails. With web beacons, our third party partners may collect Personal Information about you, such as your IP address, your browser or email client type, and other similar details. We use the data from our third party partners to improve our services.

Types of Personal Information We Collect

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data includes name, title, username or similar identifier
• Contact Data includes address, billing address, IP address, email address and telephone number.
• Financial Data includes payment card details.
• Transaction Data includes details of transactions made between you and us.
• Technical Data includes your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Websites and/or our Services.
• Profile Data includes your username, password and preferences.
• Usage Data includes information on how you use our Websites and our Services.
• Marketing and Communications Data includes your marketing and communication preferences.

How and Why We Use Your Personal Information

We will only use your Personal Information when the law allows us to. Most commonly, we will use your Personal Information in the following circumstances:

• Where we need to perform the Services pursuant to our agreement with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
• Where you have given your consent.

The table below explains what we use your personal data for and why.

What we use your Personal Information for	Our reasons	Categories of Personal Information
Creating and managing your account	For our legitimate interests so that we can efficiently deliver Services to you or your organisation. To perform our contract with you or your organisation for the Services.	Identity, contact and profile details
Providing Services	To perform our contract with you or your organisation for the Services.	Identity, contact, profile, financial, transaction, technical and usage information
Providing customer support in relation to those Services	To perform our contract with you or your organisation for the Services.	Identity, contact, financial, transaction, technical and usage information
Protecting the security of our Services	For our legitimate interests to protect our systems and data and to detect criminal activity. To comply with our legal and regulatory obligations.	Identity, contact, profile, financial, transaction and technical information.
Enforcing our legal rights or to defend or undertake legal proceedings	For our legitimate interests to protect our business, interests and rights. To comply with our legal and regulatory obligations.	Identity, contact, financial and transaction information.
To better understand your requirements and to personalise your experience of the Services.	For our legitimate interests, to be as efficient as we can so we can deliver the best service to you.	Identity, contact, profile, financial, transaction, technical and usage information
To improve the Services	For our legitimate interests, to be as efficient as we can so we can deliver the best service to you and our other clients.	Transaction, technical and usage information
To send you updates and alerts and to contact you about your account or the Services you use.	To perform our contract with you or your organisation for the Services. To comply with our legal and regulatory obligations. For our legitimate interests, to be as efficient as we can so we can deliver the best service to you.	Identity, contact, profile, financial, transaction, technical and usage information
Marketing our Services to you.	For our legitimate interests, to promote our business and the services we provide.	Identity, contact, marketing and communications information
To transfer your Personal Information in the case of a sale, merger, consolidation, or acquisition.	To comply with our legal and regulatory obligations. For our legitimate interests, to protect, realise or grow the value of our business and assets.	Identity, contact, financial, transaction, technical and usage information

If you no longer wish to receive our updates or marketing newsletters and emails, you may unsubscribe at any time by following the link located within our emails or contact us using any of the contact details provided below.

We will never share your Personal Information with other organisations for marketing purposes.

When We Might Share Your Personal Information

We may share your Personal Information with:

• IT and system administration service providers such as HubSpot (contact email and phone number), SendGrid (contact email) and Microsoft Power BI (contact email);
• Payment service providers such as Paddle and Stripe (contact name, email and payment card details if relevant);
• Account management software providers such as Xero (contact name, email and phone number);
• Software platform providers such as Microsoft Azure (contact name, contact email and authentication details);
• Other third parties we use to help us provide our Services or run our business, eg marketing agencies or website hosts and website analytics providers;
• Our external auditors and legal advisors;
• Law enforcement agencies, courts and regulatory bodies;
• Other parties that have or may acquire control or ownership of our business (and our or their professional advisers)

We require all third parties to respect the security of your Personal Information and to treat it in accordance with data protection law. We do not allow our third-party service providers to use your Personal Information for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Public Information and Third Parties

• Tugger Blog: We have public blogs on our Websites. Any Personal Information you provide in these areas may be read, collected, and used by anyone. If your Personal Information appears on our blogs and if you would like to remove it, you can send your request to [email protected]. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
• Third Parties: We are not responsible and this Privacy Policy does not cover your use of any third-party widgets, features, or websites or links to third-party websites or services. We encourage you to read the privacy policy of any third-party site you visit or service you use carefully.
• Testimonials: We publish customer testimonials on our Websites, which may contain Personal Information. We obtain consent to post the customer’s name along with their testimonial. To request the removal of your Personal Information from a testimonial, please email us at [email protected].
• Social Media Widgets: Our Websites include social media features. These features may collect your IP address, which page(s) you are visiting, and may set cookies to make sure they function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with those features are governed by the privacy policy of the companies providing them.

Telephone Recording

We may record telephone calls or virtual meetings for our own internal business purposes. Where your express prior consent has not been obtained, we will only record such calls or meetings for the following purposes:

• To establish the existence of facts relevant to our business. This could include keeping a record of instructions given by telephone where it is necessary or desirable to know what has been said during a conversation.
• To ascertain compliance with regulatory or self-regulatory practices or procedures relevant to our business. This would include monitoring as a means of checking that the business is complying with external regulatory guidelines.
• To ascertain or demonstrate standards that are or ought to be achieved by persons using the system. This could include monitoring for the purposes of quality control or staff training.
• To prevent or detect crime. For example, monitoring to detect evidence of fraud or corruption.
• To investigate or detect the unauthorised use of the communications system or ensure the effective operation of the system.

Security

We take precautions — including administrative, technical, and physical measures — to safeguard your Personal Information against loss, theft, and misuse, as well as against unauthorised access, disclosure, alteration, and destruction.

When you enter sensitive Personal Information (such as credit card number) on our order form, we encrypt the transmission of that Personal Information using secure socket layer technology (SSL).

We follow generally accepted industry standards to protect your Personal Information, both during transmission and once we receive it. No method of transmission over the internet, or method of electronic storage, however, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

International Data Transfers

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts which give personal data the same protection it has in the UK.

Your Legal Rights

You have the right to:

• Request access to your Personal Information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your Personal Information. This enables you to ask us to delete or remove your Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your Personal Information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios:
  • (a) if you want us to establish the data's accuracy;
  • (b) where our use of the data is unlawful but you do not want us to erase it;
  • (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw your consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.

We will retain your Personal Information and data that we process on your behalf for as long as your account is active, as needed to provide our Services, and as necessary to comply with our legal obligations and resolve disputes.

Updates to this Privacy Policy

We reserve the right to modify this privacy statement at any time. If we make material changes to this policy, we will notify you here and by email. You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.

Contact Details

If you have any questions regarding this Privacy Policy or the Personal Information we hold about you or if you wish to exercise any of your rights under data protection law, please contact us:

by email at [email protected]

by post to The Data Protection Officer, Tugger Limited, Clarence Mill Business Centre, Clarence Road, Bollington, Macclesfield, SK10 5JZ