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Privacy policy

Effective date: March 30, 2022

At Citizens Reserve, Inc. dba/ “Suku”, we respect your privacy and are committed to protecting it.

This privacy notice has been drafted to explain how Suku collects, uses, discloses, and protects information that we collect about you and your rights concerning that information.
This notice covers information we collect from or about you when you give it to us, use our Platform through our website, or interact with our advertisements. It also covers information that we may receive from other persons or companies who have received your information and can share it with us.
If, in any case, our privacy practices differ from those explained in this notice, we will let you know at the time we ask for or collect your information.

Content

• What information we collect about you

• Children’s online privacy

• How we collect your information

• Cookies and automatic data collection technologies

• How we use your information

• Disclosure of your information

• Interest-based advertising

• Third-party content, apps, and links

• Your rights and choices

• Data security

• Your California privacy rights

• Nevada privacy

• Canada privacy

• Changes to our privacy notice

• Contact us

WHAT INFORMATION WE COLLECT

We may collect the following types of information about you, which we have grouped together as follows:

• Identity Information. Examples include first name, last name, marital status, title, date of birth and gender.

• Contact Information. Examples include billing address, shipping address, email address and telephone numbers.

• Financial Information. Examples include payment card details, purchase transaction details, and Suku platform transaction details.

• Transaction Information. Examples include details about payments to and from you and other details of products and services you have purchased from us.

• Technical Information. Examples include internet protocol (IP) address, your login information, 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 the Platform.

• Profile Information. Examples include your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.

• Usage Information. Examples include information about how you use the Platform, products and services.

• Marketing and Communications Information. Examples include your preferences in receiving marketing from us and our third parties and your communication preferences.

• Demographic Information and Preferences. Examples include personal characteristics and preferences, such as your age, marital and family status, number of children, shopping preferences, income level, languages spoken, loyalty and rewards program information, household demographic data, data from social media platforms, education and professional information, hobbies and interests and propensity scores from third parties (likelihood of purchase, experiencing a life event, etc.).

• User Content. Examples include photos, reviews, and other feedback that you provide to us on or through the Platform about our products and services. If you choose to provide User Content, it may be made available on public areas of our website or on or through our social media channels.

Some of the information we collect about you may be personal information, or personal data, that can be used to identify you including, for example, your name, email address, mailing address or delivery address. In some jurisdictions, certain unique identifiers like IP addresses and other usage or technical information may be considered personal information. Personal information does not include data where your identity has been removed so that we can no longer identify you (anonymous data), which we may use for any purpose.

CHILDREN’S ONLINE PRIVACY

The Platform is not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on the Platform. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on the Platform or through any of its features, use any of the interactive or public comment features of the Platform, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at support@suku.world.

HOW WE COLLECT YOUR INFORMATION

We collect information from and about you in the following ways:

When you provide it to us. You may give us information about you by filling in forms or by communicating with us by email or otherwise. This includes information you provide when you register for an account, subscribe to one of our communications, enroll in a loyalty program, place an order, participate in one of our events, write a review, or when you otherwise contact us about our Platform, products, or services.

From our Platform and emails. As you interact with our Platform and use our cookies, or our emails, we may automatically collect Technical Information about your equipment, browsing actions and patterns. We collect this information by using cookies, server logs, web beacons, and other similar technologies. Our Cookies and automatic data collection technologies section contains more information and options to control or opt-out of certain data collection or uses

From others. We may receive information about you from third parties including, for example, our affiliated companies, business partners, subcontractors, analytics providers, and service providers. We may also receive information about you from commercially available sources such as data aggregators and public databases.

COOKIES AND AUTOMATIC DATA COLLECTION TECHNOLOGIES

The Platform uses automatic data collection technologies to distinguish you from other Platform users. This helps us deliver a better and more personalized service when you use the Platform. It also allows us to improve the Platform by enabling us to:

• Estimate our audience size and usage patterns.

• Store your preferences so we may customize the Platform according to your individual interests.

• Speed up your searches.

• Recognize you when you return to the Platform.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). For more information, see the Interest-based advertising section of this privacy notice.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. For information about managing browser settings to refuse cookies, see Your rights and choices.

• Flash Cookies. Certain features of the Platform may use Flash cookies (local stored objects) instead of browser cookies to collect and store information about your preferences and navigation to, from, and on the Platform. For information about managing Flash cookies, see Your rights and choices.

• Web Beacons. Our website pages, advertisements, and e-mails may contain small transparent embedded images or objects known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count website page visitors or email readers, or to compile other similar statistics such as recording website content popularity or verifying system and server integrity. For information about managing web beacons, see Your rights and choices.

We may use Google Analytics to provide certain analytics services for us. More information about Google Analytics can be found in the Google Analytics Terms of Use and the Google Analytics Privacy Policy We do not respond to or honor “do not track” (a/k/a DNT) signals or similar mechanisms transmitted by web browsers.

HOW WE USE YOUR INFORMATION

We may use your information to conduct our business operations, including for the following purposes:

• To create and manage your account.

• To provide you with products and services you request or purchase from us.

• To allow you to enter a sweepstake, contest, promotion, other programs that we may offer.

• To conduct market research.

• To develop and provide advertising tailored to your interest and to determine the effectiveness of our advertising.

• To provide you with the information or support that you request from us, including to send you newsletters.

• To improve the Platform, products or services, marketing, customer relationships, and experiences.

• To develop new products and services.

• To notify you of special offers, discounts, updates, and products and services that we think may interest you. To learn more about your choices about these communications, see Your rights and choices.

• To manage our relationship with you which may include notifying you about changes to our terms or privacy notice, providing you notices about your account, asking you to leave a review or take a survey, and addressing any concerns you may have about our products or services.

• To provide you with the information, products, services, or support that you request from us or to fulfill any other purpose for which you provide it.

• To deliver relevant content, advertisements, and messages to you and to measure or understand the effectiveness of such content, advertisements, and messaging.

• To make suggestions and recommendations to you about our own and third parties’ products or services that may be of interest to you. If you do not want us to use your information in this way or for more information on how to adjust your preferences, see Your Rights and Choices.

• To carry out our obligations and enforce our rights and to protect the Platform, our customers, and other individuals including to protect against or identify possible fraudulent transactions.

• For any other purpose as may be permitted by law or that we describe when you provide the information.

We may use information that is not personal information for any purpose. For example, we may aggregate usage data from many people in a way that does not identify any individuals to calculate the percentage of users accessing a feature on the Platform.

DISCLOSURE OF YOUR INFORMATION

We may share non-personal information without restriction. We may share your personal information with:

• Any member of our corporate group, which means our subsidiaries, affiliates, our ultimate holding company and its subsidiaries, and affiliates.

• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

• To our business partners who provide services on our behalf but who may also use the information we provide for their own commercial purposes. For example, some of our advertising partners may use information to market other parties’ products and service to you. For more information see Interest-based advertising.

• To public or government (including enforcement) authorities.

• To an actual or prospective buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, where one of the transferred assets is the personal information we hold.

• If we offer a co-branded promotion, to our co-sponsor.

• To fulfill the purpose for which you provide it.

• For any other purpose as may be permitted by law or that we describe when you provide the information.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including responding to any government or regulatory request.

• To enforce our Terms of Use and other agreements with you.

• To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection and credit risk reduction.

• To investigate suspected violations of any law, rule, or regulation, or the terms or policies for the Platform.

We may also use your information to contact you about our own and third parties’ products and services that may interest you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile or opt out as directed when you receive such an email from us. For more information, see Your rights and choices.

INTEREST-BASED ADVERTISING

Some content or applications on the Platform, including advertisements, are served by third parties, including advertisers, ad networks, servers, content partners, or application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Platform. The information they collect may be associated with your personal information, or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. Our partners may use non-cookie technologies on which browser settings that block cookies might have no effect. Your browser may not permit you to block such technologies.

For this reason, keep in mind that you can block the collection and use of information related to you by advertising companies to serve interest-based advertising by visiting the following self-regulatory programs of which those companies are members:

• The NAI’s opt-out platform is available here

• The DAA’s opt-out platform is available here

• Third Party Content, Apps, and Links.

Some content or applications on our websites may be served by third parties, content providers, and application providers, including the following:

• Plugins. The Platform may make available the option for you to use “plugins” that are operated by other companies. If you choose to use one of these plugins, then it may collect information about you and send it back to the company that owns it. This may happen even if you do not click on the plugin, if you are logged into the social media website that owns the plugin when you visit the Platform. Information collected by a plugin is subject to the privacy policy and terms of the company that makes it. If you do not want the company that owns a plugin to collect information about you when you visit the Platform, sign out of the company’s website before visiting. By interacting with a plugin when you are on the Platform (for example, clicking the Facebook “Like” button), you are intentionally transferring information to that company. Further, if you are logged into a company’s website when you visit the Platform, then you are directing us to share your data with the company that owns the plugin.

• User Content. The Platform may allow you to upload your own content to public areas of the Platform. Any information you submit becomes public information, and we do not control how others may use the content you submit. We are not responsible for uses that may violate our privacy notice, the law, or your intellectual property rights.

• Third-party links. The Platform may contain links to other sites, which we do not control. Those websites have their own privacy policies and terms.

YOUR RIGHTS AND CHOICES

Your rights may vary depending on where you are located. We have created mechanisms to provide you with the following control over your information.

• Marketing. If you do not want us to use your email address or other contact information to promote or recommend our own products and services, or third parties’ products or services, you can opt-out by checking the relevant box located on the form where we collect your contact information or, if presented with the option to opt-in, do not opt-in. If you have an account with the Platform, you may be able to log in and check or uncheck relevant boxes. If you do not have an account, you can adjust your preferences by contacting us as set forth below in the Contact Us section. You may also opt-out of further marketing communications by replying to any promotional email we have sent you or following the opt-out links on that message. This opt-out may not apply to information provided to us as a result of a product purchase, warranty registration, product service experience or other transactions.

• Accessing, Updating and Deleting Your Information. If you have an account with us, you may have the ability to access your information and make updates to or delete your data. If not, you can contact us as set forth in the Contact Us section below to request access to, correction of, or deletion of personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or negatively affect the information’s accuracy.

• Cookies and Automatic Data Collection Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Flash cookies are not managed by the same browser settings as are used for browser cookies. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website . However, if you disable or refuse cookies, please note that some parts of the Platform may become inaccessible or not function properly. If you do not want Google Analytics to be used in your browser, Google Analytics provides an opt-out tool which can be found here . In some cases, you may be able to set your browser or email program to not download web beacons.

• Interest Based Advertising Please see Interest-based advertising above for information on how to opt-out of interest-based advertising.

• California Residents If you are a California resident, you may have additional rights and choices with regard to your personal information. Please see Your California privacy rights for more information.

• Nevada Residents If you are a Nevada resident, please see our Nevada privacy section below for more information our information practices.

DATA SECURITY

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Platform. Any transmission of personal information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Platform.

YOUR CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act of 2018 (“CCPA”) The requires us to provide the following notice to California residents. This notice does not apply to employment-related information of California-based employees, job applicants, contractors, or similar individuals. Where noted in this notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B information”) from some of its requirements.

Information we collect

The information we have collected about California residents in the last 12 months is described in What information we collect above. That information corresponds with the following categories of personal information under the CCPA:

A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. YES
Category Examples Collected
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. NO
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). NO
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. YES
G. Geolocation data. Physical location or movements. NO
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information. Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other personal information. ; Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO


In the last 12 months, we have collected personal information from the sources described in How we collect your information above.

Use of personal information

In the last 12 months, we have used your personal information for the business and commercial purposes described in How we use your information above.

Sharing of personal information

The business and commercial purposes that we have shared your personal information in the last 12 months are described above in Disclosure of your information. More specific information on that sharing is as follows:

Sharing your personal information for business purposes. We have shared the following categories of personal information with our affiliated companies, service providers and public or government (including enforcement) authorities for our business purposes:

Category A: Identifiers. We are collecting your email address as a unique identifier for your unique log-in. The email address may be used to send you information about upcoming or other activity on the platform.

Category F: Internet or other similar network activity. Each of your transactions are recorded on the platform, and each transaction can be viewed by other platform users. Additionally, the transaction information is being recorded on a distributed ledger, which is publically available.

As described above, examples of business purposes include performing transactions, registering accounts, managing our relationship with you, and monitoring for security threats and fraud.

Sharing your personal information for commercial or other purposes: We have not shared any of your personal information with business partners and other third parties in a manner that is likely to be considered to be a “sale” under the CCPA.

As described above, this information may be shared for personalization, analytics, marketing, retargeting, and sales. We do not sell the personal information of consumers who are younger than 18 years of age.

Your right to know

You have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your personal information over the past 12 months. Once we verify your request, we will disclose to you:

• The categories of personal information we collected about you.

• The categories of sources for the personal information we collected about you.

• Our business or commercial purpose for collecting or selling that personal information.

• The categories of third parties with whom we share that personal information.

• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

We do not provide access rights to B2B information.

Your right to obtain a copy of your personal information

At CRI’s sole discretion, it may require you to submit any disputes arising from the use of these Terms or the Services, including disputes arising from or concerning their interpretation, violation, invalidity, non-performance, or termination, to final and binding arbitration under the Rules of Arbitration of the American Arbitration Association applying the laws of the State of California.

You further agree that you will resolve any disputes on an individual basis, and that any claims brought under these Terms or in connection with the Services must be brought in your individual capacity, and not as a plaintiff or class member in any purported class, collective, or representative proceeding. You further agree that you will not participate in any class action (existing or future) brought by any third party arising under these Terms or in connection with the Services. If any court or arbitrator determines that the class action waiver set forth in this paragraph is void or unenforceable for any reason or that an arbitration can proceed on a class basis, then such class action is not subject to arbitration and must be litigated in state or federal court in Santa Clara County in the State of California.

Limitation on Time to File Claims

You have a right to obtain a copy of the specific pieces of personal information we collected about you (also called a data portability request). Once we verify your request, we will provide you a copy of your personal information that is responsive to your request. We do not provide portability rights to B2B information.

Your right to delete your personal information

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we verify your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We do not provide deletion rights to B2B information.

Your right to opt-out of sale of your information

We may share information with third parties in a way that is considered a “sale” under the CCPA. Where that is the case, we will comply with California “Do Not Sell” requirements.

How to exercise your CCPA rights

To exercise your right to know, right to obtain a copy, or right to delete your personal information as described above, please submit your request to us by either: Contacting us at support@suku.world.

To exercise the right to opt out of sale of your personal information, you can submit a request to us by visiting the following link: Do Not Sell My Personal Information

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by visiting the following link: Opt-in to Sales of My Personal Information

How we verify requests and respond to requests

Before fulfilling your request, we take steps to verify you are who you say you are or that you have authority to act upon someone else’s behalf. Therefore, upon receipt of your request, we will request additional information that we need to verify you and, if you are submitting a request on behalf of someone else, to verify that you are permitted to act on that person’s behalf.

When we contact you to request verification information, please respond and provide the information that we have requested. Depending on the nature of the request you make, we may require you to verify your identity to either a reasonable degree of certainty or high degree of certainty. This may mean that we need to match two or three pieces of information that we hold about you with the information you provide. In some cases, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request or that you are authorized to make the request on behalf of someone else.

In addition to providing the information we need to verify you or your authority, you must provide us with enough information to understand, evaluate, and respond to your request. We cannot respond to your request or provide you with personal information if we cannot confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify your identity or authority to make the request and to locate relevant information. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and to understand, evaluate, and respond to your request. We cannot delete personal information in those situations where our retention is required for our own internal business purposes or otherwise permitted by the CCPA (such as fraud prevention or legal compliance). In these situations, we will retain your information in accordance with our records retention program and securely delete it at the end of the retention period.

Who may submit requests?

Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may also make request on behalf of your minor child. You may designate an authorized agent to make a request on your behalf by registering such person or entity with the California Secretary of State.

How often you can submit requests?

You may make a CCPA consumer request twice within a 12-month period.

Response timing and format

We make every attempt to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. When you request a copy of your personal information, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity easily.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-discrimination

We will not discriminate against you for exercising any of your CCPA rights. You have a right not to receive discriminatory treatment by us for exercising your privacy rights.

Other California privacy rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@suku.world.

NEVADA PRIVACY RIGHTS Nevada residents have the right to opt out of the sale of certain “covered information” collected by operators of websites or online services. We currently do not sell covered information, as “sale” is defined by such law, and we do not have plans to sell this information.

14. GDPR privacy rights This GDPR Privacy Notice is a supplement to our Privacy Policy and concerns certain personal data we have collected about residents of the countries in the European Union, consisting of the European Economic Area, Switzerland, and to the extent that the United Kingdom is no longer a member of the European Union, the United Kingdom (the “EU” or the “European Union”). It explains why we have that information, how we use and handle it, and your rights to that information, all as required by the European Union’s General Data Protection Regulation (“GDPR”).

What personal data do we hold?

Data You Provide to Us. We may collect your personal contact information such as name, email address, phone number, and country of residence, and financial account information in order to process payment for your purchases.

Data from Others. We may receive personal data about you from our vendors or affiliates, such as your personal contact information (name, home or business address, email address, phone number, and country of residence), in the context of providing to servicing and support to our customers.

Where did we get your personal data?

We collect your personal data when you ask us to contact you or when you place an order for our products and services. Your failure to provide this information means we cannot fulfill your request. We may also collect your contact information when you provide it by using our Website, as well as your IP address and other information about your activity on our Website, such as what pages you visit. We may also receive personal data when we are working on the resolution of our customer's problems.

What is our purpose for holding your personal data?

Our lawful basis for holding your information depends on the circumstances under which we acquired it:

Type of Information Lawful Basis for Processing
Customer and prospective customer contact information collected in connection with an order or an inquiry For fulfillment of a contract
Customer and prospective customer contact information collected for use in marketing additional products and services Consent or Legitimate Interest
Personal data of our customers’ customers collected for use in filling orders for our products and services For fulfillment of a contract

What we do with your personal data.

We use your details so that we can communicate with you by email or phone and inform you of our services, the status of your order, or questions about payment of your invoice. We may also collect your IP address and details concerning your activity while on our Website in order to understand your interests and preferences. The personal data we hold is stored and processed securely in line with the information security measures and guidance standard in our industry. We have implemented appropriate technical and organizational measures designed to prevent the unauthorized disclosure of your personal data, taking into account the level of risk associated with the processing of your personal data. If we receive your personal data in the context of providing problem solving services to our customers, we will securely accept that data, segregate it from other customer data, and limit access to the data. We will delete the data once the issue is resolved.

Cross Border personal data transfers.

Your personal data may be transferred to and stored at our servers located in the United States. The United States has personal data privacy laws that are different from your country. While the United States has not received an adequacy decision from the European Union Commission, we will ensure that it is protected in a manner that is consistent with how your personal data is protected if it was processed in your country. What we don’t do with your personal data.

We do not pass your information to anyone else apart from our business services partners as necessary to provide you with the products and services you have requested. We do not use any automated systems relating to your personal data. We do not use your information for profiling.

How long do we keep your personal data?

We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law or we have obtained your consent.

What are my personal data rights?

You have the following rights concerning your personal data that we hold and process that you can exercise at any time:



• To create and manage your account.

• To provide you with products and services you request or purchase from us.

• To allow you to enter a sweepstake, contest, promotion, other programs that we may offer.

• To conduct market research.

• To develop and provide advertising tailored to your interest and to determine the effectiveness of our advertising.

• To provide you with the information or support that you request from us, including to send you newsletters.

• To improve the Platform, products or services, marketing, customer relationships, and experiences.

• To develop new products and services.

• To notify you of special offers, discounts, updates, and products and services that we think may interest you. To learn more about your choices about these communications, see Your rights and choices.

• To manage our relationship with you which may include notifying you about changes to our terms or privacy notice, providing you notices about your account, asking you to leave a review or take a survey, and addressing any concerns you may have about our products or services.

• To provide you with the information, products, services, or support that you request from us or to fulfill any other purpose for which you provide it.

• To deliver relevant content, advertisements, and messages to you and to measure or understand the effectiveness of such content, advertisements, and messaging.

• To make suggestions and recommendations to you about our own and third parties’ products or services that may be of interest to you. If you do not want us to use your information in this way or for more information on how to adjust your preferences, see Your Rights and Choices.

• To carry out our obligations and enforce our rights and to protect the Platform, our customers, and other individuals including to protect against or identify possible fraudulent transactions.

• For any other purpose as may be permitted by law or that we describe when you provide the information.

We may use information that is not personal information for any purpose. For example, we may aggregate usage data from many people in a way that does not identify any individuals to calculate the percentage of users accessing a feature on the Platform.

DISCLOSURE OF YOUR INFORMATION

We may share non-personal information without restriction. We may share your personal information with:

• Right of access – you have the right to request a copy of the information that we hold about you.

•Right of rectification – you have a right to correct personal data that we hold about you that is inaccurate or incomplete.

• Right to be forgotten – in certain circumstances, you can ask for the personal data we hold about you to be erased from our records.

• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.

• Right of portability – you have the right to have the personal data we hold about you transferred to another organization.

• Right to object – you have the right to object to certain types of processing, such as direct marketing.

• Right to judicial review – in the event that we refuse your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in the process below.

All of the above requests will be forwarded to other parties holding and processing your personal data where appropriate.

Who do I contact if I have an issue with my personal data that you hold?

Please contact our Privacy Officer at [support@suku.world].

How do I make a complaint about how my personal data is being held or processed?

If you wish to raise a complaint on how we handle your personal data, you can contact our Privacy Officer as follows:

By Email: support@suku.world

By Mail: 2840 Blake St., Apt 540, Denver, CO, 80205, US

Attention: Privacy Officer

CHANGES TO OUR PRIVACY NOTICE

We will post any changes we may make to our privacy notice on this page. If the changes materially alter how we use or treat your information, we will notify you by email to the primary email address specified in your account (if you have an account with us), and/or through a notice on the Platform. The date the privacy notice was last revised is identified at the top of the page. You are responsible for ensuring that we have an up-to-date email address for you and for periodically visiting the Platform and this page to check for any changes.

CONTACT US

If you have any comments or questions about our privacy notice, please use our Help page to reach out to us at (650) 838-4434