Effective Date: October 28, 2019

We may update or change this policy from time to time. Any changes we make to this Privacy Policy in the future will be posted on this page and, where appropriate, we will notify you through an appropriate method (for example, via a pop-up notice or email). Please review this Privacy Policy whenever you access the Services to stay informed of our practices.

Key points:

You can find information about us and how we collect, use and store your personal data in each section of this policy:

• Who we are
• Information we collect from you
• Lawful basis for use of your information
• How your information will be used
• Disclosure of your information
• Your rights
• Security of your information
• International transfers
• Contact

Who we are

We are Sugar Inc UK Limited, a media and technology company based in England. If you need it, our company number is 06552656. We are owned by Group Nine Media Inc. All references in this policy to "POPSUGAR", "our", "us" or "we" refer to Sugar Inc UK Limited, or our group companies (including POPSUGAR Inc.) and suppliers which provide services to us, as appropriate. For our POPSUGAR Voices or Influencer platforms, both Sugar Inc UK Limited and POPSUGAR Inc. act as independent data controllers with respect to your user information, and each company will process your user information in connection with this Privacy Policy.

We take your privacy seriously and have developed this Privacy Policy (EU) ("Privacy Policy") to explain what we collect from our users ("users" or "you") and how we use and share this information. All references in this Privacy Policy to "our website", are a reference to the website owned by POPSUGAR that you are currently accessing, and this Privacy Policy applies to your use of our website and any related services (please see our Terms of Service) (collectively, the "Services").

We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your user information. We also want you to know your rights in relation to your information, which you can find in this Privacy Policy.

In line with these values, this Privacy Policy tells you what to expect when we collect and use information about you. We have tried to make it easy for you to navigate so you can find the information that is most relevant to you and our relationship with you. We refer to this information as "user information" throughout this Privacy Policy.

We are always looking to improve the information we provide to our customers and contacts so if you have any feedback on this Privacy Policy, please let us know using our contact details below.

Who this policy applies to

This policy applies to:

Visitors to our websites and users of our related services;

People who contact us with enquiries; and

Members and contributors on our POPSUGAR Voices and Influencer platforms.

Your rights to object

You have various rights with respect to our use of your user information as set out in Section 5 (YOUR RIGHTS). Two of the fundamental rights to be aware of are as follows:

You may ask us to stop using your user information for direct-marketing purposes. If you exercise this right, we will stop using your user information for this purpose.

You may ask us to consider any valid objections which you have to our use of your user information where we process your user information on the basis of our, or another person's, legitimate interest.

• You can exercise your rights to object here.

You can find out more information in Section 5 (YOUR RIGHTS).

What you need to do and your confirmation to us

Please read this Privacy Policy carefully to understand how we handle your user information. By engaging with us in the ways set out in this Privacy Policy, you confirm that you have read and understood the entirety of this Privacy Policy as it applies to you.

1. DEFINITIONS YOU NEED TO KNOW AS USED IN THIS PRIVACY POLICY

Cookies and Web Beacons

Some of the user information is collected on the Services through the use of Cookies and/or Web Beacons.

"Cookies" are small data file identifiers that are transferred to your computer or mobile web browser that allow us, and third parties with whom we partner, to recognise your browser or mobile device and transfer information about you and your use of our Services. For example, Cookies that we use tell us how many times you have visited one of our websites, your search preferences, and if you have clicked on an advertisement that has been displayed to you. We use "persistent" Cookies to save your login information for future logins to the Services. We also use "session ID" Cookies to enable certain features of the Services, to better understand how you interact with the Services and to monitor aggregate usage by users and web traffic routing on the Services. Unlike persistent Cookies, session ID Cookies are deleted from your computer when you log off from a Service and close your browser.

Where we use Cookies on our website, you may block these at any time. To do so, you can usually instruct your browser by changing its settings to stop accepting Cookies or to prompt you before accepting a Cookie from our websites that you visit. If you choose to disable all Cookies, you may not be able to use all portions of the Services or all functionality of the Services.

"Web Beacons" are small, invisible graphic images that may be used on the Services interface or in emails to collect certain information and monitor user activity on the Services interface, such as to count visits, access Cookies, understand usage effectiveness, and to determine if an email has been opened and acted upon. "Pixels" or "Pixel Tags" also known as clear GIFs, beacons, spotlight tags or web bugs, are a method for passing information from the user's computer to a third party website. We (and third parties with whom we partner) may deliver Web Beacons, Pixels or Pixel tags to you through our Services. Web Beacons allow ad networks, marketing partners and other service providers that we use to provide anonymised, aggregated auditing, research and reporting for us, for advertisers and our other partners. Web Beacons also enable ad networks and other partners to track your behavior for their own analysis and use, and to serve targeted advertisements to you when you visit other websites or platforms. These Web Beacons enable third party companies to view, edit, or set their own Cookies when you visit the Services, just as if you had visited a web page from their site.

Other Definitions

We use a number of other terms throughout this Privacy Policy, including the following:

IP Addresses (also known as Internet Protocol Addresses) consist of a unique string of numbers automatically assigned to a device whenever you access the Internet (but which may be identical to the IP Address of other users on the same network).

Device ID (also known as a device identification number) is a distinctive number associated with a mobile device.

Log Files (also known as log data) may include IP Addresses, browser type, internet service provider referring/exit pages, operating system, date/time stamps and/or clickstream data, including any clicks on customized links.

Local Shared Objects are pieces of data that websites may store on a user's computer, including Browser Cookies and Local Storage.

2. INFORMATION WE COLLECT OR RECEIVE

Some user information you provide to us directly, some user information is collected automatically when you use the Services and some user information we receive from third parties, such as our third party vendors and publicly available sources such as public websites, which we refer to as "third party sources" or "suppliers" throughout this policy.

This Privacy Policy does not apply to the practices of any other company or individual that is not owned or controlled by POPSUGAR.

Our website may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third-party websites or any association with their operators. This Privacy Policy only applies to the user information that we collect or which we receive from third party sources, and we cannot be responsible for user information about you that is collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any user information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.

Information that you provide to us directly

User information you provide to us directly may include any of the following information about you, depending on the portion of the Services used:

your name;

your age;

your date of birth;

your email address;

information about your article preferences;

details of your topics of interest;

any user-generated content that you submit;

information regarding your social media accounts;

your postal address;

your telephone number;

information provided when you correspond with us; and

any updates to information provided to us.

Some of the user information we collect directly from you is collected with your consent. At other times, the user information we collect directly from you is necessary for us to collect in order to ensure the adequate performance of the contract between you and POPSUGAR, to enable us to comply with legal obligations, and/or given our legitimate interest in being able to provide the functionalities of the Services. Depending on the portion of the Services used, this may include the following:

We use some user information to ensure the security of our website, including carrying out age verification checks. When you sign up for an account on the Services, we collect your date of birth in order to verify that you are over the age of 13. Date of birth information provided by you when creating an account is used for age verification purposes only.

We need certain account and profile information, including username and password as well as contact information like your email address, in order for you to create an account on the Services. This enables you to access certain features of the Services that are not available without an account. For example, creating an account enables you to use the "Favorites" feature on the Services.

On our POPSUGAR Voices and Influencer platforms, we need your account and profile information, including contact information, in order for you to submit content submissions and to enable us to determine what assignments or projects are a good fit for your skills and interests, as well as to process payments for your services if you are selected for a paid assignment.

When you take a quiz or respond to a poll on the Services, we need to record your responses and IP Address in order to provide an outcome (for quizzes) or report your vote as part of the final count (for polls).

We need certain user information (such as account information) to recognise you when you return to our website, to store information about your preferences and to allow us to customise the website in order to engage with certain features of the Services and improve your experience with the Services.

You may also choose to provide us with user information that is not essential to the function of the Services in order to engage with certain features of the Services and improve your experience with the Services. This additional user information that you provide will be processed in connection with the performance of the contract between you and POPSUGAR and/or given our legitimate interest in being able to provide the functionalities of the Services and providing customer service to our users. Depending on the portion of the Services used, this may include the following:

You may choose to provide user information as part of your account or profile that is not essential to the function of the Services, such as age and/or date of birth, "About" information, profile photos, article preferences or topics of interest, and links to your social media accounts and websites.

We may receive your user-generated content when you provide it to us (for example, photos that you take or upload, comments that you provide, or URL links).

When you send an email to us, we will receive your email address and other information associated with your request.

Information that we automatically collect

When you use the Services, we automatically collect certain user information, including information about the Services you use and how you use them. Except as otherwise stated below in this Section, this user information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations, and/or given our legitimate interest in being able to provide the functionalities of the Services. Depending on the portion of the Services used, this may include the following:

Log Data. We collect Log Files and usage information when you access, use and interact with the Services (even if you have not created an account or logged into your account on the Services), including IP Address, date and time that you signed up for an account, language setting, browser type, operating system type, internet service provider referring/exit pages, page you requested, user agent, date and time stamps, clickstream data, and information about your search and click activity in order to improve your user experience on the Services and for various types of analysis about our audience, as well as for legal compliance, to prevent fraud, and for other security purposes. Through our third party consent management platform, we maintain a log of user consents to Cookies and tracking by third parties on the Services, which includes a date and timestamp linked to your IP Address.

Cookies and Similar Technologies. We use Cookies and other similar technologies for marketing and advertising purposes, such as IP Addresses, Web Beacons, Pixels, and other identifiers and may also allow our business partners to use these tracking technologies on the Services, or engage third party providers to track your behavior on the Services on our behalf. Generally, we rely on your consent to use Cookies and similar technologies for advertising purposes (as described below under Advertising and marketing). We participate in the IAB Transparency and Consent Framework to give you greater transparency into how your data is processed so you can make a choice.

Location Data. We collect certain non-precise information about the approximate physical location (for example, at the city or postal code level) of your computer or device derived from the IP Address of such computer or device to offer you an improved user experience and in order to ensure that we are providing you with the correct experience based on your territory, including showing you relevant advertisements and providing privacy notices, consent options, and other information required by applicable laws. Please note that POPSUGAR itself does not collect precise location in connection with an Offer (as described below under Advertising and marketing).

Information that we receive from third parties

We may also receive certain user information about you from third parties. This User information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations, and/or given our legitimate interest in being able to provide the functionalities of the Services and allowing us to improve the Services for our users. Depending on the portion of the Services used, this may include the following:

If you use a third party connection or log-in (via Facebook Connect or Google) in connection with the Services, we may receive your name, email address and/or profile photo for those third party services.

We may receive various types of user information from our third party partners and vendors, such as analytics data about your visits to our sites and reporting information about ad campaigns.

We will not use your user information in any way that is incompatible with the purposes set out in this Section 2. Please contact us using the details below if you want further information on the analysis we will undertake to establish if a new use of your user information is compatible with these purposes.

We keep your user information for no longer than necessary for the purposes for which the user information is processed. The length of time we retain user information for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

Children and our Services

The Services are not directed to children under 13, and we do not knowingly collect or solicit user information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any information about yourself to us. If a parent or guardian becomes aware that their child has provided us with user information without their consent, please contact us at privacy@popsugar.com.

3. LAWFUL BASES FOR PROCESSING

When you access or use the Services, we collect, use, share and otherwise process your user information as described in this Privacy Policy. We rely on a number of lawful bases in order to use your information in these ways. These lawful bases include where:

It is necessary to use such user information in order to perform our obligations under any contract with you (for example, to comply with our Terms of Service which you accept by browsing our website and/or in order to provide the Services to you);

It is necessary to process the user information in order to comply with a legal obligation;

If the above do not apply then use of your user information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website). Our legitimate interests are to:

1. run, grow and develop our business;
2. operate and improve our Services;
3. to provide customer service to our users;
4. marketing, market research and business development;
5. understanding advertising campaigns on the Services;
6. for the POPSUGAR Voices and Influencer platforms, selecting the right person to engage for the particular campaign and communicating with you about submission opportunities and other information related to your engagement by POPSUGAR;
7. for internal group administrative purposes;
8. keeping our Services secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage; and
9. to protect your life or other vital interests or those of a third party.

We may process your user information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time after giving it, as described below).

If we rely on your consent for us to use your user information in a particular way, but you later change your mind, you may withdraw your consent by contacting us at privacy@popsugar.com and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide the Services to you.

4. HOW WE MAY USE AND SHARE YOUR INFORMATION

We may use and share your user information in the following ways, depending on the portion of the Services used:

User profile and submissions

Certain user information from your profile such as your user name or any video or image content that you have uploaded to the Services may be displayed to other users to facilitate user interaction within the Service or address your request for Services. Such user information is used by us as necessary for the adequate performance of the contract between you and us and/or given our legitimate interest in being able to provide the functionalities of the Services.

For our POPSUGAR Voices and Influencer platforms, user information from your profile may be shared with third parties including advertisers in connection with an advertising campaign, which may include publicly available metrics related to your social media channels and a description of your blog or other content you have created in the past. Such user information is disclosed by us as necessary for the adequate performance of the contract between you and us and/or given our and such third parties' legitimate interests in selecting the right person to engage for the particular campaign.

Contact and communications

We may use your user information to contact or communicate with you, for example, by email, postal mail, pop-ups or other notices on our websites or applications, or other means available through the Services. Such communications may be sent as needed to carry out other purposes described in this Privacy Policy and may contain messages of a commercial or non-commercial nature, such as messages sent to notify you that our Privacy Policy has changed, or for other administrative purposes related to the Services. Such user information is used by us as necessary for the adequate performance of the contract between you and us and/or given our legitimate interest in being able to provide the functionalities of the Services. Sometimes user information is used by us with your consent.

For our POPSUGAR Voices platform, your email address may be used to send you the Voices newsletter. The use of your email in this way is to support our legitimate interest in communicating with you about submission opportunities and other information related to your engagement by POPSUGAR in connection with Voices.

We may use information you provide to us in order to deal with any enquiries or issues you have about how we collect, store and use your user information, or any requests made by you for a copy of the information we hold about you. We may also use your user information for improvement and maintenance of our website and to provide technical support for our website. Use of your user information for these purposes is to enable us to comply with legal obligations, and/or supports our legitimate interest in providing customer service to you.

Understanding our audience and improving our Services

We and our partners use Cookies and other tracking technologies to administer the Services, analyse trends, track users' movements around the Services and on third party sites, devices and applications, and to gather demographic information about our user base.

We may also receive certain data (on an individual and/or aggregated basis) collected by our partners (including but not limited to e-commerce partners, affiliates, and analytics providers), including through the use of Pixel Tags, e-tags, IP Addresses, and Local Shared Objects, which allows us to:

Analyse trends across our user base;

Supplement our server logs and other methods of traffic and response measurement;

Track users' location and movements around the Services; and

Improve our understanding of traffic on the Services and visitor behavior.

When you receive email messages from us, we may use Web Beacons, customized links, clear GIFs or similar technologies to determine whether the email has been opened and which links you click.

Our collection and use of the user information described in this section is based on our legitimate interests in understanding how our Services are being used, and to develop new products and services and grow our business. It is also necessary to allow us to pursue our legitimate interests in improving our Services, including through increased efficiency.

Third party service providers

We employ or utilise the services of certain third party vendors, consultants and service providers who need access to your user information (such as your name, address, email, or other identifiers) in order to enable them to perform services on our behalf or to provide us with additional information necessary to provide Services to you. We use third party vendors for a variety of services across our Services, such as email message deployment, research, statistical analysis, cross-device user tracking, data and website hosting, and other data and transaction processing. These third party vendors have only limited access to your user information, and may use your information only to perform these tasks on our behalf.

In addition to receiving your user information from us, our service providers may also:

Collect information directly from you and/or your device, such as your IP Address, Device ID, and information about your browser or operating system;

Combine user information about you received from POPSUGAR with information about you from other sites or services; and/or

Place or recognise a unique Cookie or other tracking mechanism on your browser.

Our engagement of service providers is often necessary for us to provide the Services to you. In such cases, the sharing and processing of user information by those service providers is necessary for the adequate performance of the contract between you and POPSUGAR, to enable us to comply with legal obligations, and/or given our legitimate interest in being able to provide the functionalities of the Services.

In other cases, these service providers are not strictly necessary for us to provide the Services to you, but help us to improve the Services, such as when we conduct research into how we could better serve our users. In these latter cases, we have a legitimate interest in working with service providers to make our Services better.

Advertising and marketing

POPSUGAR works with third parties to provide analytics information regarding your usage of our Services or to help us track the advertisements that are delivered to you on the Services to determine the effectiveness of advertising on our Services. We may also link this information to other user information that we hold about you.

Certain third party vendors and partners authorised by POPSUGAR (including, but not limited to, advertisers, advertising agencies, ad networks, ad measurement providers, and other marketing and advertising service providers and partners) ("Advertisers"") may also collect information about you on the Services in order to provide you with relevant advertising on the Services and on other websites, platforms and media channels, and to analyse the performance of advertising campaigns. These Advertisers may use tracking technologies such as Cookies, Web Beacons, and other similar technologies, and may collect many different kinds of data, such as your IP Address and Device ID. The specific Advertisers we work with are subject to change at any time. For a list of some of the applicable providers or for more details on opting out of tracking for advertising purposes, please use our consent management platform by clicking on the button in the lower right corner of the cookie banner labeled "Show Purposes," or navigating to the "Manage Purposes" link at the bottom left corner of the home page. The use of tracking technologies by these third parties is subject to their own privacy policies.

Some Advertisers may combine the user information they collect about you on the Services with their own data about you to form a more detailed picture. We may also share your information with Advertisers for the purpose of allowing them or their clients to send you marketing communications related to your use of the Services, their services or programs featured and/or advertised on the Services (for example, through advertisements), or their products, services and/or programs generally.

Our third party vendors and partners use your user information to display ads on both the Services and on third party websites, applications, platforms and other media channels (collectively, "Channels""). For example, if you read content about a particular subject on the Services, we may use Cookies from a vendor to later serve you an advertisement for a particular product or service related to the viewed article. These third party vendors may connect information about pages you visit on the Services with information about pages you visit on other Channels and show you advertising based on this combined information. These advertisements may appear when you are visiting a different section of the Services or on another Channel. Likewise, third party vendors may serve you advertisements when you visit the Services based on your interaction with the Services and other Channels.

Some of our Services may include digital promotional offers in the form of coupons, or discount or rebate cards from POPSUGAR or one of its advertiser partners that you elect to save into your digital wallet (e.g., Apple Wallet or Android Pay) on your mobile device ("Offers"). When you engage with such Offers, your IP address, user agent, operating system, and other non-personal data about your interaction with such Offer may be collected by Advertisers. Also, the developer of your digital wallet (e.g., Apple for iPhones devices or Google for Android devices) may collect your precise location of your device. The collection and use of such data by these third parties is subject to their own respective terms and privacy policies.

Some of our Services may use Facebook and Instagram features and tools, including Pixel Tags, which send data regarding your use of the Services to Facebook and/or Instagram for the purpose of tracking your interaction with the Services and with our brand on Facebook and Instagram, and to create custom audiences on the Facebook and/or Instagram platforms. Facebook and Instagram link the data collected on our Services with your account on their platforms and we and/or our Advertisers may use that data to serve you with advertisements both on and off of Facebook and Instagram.

In order to help us sell advertising on the Services and otherwise publicise POPSUGAR and its products and services, we may share aggregate statistics that describe our online audience. Those statistics are often based on the information you provide when you subscribe, register, or browse the Services and describe, among other things, the demographics of our visitors.

Generally we will rely on your consent for third parties to track you and otherwise collect and process your Personal Data on the Services for advertising purposes, including profiling. Where we rely on your consent for such processing, you can withdraw your consent at any time (see the section below entitled YOUR RIGHTS).

With respect to processing of Personal Data in circumstances where we are not relying on consent as the legal basis for processing, such as processing of Personal Data for fraud detection and prevention and other types of processing related to the performance of ad campaigns (for example, to measure how many people saw an advertisement) and your interaction with advertisements (for example, to determine how many people clicked an advertisement), this processing is based on our and our Advertisers' and partners' legitimate interests in understanding the effectiveness of advertising campaigns on the Services and on other Channels and preventing fraud.

Social plug-ins and embeds

We may use social plug-ins on our Services, for instance plugins of the social networks such as Facebook, Twitter, Google+, Pinterest and Tumblr, and may feature icons, like the "thumbs up" icon or text like "Recommend", "Like" or "Comment". We also feature certain embedded content on our Services such as text and video content embedded from social networks and other third party platforms including, but not limited to, Facebook, Twitter, YouTube, Pinterest, and Vimeo. Your browser may create a connection to the servers of such social networks and other third parties and/or transmit data to such third party servers when you view a page on the Services. These interactions are subject to the privacy policy of the applicable third party. This Privacy Policy does not cover the practices of these third party social networks.

Sharing of aggregated information

We may also share demographic information with business partners in an aggregated and de-personalized format, so that Personal Data is not shared.

Safety and security

We may also use your user information for safety and security purposes, including sharing of your information for such purposes, and we do so because it is necessary to pursue our legitimate interests in ensuring the security of our Services, including enhancing protection of our users against security risks of all kind.

Legal compliance and safety

We may retain, preserve, or release your user information to a third party in the following circumstances:

In response to lawful requests by public authorities, including to meet legitimate national security or law enforcement requirements;

To protect, establish, or exercise our legal rights or defend against legal claims;

To ensure the safety of POPSUGAR employees and agents; or

To comply with a subpoena, court order, legal process, or other legal requirement; or when we believe in good faith that such disclosure is reasonably necessary to comply with the law, prevent imminent physical harm or financial loss, or investigate, prevent, or take action regarding illegal activities, suspected fraud, threats to our property, or violations of our Terms of Service.

If we receive a lawful, verified request for user's records or information in one of the limited circumstances described in the previous paragraph, we may disclose Personal Data in connection with such request, which may include, but may not be limited to, a user's name or email address.

In the above cases, our use of your user information may be necessary for the purposes of POPSUGAR's or a third party's legitimate interest in keeping our Services secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage. Such use may also be necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims. It may also be necessary to protect vital interests (in rare cases where we may need to share information to prevent loss of life or personal injury).

Business transfers

We may share your user information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition, or in any other situation where user information may be disclosed or transferred as one of our business assets. In these types of transactions, user information is typically one of the business assets that will be transferred. Such transactions may be necessary and in our legitimate interests, particularly our interest in making decisions that enable our business to develop over the long term.

5. YOUR RIGHTS

You may exercise any of the rights described in this section. If you would like further information in relation to these or would like to exercise any of them, please click here or contact us via email at privacy@popsugar.com. Please note that we may ask you to verify your identity before taking further action on your request.

We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period allowed by applicable law). Please note, however, that certain user information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.

If an exception applies, we will tell you this when responding to your request.

You have the following rights:

Right of access

You have a right of access to any user information we hold about you. You may access and update some of your user information through your user account settings on the applicable Services. You may add, update or delete information, which limits the ability of other users to see the information in your user profile. You can ask us for a copy of your user information; confirmation whether your user information is being used by us; details about how and why it is being used; and details of what safeguards are in place if we transfer your information outside of the European Economic Area ("EEA").

In order to de-link your POPSUGAR account from your account on Facebook or Google, you must adjust your account settings with the third party application. For example, if you want to de-link your Facebook account with POPSUGAR, you must de-link your accounts in your Facebook application settings.

Right to update your information

You have the right to ask us to correct inaccurate or incomplete user information concerning you that we hold.

Data portability

You have a right to ask us to provide your user information to a third party provider of services. This right only applies where we use your user information on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.

Data retention and erasure

You have a right to ask us to delete any user information which we are holding about you in certain specific circumstances. If you no longer want us to use your user information to provide Services to you, you can request that we erase your user information and close your user account(s).

We will pass your request onto other recipients of your user information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contact details in Section 8 (IDENTITY AND CONTACT INFORMATION OF THE DATA CONTROLLERS).

Please note that if you request the erasure of your Personal Data:

We may retain some of your Personal Data as necessary for our legitimate business interests, such as for safety or security purposes as well as fraud detection and prevention.

We may retain and use your Personal Data to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations.

Information you have shared with others may continue to be publicly visible on the Services, even after your user account deleted. However, attribution of such information to you will be removed. Additionally, some copies of your user information (such as Log Files) may remain in our database after deletion of your account, but are disassociated from personal identifiers like name and email.

We maintain back-up copies of our database to prevent accidental loss of data. Because of this, residual copies of your Personal Data may not be removed from our backup systems for a limited period of time.

Withdrawing consent and restriction of processing

(a) Withdrawing consent.

Where you have provided your consent to the processing of your user information by POPSUGAR, you may withdraw your consent at any time by changing your user account or by sending a communication to privacy@popsugar.com specifying which consent you are withdrawing.

Where we rely on your consent as the basis for allowing third parties to track you on the Services and process your user information for advertising purposes (including profiling), you can withdraw your consent from tracking and processing by one or all of such third parties by clicking on the "Manage Purposes" link at the bottom left corner of the home page.

To opt out of collection of your information by Nielsen, or to obtain information about the technologies they use or their own privacy policies, please visit the Nielsen consumer opt out page located here.

Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent prior to your withdrawal of consent.

(b) Restriction of processing.

Additionally, you have the right to limit the ways in which we use your user information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details in Section 8 (IDENTITY AND CONTACT INFORMATION OF THE DATA CONTROLLERS).

We will pass your request onto other recipients of your user information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contact details in Section 8 (IDENTITY AND CONTACT INFORMATION OF THE DATA CONTROLLERS).

Objection to processing

You are also entitled to require that POPSUGAR not process your user information for certain specific purposes where such processing is based on legitimate interest. If you object to such processing, we will no longer process your user information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims.

Right to stop marketing

Where your user information is processed for direct marketing purposes, you may, at any time, submit a request asking us to cease processing your data for these direct marketing purposes by clicking here.

Lodging complaints

In accordance with Article 77 of the General Data Protection Regulation, you have the right to lodge complaints about the data processing activities carried out to the UK Information Commissioner's Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.

6. SECURITY OF INFORMATION

We use appropriate technical and organizational measures to ensure a level of security appropriate to the risks associated with different kinds of processing of user information. However, we cannot ensure or warrant the security of any information you provide to us or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed by unauthorised persons or hardware or software failure. You are ultimately responsible for the security of your email address and password.

The main risk of our processing of your user information is if it is lost, stolen or misused. This could lead to your user information being in the hands of someone else who may use it fraudulently or make public information that you would prefer to keep private.

For this reason, we are committed to protecting your user information from loss, theft and misuse. We take all reasonable precautions to safeguard the confidentiality of your user information, including through use of appropriate organisational and technical measures.

In the course of provision of your user information to us, your user information may be transferred over the internet. Although we make every effort to protect the user information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your user information transmitted to our website and that any such transmission is at your own risk. Once we have received your user information, we will use strict procedures and security features to prevent unauthorised access to it.

Where we have given you (or where you have chosen) a password which enables you to access your online account, you are responsible for keeping this password confidential. We ask you that you create a strong, unique password that you do not use on other sites and that you not share your password with anyone.

7. INTERNATIONAL TRANSFERS

Your user information may be used, stored and/or accessed by staff operating outside the EEA working for us, other members of our group, and/or suppliers. Your user information may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If we provide any user information about you to any such non-EEA members of our group or suppliers, we will take appropriate measures to ensure that the recipient protects your user information adequately in accordance with this Privacy Policy.

Sugar Inc UK Limited transfers user information to its parent company, POPSUGAR Inc., located in the United States, so your user information will be processed in the United States.

To the extent that POPSUGAR is deemed to transfer any user information outside of the EEA, we rely separately, alternatively, and independently on certain transfer mechanisms to transfer your user information as follows. We will provide further information on the means to ensure an adequate level of data protection for your user information upon your request, which can be directed to
privacy@popsugar.com.

Standard contractual clauses

The European Commission has adopted standard contractual clauses (also known as model clauses), which provide safeguards for user information that is transferred outside of the EEA. We often use these standard contractual clauses when transferring user information outside of the EEA, including where we transfer data between Sugar Inc UK Limited (our UK entity) and its parent company POPSUGAR Inc. in the United States.

Privacy Shield

None of the POPSUGAR entities participate in Privacy Shield. However, we may rely on the EU-U.S. Privacy Shield to transfer user information to some of our third party service providers and partners in the United States, where they are certified to receive such information under the Privacy Shield Program.

Adequacy decisions

In some cases we may transfer your user information to certain third party service providers and partners of POPSUGAR based on an adequacy decision of the European Commission confirming an adequate level of data protection in the non-EEA country of the receiving party.

8. IDENTITY AND CONTACT INFORMATION OF THE DATA CONTROLLERS

If you have any questions or complaints regarding our collection, use or storage of your user information, or if you wish to exercise any of your rights in relation to your user information, please contact privacy@popsugar.com. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your user information.

If you are located in the European Union, the applicable data controller with respect to your user information is Sugar Inc UK Limited.

Most user information collected through our Services will also be processed by POPSUGAR Inc., parent company of Sugar Inc UK Limited, which acts as a data processor with respect to your user information. For our POPSUGAR Voices or Influencer platforms, both Sugar Inc UK Limited and POPSUGAR Inc. act as independent data controllers with respect to your user information.

Contact details of Sugar Inc UK Limited:
Sugar Inc UK Limited
WeWork Soho
Sheraton House
14-16 Great Chapel Street
London W1F 8FL
United Kingdom

Contact details of POPSUGAR Inc.:
Group Nine Media Inc.
568 Broadway
10th Floor
New York, NY 10012