The Privacy Policy of Sgioba

1. Introduction

Thanks for choosing Sgioba!

At Sgioba, we want to give you the best possible experience to ensure that you enjoy our service today, tomorrow, and in the future. To do this we need to understand your listening habits so we can deliver an exceptional and personalized service specifically for you. That said, your privacy and the security of your personal data is, and will always be, enormously important to us. So, we want to transparently explain how and why we gather, store and use your personal data - as well as outline the controls and choices you have around when and how you choose to share your personal data.

That is our objective, and this Privacy Policy (“Policy”) will explain exactly what we mean in further detail below.

2. About this Policy

This Policy sets out the essential details relating to your personal data relationship with Sgioba. The Policy applies to all Sgioba services. The terms governing your use of the Sgioba Service are defined in our Terms and Conditions of Use (the “Terms and Conditions of Use”).

From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any change to the way we collect or process your personal data we will provide you with more information and additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy.

The aim of this Policy is to:

Ensure that you understand what personal data we collect about you, the reasons why we collect and use it;
Explain the way we use the personal data that you share with us in order to give you a great experience when you are using the Sgioba Service; and
Explain your rights and choices in relation to the personal data we collect about you and how we will protect your privacy.

We hope this helps you to understand our privacy commitments to you. For further clarification of the terms used in this Policy please visit our Privacy Center on spotify.com. For information on how to contact us if you ever have any questions or concerns, please see the ‘How to Contact Us’ Section 14 below. Alternatively, if you do not agree with the content of this Policy, then please remember it is your choice whether you want to use the Sgioba Service.

3. Your rights and your preferences: Giving you choice and control

You may be aware that a new European Union law, called the General Data Protection Regulation or "GDPR" gives certain rights to individuals in relation to their personal data. Accordingly, we have implemented additional transparency and access controls in our Privacy Center and Privacy Settings to help users take advantage of those rights. As available and except as limited under applicable law, the rights afforded to individuals are:

Right of Access - the right to be informed of and request access to the personal data we process about you;
Right to Rectification - the right to request that we amend or update your personal data where it is inaccurate or incomplete;
Right to Erasure - the right to request that we delete your personal data;
Right to Restrict - the right to request that we temporarily or permanently stop processing all or some of your personal data;
Right to Object -
- the right, at any time, to object to us processing your personal data on grounds relating to your particular situation;
- the right to object to your personal data being processed for direct marketing purposes;
Right to Data Portability - the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
Right not to be subject to Automated Decision-making - the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

In order to enable you to exercise these rights with ease and to record your preferences in relation to how Sgioba uses your personal data, we provide you with access to all the data we have about you in the My Details section of the Sgioba counselling application.

Sgioba will only contact you, using email. Any contact will be in direct reference to the counselling application service and will never be by third party organisations. We hold you and your user data in complete confidence and do not do any processing or manipulation of this data.

If you have any questions about your privacy, your rights, or how to exercise them, please contact our Data Protection Officer using the ‘Contact Us’ form on the Privacy Center. We will respond to your request within a reasonable period of time upon verification of your identity. If you are unhappy with the way we are using your personal data you can also contact and are free to lodge a complaint with your local Data Protection Authority.

4. How do we collect your personal data?

We collect your personal data in the following ways:

When you sign up for the Sgioba Service - when you sign up to the Sgioba Service, we collect certain personal data so you can use the Sgioba Service such as your email address and mobile phone number.

Through your use of the Sgioba Service - when you use the Sgioba Service, we collect usage data on how you are using the application and how often.

Personal data collected that enables us to provide you with additional features/functionality - from time to time, you also may provide us with additional personal data or give us your permission to collect additional personal data e.g. to provide you with more features or functionality. As described further below, we will not, precise mobile device location, voice data, or contacts from your device without your prior consent. You always will have the option to change your mind and withdraw your consent at any time.

From third parties - we do not receive or give/offer personal data about you and your activity to/from third parties, there are no tracking cookies or advertisment systems in use within the Sgioba Application.

We use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, improving the Sgioba Service, and developing new features and functionality within the Sgioba Service.

5.What personal data do we collect from you?

We have set out in the tables below the categories of personal data we collect and use about you:

Personal data collected when you sign up for the Sgioba Service

Account Registration Data - This is the personal data that is provided by you or collected by us to enable you to sign up for and use the Sgioba Service. This includes your Business Name, your full name, email address and telephone number.

Some of the personal data we will ask you to provide is required in order to create your account. You also have the option to provide us with some additional personal data in order to make your account more personalized.

Personal data collected through your use of the Sgioba Service

Sgioba Service Usage Data - This is the personal data that is collected about you when you are using the Sgioba Service - this may include:

Information about your type of Sgioba Service plan.
Information about your interactions with the Sgioba Service which includes the date and time of any requests you make
User Content (as defined in the Terms and Conditions of Use) you post to the Sgioba Customer Service team.
Technical Data which may include URL information, cookie data, your IP address, the types of devices you are using to access or connect to the Sgioba Service, unique device IDs, device attributes, network connection type (e.g. WiFi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, information enabling digital rights management, operating system, and Sgioba application version. Further details about the technical data that is processed by us can be found in our Cookies Policy.
Motion-generated or orientation-generated mobile sensor data (e.g. accelerometer or gyroscope) required for the purposes of providing specific features of the Sgioba Service to you.

We will not access any of the personal data you record about any of your clients. We will never access this information. All client records and associated data is stored on your own individual database. This information is stored encrypted within the database. All databases are automatically backed up and the restore policy means that our staff cannot access your client data.

Payment Data - We may collect such personal data if you sign up for a Trial or purchase any of our Paid Subscriptions (as defined in the Terms and Conditions of Use). The exact personal data collected will vary depending on the payment method (e.g. direct via your mobile phone carrier or by invoice) but will include information such as:

        Name;
        Date of birth;
        Credit or debit card type, expiration date, and certain digits of your card number;
        Postal code;
        Mobile phone number; and
        Details of your transaction history.

If you choose to pay by invoice, we will provide your personal data to our payment processors to enable them to complete a credit check and to send you invoices.

Marketing Data - We do not collect any marketing data or pass your details on to third parties.

6. What do we use your personal data for?

When you use or interact with the Sgioba Service, we use a variety of technologies to process the personal data we collect about you for various reasons. We have set out in the table below the reasons why we process your personal data, the associated legal bases we rely upon to legally permit us to process your personal data, and the categories of personal data (identified in Section 5 ‘What personal data do we collect from you?’) used for these purposes:

To provide, personalise, and improve your experience with the Sgioba Service and other services and products provided by Sgioba.

        Performance of a Contract
        Legitimate Interest

        Account Registration Data
        Service Usage Data

To understand how you access and use the Sgioba Service to ensure technical functionality of the Sgioba Service, develop new products and services, and analyse your use of the Sgioba Service, including your interaction with the application and services that are made available.

        Performance of a Contract
        Legitimate Interest

        Account Registration Data
        Service Usage Data

To communicate with you for Sgioba Service-related purposes.

        Performance of a Contract
        Legitimate Interest

        Account Registration Data
        Service Usage Data

To process your payment to prevent or detect fraud including fraudulent payments and fraudulent use of the Sgioba Service.

        Performance of a Contract
        Compliance with legal obligations
        Legitimate Interest

        Payment Data

If you require further information about the balancing test that Sgioba has undertaken to justify its reliance on the legitimate interest legal basis under the GDPR, please see Section 14 ‘How to contact us’ for further details on how to contact us.

7. Sharing your personal data

We have set out the categories of recipients of the personal data collected or generated through your use of the Sgioba Service.
Service Providers and Others We use technical service providers which may operate the technical infrastructure that we need to provide the Sgioba Service, in particular providers which host, store, manage, and maintain the Sgioba application, its content and the data we process.

We use technical service providers to help us communicate with you, as described in Section 6 of this Policy.

Academic Researchers We will share your personal data for activities such as statistical analysis and academic study but only in a pseudonymised format.

We also will share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.

8. Data retention and deletion

We keep your personal data only as long as necessary to provide you with the Sgioba Service and for legitimate and essential business purposes, such as maintaining the performance of the Sgioba Service, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your personal data for as long as you are a user of the Sgioba Service

If you request, we will delete or anonymise your personal data so that it no longer identifies you, unless, we are legally allowed or required to maintain certain personal data, including situations such as the following:

If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
Where we are required to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.

9. Links

We may display links from third parties and other content that links to third-party websites. We cannot control or be held responsible for third parties’ privacy practices and content. If you click on a third-party link, please understand that you are leaving the Sgioba Service and any personal data you provide will not be covered by this Policy. Please read their privacy policies to find out how they collect and process your personal data.

10. Keeping your personal data safe

We are committed to protecting our users’ personal data. We implement appropriate technical and organisational measures to help protect the security of your personal data; however, please note that no system is ever completely secure. We have implemented various policies including pseudonymisation, encryption, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems.

Your password protects your user account, so we encourage you to use a unique and strong password, limit access to your computer and browser, and log out after having used the Sgioba Service.

12. Children

The Sgioba Service is not directed to persons under the age of 18 years.

We do not knowingly collect personal data from persons under 18 years or under the applicable age limit (the “Age Limit”). If you are under the Age Limit, please do not use the Sgioba Service, and do not provide any personal data to us.

If you are a parent of a child under the Age Limit and become aware that your child has provided personal data to Sgioba, please contact us using the ‘Contact Us’ form on the Privacy Center, and you may request exercise of your applicable rights detailed in the ‘Your rights and your preferences: Giving you choice and control’ Section 3 of this Policy.

If we learn that we have collected the personal data of a person under the age of 18 years, we will take reasonable steps to delete the personal data. This may require us to delete the Sgioba account for that person.

13. Changes to this Privacy Policy

We may occasionally make changes to this Policy.

When we make material changes to this Policy, we’ll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Sgioba Service or by sending you an email. We may notify you in advance.

Please, therefore, make sure you read any such notice carefully.

If you want to find out more about this Policy and how Sgioba uses your personal data, please visit the Privacy Center on spotify.com to find out more.

14. How to contact us

Thank you for reading our Privacy Policy. If you have any questions about this Policy, please contact our Data Protection Officer by using the ‘Contact Us’ form or by writing to us at the following address:

Sgioba International Ltd,
27 Ingram Street,
Glasgow
G1 1HA
Scotland

Registered Company No: SC660454

Sgioba is the data controller for the purposes of the personal data processed under this Policy.

We hope you enjoy Sgioba!