Last Updated: January 2023
This privacy notice (our “Policy“) describes how Sooggi Limited (a UK company) (“Sooggi” “we”, “our” or “us”) collects and processes your personal data. How we use your personal data will depend on the particular service we are providing and the nature of your relationship with us.
This Policy applies to all personal data we collect or process about you in the context of your use of our services. Sooggi is the data controller for the processing of personal data.
We may collect the following personal data from you:
Third-Party Accounts Data: Sooggi allows you to sign up and log in to the Sooggi Services using accounts that you have created with third-party products and services including Facebook, Google, or Apple (together “Third-Party Accounts”).
Where you access the Sooggi Services using Third-Party Accounts we will collect information that you have agreed to make available such as your name, email address, profile information and preferences (“Third-Party Accounts Data”).
This information is collected by the relevant Third-Party Account provider and is provided to us under their terms and policies. You may be able to control the information that we receive from these sources using the privacy settings in the relevant Third-Party Account.
We collect some of the personal data described above directly from you for a number of different purposes, as detailed in the “How we use your data” section below. We collect your personal data indirectly via the websites of our Partners who have integrated our platform (i.e., the shopping list function) in order to provide you with a seamless food shopping experience and from any social media sites through which you access our services.
We also collect information about you from other Consumers such as when they like (or equivalent), comment on, review or rate your recipes or where they choose to share their Contact Information to us.In addition, we collect personal data about you via automated means, such as from cookies and similar tools as you use our services.
A cookie is simply a piece of text, which can be placed on the browser of your personal computer or mobile device and subsequently read as you visit a website. Some of the cookies we deploy are necessary to provide certain functions through our website and Application, whereas others (such as those which relate to targeted advertising) are not. You have a choice about whether or not to accept these non-essential cookies.
We may use the data you provide to us for the following purposes:
For example, when you select a recipe from a website belonging to one of our Partners, you will be able to log into your account with us and create a shopping list via our integrated platform. If you decide to buy the items on your list, then we will transfer your selected grocery products for purchase to the third party grocery website of your choice, using Authentication Data to verify your identity and your Location Data to suggest appropriate grocery retailers.
Sooggi processes personal data for the purposes described above. Sooggi's legal basis to process personal data includes processing that is: necessary for the performance of the contract between you and Sooggi (for example, to provide you with the services and to identify and authenticate you so you may use certain services); necessary to comply with legal requirements (for example, to defend ourselves against legal claims or to make mandatory disclosures to law enforcement); necessary for Sooggi's legitimate interests (for example, perform data analytics to understand food trends, build a profile of your preferences and improve our services); and based on obtaining your separate consent (for example, to communicate with you about our products and services and provide you with marketing information), which may subsequently be withdrawn at any time by contacting us as specified in the Contact Us section of this Privacy Policy without affecting the lawfulness of processing based on consent before its withdrawal.
We sometimes process your personal data using a combination of machine learning and other AI techniques to evaluate information about you that we receive from the sources described under our “How we collect your data” section above. This is known as profiling and it helps us to build our understanding of your preferences in order to provide you with the best service we can. For example, we may analyse information relating to your purchases of a particular product to suggest similar products that you may be interested in buying via targeted advertising.
Depending on the purpose for which we are using your data, we may rely on various legal grounds for processing. In some cases, we will seek your explicit consent, in others we may rely on our legitimate interests or it may be necessary in order to perform our contract with you.
We will retain your personal data for as long as required to fulfil the purpose for which the data were collected, having regard to a range of applicable criteria, including the on-going relationship we have with you, the completion of the purpose for which the data was originally given, our own legal obligations and requirements, the type and size of the data held or our accounting requirements in relation to the data. For example, we will retain the Personal details that you provide when you open an account via our Application until you choose to delete your account. We may then in any event need to retain those Personal details for a period in order to defend ourselves against legal claims.
We use session and long-lived cookies on our websites and Application. Personal data that are collected by session cookies that are strictly necessary for purposes relating to fundamental website or Application functionality will be retained for a matter of minutes. Personal data that are collected by long-lived cookies may be retained for up to two years, depending on the purpose.
We will delete personal data once the relevant retention period expires. After such date, you will not be able to exercise some of your rights over your personal data that are described below. In general, we keep the length of time that we hold your personal data for under review. These reviews take place annually.
We may share your personal data with third parties under the following circumstances:
Your personal data may be transferred to and processed in a country that is not regarded as providing the same level of protection for personal data as the laws of your home country, including, for example and without limitation to the United Kingdom and the United States.
Where possible, we have sought to put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to provide adequate protections for your personal data. For more information on the appropriate safeguards in place and to obtain a copy of such safeguards, please contact us at the contact information set out below.
We engage Google Cloud to store your personal data within the European Economic Area (“EEA“). We have also implemented appropriate technical and organisational controls to ensure that your personal data are processed securely, such as encryption and authentication during transfer. However, no method of transmission over the internet or of electronic storage is fully secure, and as such, we cannot guarantee its absolute security.
You can withdraw any consent you have given us at any time and we will stop using your data for the purpose that consent was granted. You can also contact us at any time to request :
There may be situations where it is not possible for us to grant you these rights or we are not required by law to do so. For example, where restricting the processing of your personal data would impede a criminal investigation. As such, the rights described in the bullet points above are not absolute.
If you have questions or concerns regarding the way in which your personal data has been used, please contact our data protection officer, Neil Moran, at support@sooggi.com.
You can also contact us by post at:
Attention: Data Protection Officer
Sooggi Limited
71-75 Shelton Street
Covent Garden
London
WC2H 9HQ
United Kingdom
We are committed to working with you to obtain a fair resolution of any complaint or concern about your privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection regulator of your country of residence.
Changes to the Policy
We may modify or update this privacy notice from time to time. If we make any revisions that materially change the ways in which we process your personal data, we will notify you of these changes by email.
