Privacy Policy

 WWW.SANGOGBEMI.COM

Last Updated: July 14, 2024

This privacy policy (“Privacy Policy”) describes how www.Sangogbemi.com (the "Site," "we," or "us") collects, uses, discloses and processes information about you as you access our website, mobile application, and other services (collectively, our "Services"), and interact with us through customer support and social media.

We may change this Privacy Policy periodically. If we make changes, we will notify you by revising the date at the top of this policy. If we make material changes, we will provide you with additional notice by adding a statement to our Services or sending you a notification. We encourage you to review this Privacy Policy regularly to stay informed. If you have complaints about how we process your personal information, please contact us using the contact details provided below. If you are not satisfied with our response to your complaint, you may- depending on jurisdiction- have the right to appeal to your local data protection authority.

1. COLLECTION OF INFORMATION

The information we collect about you depends on how you interact with us or use our Services. In this section, we describe the categories of information we collect and the sources of this information.

Information You Provide to Us

We collect information you provide directly to us when you submit information through our contact form, create an account (if applicable), request customer support, etc. This type of information includes identifiers such as your name, email address, phone number and the like.

Information We Collect Automatically

We also automatically collect certain information about your interactions with us or our Services, including:

• Device and Internet Activity Information: We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We collect information about your activity on our Services, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services.
• Information Collected by Cookies and Similar Tracking Technologies: We and our partners use tracking technologies, such as cookies, pixels, and SDKs (collectively, "Cookies"), to collect information about your interactions with the Services. A “cookie” is a small text file that is placed on the hard disk of your computer by a web-page server and contains non-personally identifying information about you. The purpose of a cookie is to tell the web server that you have accessed a specific page on our Site, so that when you visit the site again, your experience can be personalized. Cookies help us improve our Services and your experience, see which areas and features of our Services are popular, etc. We use essential Cookies to operate the Services, and also those which facilitate analytic observations (those that help us measure and analyze performance, and improve our Services) and targeted advertising. This site also uses tracking technologies such as the Common ID cookie to provide its services. The Common ID cookie stores a unique user id in the first party domain and is accessible to our ad partners. This simple ID can be utilized to improve user matching, especially for delivering ads to iOS and MacOS browsers. Users can opt out of this tracking by contacting AskSangogbemi@Gmail.com. While you do have the ability to accept or decline Cookies, the latter could affect the availability and functionality of our Services to you. For EU users only: When you use our Site, pre-selected companies may access and use certain information on your device and about your interests to serve ads or personalized content. You may revisit or change consent-choices at any time by contacting us at AskSangogbemi@Gmail.com.

Information We Derive

We may also derive information or draw inferences about you based on the information we collect. For example, we may make inferences about offers you would like to receive based on your Site interactions.

2. USE OF INFORMATION

We use information we collect for the following business and commercial purposes:

• Service delivery, including to provide and maintain our Services and authenticate your account (if applicable);
• Personalization, including to provide content recommendations;
• Communication, including to send support messages and other transactional correspondence;
• Marketing and Advertising, including to send direct marketing messages, targeted advertising and presenting sponsored content recommendations through the Services;
• Conducting Analytics, including to monitor/analyze trends, usage, and activities in connection with our Services, optimizing features we offer, and generating de-identified data that we will not attempt to re-identify;
• Protection and Compliance, including to detect, investigate, and help prevent security incidents and other malicious, fraudulent, or illegal activity, helping protect our rights and complying with our legal/financial obligations.

3. DISCLOSURES OF INFORMATION

We disclose the categories of personal information we collect as follows:

• Vendors: we disclose personal information to companies that need this information to provide services to us, such as companies that assist us with web hosting, fraud prevention, customer service, analytics, and marketing and advertising.
• Legal Authorities: we may disclose personal information for the protection and compliance purposes, including if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements, if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of us, our users, the public, or others.
• Professional Advisors: we disclose personal information to our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
• Corporate Transactions: we reserve the right to disclose personal information in connection with, or during negotiations of certain corporate transactions, including the merger, sale of company assets, financing, or our acquisition.
• Affiliates: we reserve the right to disclose personal information between and among our current or future parents, affiliates, subsidiaries, and other companies under common control and ownership.
• Consent: we may disclose personal information, when we have your consent or you direct us to do so.

You acknowledge that if you provide a review or post content on our Services, the public/other users of our Services will be able to see any information included in what you post and that we are not responsible for use others make of the same.

4. TRANSFER OF INFORMATION

We are headquartered in the United States and may work with those domestically and internationally in the course of providing our Services. Therefore, we and those that perform work for us may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. In the event that advertising on our Site becomes managed by a third-party, your information as it relates thereto may also become subject to the policies of said third-party. 

5. DATA RETENTION

There are many factors that we use to determine how long personal information is retained, such as: the purposes for which the information was collected, your marketing preferences and the way you engage with our brands, legal or regulatory requirements that apply to the information, and the relevance of such information to our own protection/rights. Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee “perfect security” regarding our data retention. In addition, information you send to us may not be secure while in transit. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us.

6. CHILDREN’S DATA

The Services are not intended to be used by children and we do not knowingly collect any personal information about children. If you are the parent or guardian of a child who has provided us with their personal information, you may contact us using the contact details set out below to request that it be deleted. As of the date of this Privacy Policy, we do not have actual knowledge of “sharing” or “selling” (as those terms are defined in applicable law) personal information of individuals under 16 years of age.

7. YOUR PRIVACY RIGHTS AND CHOICES

Access, Correction, and Deletion

Depending on where you reside, you may have the right to request to know more about and access your personal information, and request deletion or correction of the same. Please contact us regarding any of the aforementioned- we will not discriminate against you for exercising your rights. We may verify your request by asking you to provide further information, and if we deny your request, you may appeal our decision by contacting us further or contacting a local attorney.

Communications Preferences

You may opt out of receiving promotional emails from us by following the instructions in those communications or the settings. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

California and Colorado Residents 

This section provides additional disclosures required by California and Colorado law. The table below lists the categories of information we collect, the business/commercial purpose of processing, and the categories of recipients. Earlier sections of this Privacy Policy describe in more detail how we collect, use, and disclose personal information.

California and Colorado residents have the rights to request to know more about/access, correct, and delete their personal information as described above. California residents can also submit a rights request as an authorized agent. In that case, the agent must submit proof of authorization to make the request. Please do not provide sensitive personal information in connection with this request, such as a driver's license or other government-issued ID. We may be required to contact the individual who is the subject of the request to verify identity or confirm your permission to submit this request. 

Connecticut and Virginia Residents

This section applies to Connecticut and Virginia residents and supplements our Privacy Policy. If you are a Connecticut, or Virginia resident, you have the right to request access to, or request the correction or deletion of your personal information; and, to opt out of the processing of your personal information for targeted advertising purposes or the sale of your personal information. 

You can exercise your rights by contacting MEpsteinLaw@Gmail.com. Before processing your request, we will take reasonable steps to verify your identity. To ensure you are the owner of the relevant email address, you must respond to a confirmation email that we will send to the email address. In some cases, we may ask that you provide additional information to verify your identity. You may appeal our decision with respect to a request you have submitted by contacting us at the below email. You may also opt-out of the processing of your personal information for targeting advertising purposes or the sale of your personal information by requesting the same using the email address provided. 

Utah Residents

This section applies solely to Utah residents and supplements our Privacy Policy. If you are a Utah resident, you have the right to request access to, or request the correction or deletion of your personal information; or, to opt out of the processing of your personal information for targeted advertising purposes or the sale of your personal information. 

You can exercise your rights by contacting MEpsteinLaw@Gmail.com. Before processing your request, we will take reasonable steps to verify your identity. To ensure you are the owner of the relevant email address, you must respond to a confirmation email that we will send to the email address. In some cases, we may ask that you provide additional information to verify your identity. You may appeal our decision with respect to a request you have submitted by contacting us at the provided email. You may also opt-out of the processing of your personal information for targeting advertising purposes or the sale of your personal information by requesting the same using the email address provided. 

Individuals in Europe 

The following applies to those located in the European Economic Area ("EEA"), the United Kingdom, or Switzerland.

Your Data Protection Rights Under the General Data Protection Regulation (GDPR)

Our Site is based in the United States. We make no claims that the Site or any of its content is accessible or appropriate outside of the United States. If you access the Site from outside the United States, you do so on your own initiative and are responsible for compliance with local laws. As a courtesy to Site users that are EEA residents, we ensure compliance with the requirements thereof. We take reasonable steps to allow you to correct, amend, delete or limit the use of your personal information. If you wish to be informed regarding personal information retention or have requests regarding the same, contact us at MEpsteinLaw@Gmail.com. This paragraph also applies to all policy under every GDPR-related subheading below.  

In certain circumstances, you have the right to:

• Access, update or delete your information;
• Rectify your information if that information is inaccurate or incomplete;
• Object to our processing of your personal information;
• Request that we restrict the processing of your personal information.
• Be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format;
• Withdraw your consent at any time where we previously relied on your consent to process your personal information.

Site users who reside in the EEA have the right to object our processing their personal information based on legitimate interests, direct marketing, and- in some cases- scientific, historical and statistical research. Upon objection pursuant to legitimate interests, we shall cease unless we can demonstrate legitimate grounds that overrides user interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims. Where a user objects in connection with our direct marketing practices, we shall cease such processing immediately. Where a user objects in connection with our research and statistical analysis, the user must, under the GDPR, “demonstrate grounds relating to his or her particular situation”. We are not required to comply if our research is necessary for the performance of a task carried out for reasons of public interest.

Data Subject Requests

Site users who reside in the EEA may make subject access requests (“SARs”) to find out more about personal information which we hold about them, in addition to how/why such information is used. Users wishing to make a SAR may do so in writing, via email, to MEpsteinLaw@Gmail.com. Responses to SARs shall normally issue within one month of receipt, however this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If additional time is required, the user shall be informed. We reserve the right to charge reasonable fees for additional copies of information already supplied, and requests that are manifestly unfounded or excessive, particularly where repetitive. We may ask you to verify your identity before we respond. 

Data Breach Notification as Per the GDPR

All personal information breaches must be reported immediately to our data protection officer via email to MEpsteinLaw@Gmail.com. If a personal information breach occurs which is likely to result in a risk to the rights and freedoms of users (e.g. financial loss, breach of confidentiality, discrimination, or other significant social or economic damage), the data protection officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it. In the event that a personal information breach is likely to result in a high risk to the rights and freedoms of users, the data protection officer must ensure that all affected users are informed of the breach directly and without undue delay. Data breach notifications shall include the following information: (i) categories and approximate number of users concerned; (ii) categories and approximate number of personal information records concerned; (iii) the name and contact details of our data protection officer (or other contact point from whom more information can be obtained); (iv) the likely consequences of the breach; and, (v) the details of the measures taken, or proposed to be taken, to address the breach.

Lawful, Fair, and Transparent Data Processing as Per the GDPR

The GDPR seeks to ensure that personal information is processed lawfully, fairly, and transparently, without adversely affecting the rights of the user, and that all such processing shall be lawful if at least one of the following applies:

• The user has given consent to the processing of their personal information for one or more specific purposes;
• The processing is necessary for the performance of a contract to which the user is a party, or in order to take steps at the request of the user prior to entering into a contract with them;
• The processing is necessary for compliance with a legal obligation to which the data controller is subject;
• The processing is necessary to protect the vital interests of the user or of another natural person;
• The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or,
• The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the user which require protection of personal information, in particular where the user is a child.

If the personal information in question is “special category data” (also known as “sensitive personal information”) (for example, data concerning the user’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation), at least one of the following conditions must be met:

• The user has given their explicit consent to the processing of such data for one or more specified purposes (unless EU or EU Member State law prohibits them from doing so);
• The processing is necessary for carrying out the obligations and exercising specific rights of the data controller or of the user in the field of employment, social security, and social protection law (insofar as it is authorized by EU or EU Member State law or a collective agreement pursuant to EU Member State law which provides for appropriate safeguards for the fundamental rights and interests of the user);
• The processing is necessary to protect the vital interests of the user or of another natural person where the user is physically or legally incapable of giving consent;
• The data controller is a foundation, association, or other non-profit body with a political, philosophical, religious, or trade union aim, and the processing is carried out in the course of its legitimate activities, provided that the processing relates solely to the members or former members of that body or to persons who have regular contact with it in connection with its purposes and that the personal information is not disclosed outside the body without the consent of the users.
• The processing relates to personal information which is clearly made public by the user;
• The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;
• The processing is necessary for substantial public interest reasons, on the basis of EU or EU Member State law which shall be proportionate to the aim pursued, shall respect the essence of the right to data protection, and shall provide for suitable and specific measures to safeguard the fundamental rights and interests of the user;
• The processing is necessary for the purposes of preventative or occupational medicine, for the assessment of the working capacity of an employee, for medical diagnosis, for the provision of health or social care or treatment, or the management of health or social care systems or services on the basis of EU or EU Member State law or pursuant to a contract with a health professional, subject to the conditions and safeguards referred to in Article 9(3) of the GDPR;
• The processing is necessary for public interest reasons in the area of public health, for example, protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of EU or EU Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the user (in particular, professional secrecy); or,
• The processing is necessary for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) of the GDPR based on EU or EU Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection, and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the user.

Erasure of User Personal Information as per the GDPR 

Users have the right to request that we erase their personal information the following circumstances:

• It is no longer necessary for us to hold said information in connection with the purpose(s) for which it was originally collected or processed;
• The user wishes to withdraw their consent to our holding and processing their personal information;
• The user objects to our holding and processing their personal information and there is no overriding legitimate interest to allows us to continue doing so;
• The personal information has been processed unlawfully; or,
• The personal information needs to be erased in order for us to comply with a particular legal obligation.

Unless we have reasonable grounds to refuse to erase personal information, all requests for erasure shall be complied with, and the user shall be informed of the erasure, within one month of receipt of the user’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the user shall be informed. In the event that any personal information that is to be erased in response to a user’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).

Rectification of User Data as per the GDPR

You have the right to request that we rectify the personal information held about you if said information is inaccurate or incomplete. We shall rectify the same and inform you of that rectification within one month of your request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, you shall be informed. In the event that any affected Personal Information has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal information.

If you have a concern about our processing of personal information that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en

For individuals in the UK: https://ico.org.uk/global/contact-us/

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

8. CONTACT US

If you have any questions about this Privacy Policy, please contact us at MEpsteinLaw@Gmail.com.