Privacy Notice

The fine print.

Index.

1. Privacy Notice for U.S. Site.

2. Processing Activities Schedule.

3. Supplement for European Union and United Kingdom Residents.

4. Supplemental Information for Residents of Canada.

5. Colombian Residents.

Privacy Notice for U.S. Site

This version is effective from December 2025.

1. INTRODUCTION 

Your privacy matters to us. This privacy notice (the “Privacy Notice”) explains how Hero Digital LLC DBA Huge US (“Huge,” “we,” “our” or “us”) collects and processes your personal data in connection with your use of www.hugeinc.com (the “Site”).

This Privacy Notice also explains how we may use your personal data if you interact with us, including if you: are someone who uses our Site or Services; have seen an online ad promoting our Services or our business; work for businesses that provide goods or services to us; visit our premises; and attend events that we host.

This Privacy Notice does not apply to data we may collect and use outside of your interaction with our Site. Huge has separate agreements with clients and potential clients who want to engage Huge for the purpose of providing services. Those agreements include terms outlining our policies and practices for data collection and processing in that context. If you are a potential employee, employee or contractor, Huge likewise has separate agreements that contain our policies and practices for data collection and use in that context. If you are a potential client/ client or a potential employee/employee/contractor with questions about our data practices and your rights related thereto, please reference your agreement with us for information about how to contact us to answer those questions.

Please also note that in many cases where we process data in relation to services that we provide, those activities are governed by contracts between us and our clients and do not fall within the scope of this Privacy Notice. If you are an individual whose data is processed by us on behalf of a client, please contact that entity to learn about its data practices and policies related to your personal data.

Please also take time to review our Site’s Terms of Use. Your access and use of the Site is subject to our Terms of Use and this Privacy Notice is expressly incorporated into the Site Terms of Use.

Any changes we make to this Privacy Notice will be posted on our Site, including to reflect any changes to our use of personal data or to comply with applicable law or regulatory requirements. Where possible we may notify you of these changes by email, but we encourage you to check this page regularly to keep up to date.

2. WHO IS HUGE?

The Site is a platform for engagement with various companies in the Huge group of companies.

In the rest of this Privacy Notice, where “Huge”, “we”, “us, “our” is used, this means the Group Company that provides the Site, as identified below. Details of the Group Companies and the processing for which they are responsible are set out below.

Jurisdiction

Group company details

United States

Hero Digital LLC, dba Huge US is a limited liability company incorporated in the State of Delaware, United States of America with headquarters in Chicago, IL.

Canada

HelloHuge Canada, Inc. (company no: 1001075451) is a company established under the laws of Ontario, Canada with its registered office at 199 Bay Street, Ste 4000 Toronto ON M5L1A9 CANADA

Colombia

Huge SAS is a company established under the laws of Colombia with its registered address being Calle 97 A # 13 A - 57 Piso 2  Bogotá.

UK

Huge UK Limited (company no: 04235088), A private limited company with a registered address of 99 Clifton St, London, United Kingdom, EC2A 4LG.

Collectively, these entities operate under the Huge brand and are responsible for the personal information collected through this Site. Depending on where you are located and the type of interaction, a particular entity may act as the data controller for your personal information.

You can contact us at risk.compliance@hugeinc.com for more information. Please also see the “Your Privacy Rights” section below as well as the Addenda specific to Site visitors from the UK,  Canada and Colombia.

3. HOW WE COLLECT PERSONAL INFORMATION

We use the term “personal information” to describe information that can reasonably be associated with you and can be used to identify you. Personal information does not include information that has been deidentified or aggregated. We collect and receive personal information through the following methods:

  • Personal information you provide to us. You may give us your personal information directly, for example, when contact us with inquiries, complete forms on our Site, subscribe to receive our marketing communications or provide feedback to us.

  • Personal information we collect automatically, including through cookies and other similar technologies. When you access and use our Site, we may collect Technical Data and Usage Data automatically, including through our use of cookies and other similar technologies. For more information about our use of cookies and other similar technologies, please see the Cookies section.

  • Personal information we obtain from third parties. We may obtain personal information from third parties. Such third parties may include event suppliers and organizations we work with, analytics providers, data suppliers, third-party directories and third parties that provide technical services to us so that we can provide our Site.  They may also include social networks and other technology providers (for instance, when you click on one of our Facebook or Google ads).

  • Personal data that is publicly available. We may collect personal data that is available from public sources or that you or a third party may otherwise publish (for example on websites, posts on social media platforms, or speeches at events).

4. CATEGORIES OF PERSONAL INFORMATION WE COLLECT

  • Identity Data. Name (first, middle, and last); and title.

  • Contact Data. Email address; telephone number; social media handle; and postal/delivery address.

  • Communications Data includes correspondence or messages (including form submissions via the Site, surveys, emails, SMS or chat or social media messages or comments), the nature of your inquiry and other personal information which you choose to provide to us through these sources.

  • Professional Data. Job title; and organization that you represent (where you or your organization supplies products or services to us).

  • Usage Data. Data observed or collected in relation to browsing activity on our Site, interaction with our emails, interaction with ads that you see as a result of the activities described in the Online Advertising Activities section. This may include information about pageviews and events on our Site; information about the webpage or other source that users were previously on before reaching our Site; information about when a browsing session started and ended; information about views of and clicks on our ads, together with advertising or other identifiers associated with a user or their device (e.g. a device’s IDFA [iOS] or AAID [Android]) or advertising cookie identifiers.

  • Technical Data. IP address; details of the Site that you are viewing, such as full web page URL; browser type, device type and operating system and any other information available to us about the device you are using; location data, including the geographic location (which may be approximate, like the city or region you are in, or more precise) of a device derived from IP address, and any other data collected for technical diagnostics purposes), and any relevant unique identifiers assigned to a device or browser (including cookie identifiers)

  • Advertising Partner Data. Information obtained independently by our Advertising Partners as described in the Online Advertising Activities section. This may include unique identifiers and a profile of your possible interests and characteristics, which may have been built by observing your activity on websites, apps and other digital properties, including those operated by third parties, that use our Advertising Partners’ services. Unless specified otherwise in this Privacy Notice, this personal data is not shared with us, but we may be a controller of it in relation to purposes described in this Privacy Notice.

  • Marketing Data. Marketing preferences; and service communication preferences.

5. HOW WE MAY USE YOUR INFORMATION 

We may collect, use, disclose and otherwise process personal information for the following purposes:

  • Services and Support. To enable our Site, communicate with you through the Site, provide troubleshooting, technical support, and for similar support purposes, respond to your inquiries, and otherwise fulfill your requests.

  • Analytics and Improvement. To better understand how users access and use the Site, and for other research and analytical purposes, such as to evaluate, develop, and improve our Services and business operations, and for internal quality control and training purposes.

  • Communication. To respond to your questions, send you requested materials and newsletters, as well as information and materials regarding our Services and our offerings. We may also use this information to send administrative information to you. For example, information regarding the Services and changes to our terms and policies.

  • Customization and Personalization. To tailor content we may send or display on the Site and/or in providing our Services.

  • Marketing and Advertising. For marketing, advertising, and promotional purposes. For example, to send you promotional information about our Services, including information about sales, discounts, and new offerings, as well any other information that you sign up to receive.

  • Research and Surveys. To administer surveys and questionnaires, such as for market research or user satisfaction purposes.

  • Security and Protection of Rights. To protect the Site and our business operations, and to protect our rights or those of our stakeholders; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use.

  • Compliance and Legal Process. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding, to respond to a subpoena, warrant, court order, or other legal process, or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.

  • Auditing, Reporting, and Other Internal Operations. To conduct financial, tax and accounting audits, audits and assessments of our operations, including our privacy, security and financial controls, as well as for risk and compliance purposes. We may also use personal information to maintain appropriate business records and enforce our policies and procedures.

  • General Business and Operational Support. To assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and to administer our business, accounting, auditing, compliance, recordkeeping, and legal functions.

6. LAWFUL BASIS FOR PROCESSING PERSONAL INFORMATION 

If you are located in a region that requires a legal basis for processing of personal data (such as the EEA or UK), we need a lawful basis pursuant to applicable law to collect, use and disclose your personal information where Huge is a controller. Our legal basis will depend on the information concerned and the context in which it is processed.

7. HOW WE MAY DISCLOSE YOUR INFORMATION (TO THIRD PARTIES)

We will not disclose your personal information to third parties other than as described in this Privacy Notice unless we have your permission or are required or permitted to do so by law. We may share such information with our affiliates as necessary to carry out the purposes for which the information was supplied or collected. Similarly, third party contractors, consultants and/or vendors engaged by Huge to provide services may have access to your personal information. These third parties will be subject to their own data protection requirements providing the same or greater level of security provided by Huge and in most instances will also have entered into a written agreement with us which addresses access to and use of your personal information.

We may disclose the personal information we collect for the purposes described above with third parties as follows:

  • Vendors and Services Providers. We may disclose personal information we collect to our service providers, processors, and others who perform functions on our behalf. These may include, for example, IT service providers, help desk, payment processors, analytics providers, consultants, auditors, and legal counsel.

  • Compliance and Legal Obligations. We may disclose personal information to third parties to comply with our legal and compliance obligations and to respond to legal process. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements. This may include regulators, government entities, and law enforcement as required by law or legal process.

  • Security and Protection of Rights. We may disclose personal information where we believe it is necessary to protect the Services, our rights and property, or the rights, property and safety of others. For example, we may disclose personal information in order to (i) prevent, detect, investigate and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety, or legal rights of any person or third party, or (iii) enforce, and detect, investigate and take action in response to violations of our Terms of Use.  We may also disclose information, including personal information, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.

  • In Support of Business Transfers. If we, or our affiliates are, or may be acquired by, merged with, or invested in by another company, or if any of our assets are, or may be, transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company.  We may also share certain personal information as necessary prior to the completion of such a transaction or corporate transactions such as financings or restructurings, to lenders, auditors, and third-party advisors, including attorneys and consultants, as part of due diligence or as necessary to plan for a transaction.

  • Aggregate and Deidentified Information. Notwithstanding anything else in this Privacy Notice, we may use and share information that has been combined with data from other users or modified so that it can no longer be linked to any individual. This type of information does not identify you personally and may be shared with third-party partners, service providers, or the public for purposes such as improving our services, analyzing trends, or publishing research and reports.

  • Other Disclosures. We may disclose personal information in other ways not described above, but will notify you and, if necessary, obtain your consent.

8. COOKIES AND OTHER TRACKING TECHNOLOGY

We use cookies, pixels, local storage objects, log files, APIs, and other mechanisms to automatically collect browsing, activity, device, and similar information on our Site and to target advertising and content. We may also engage third-parties or service providers to do the same. We use this information to, for example, analyze and understand how visitors interact with our Services; identify and resolve bugs and errors in our Site, assess, secure, protect, optimize and improve Site performance; conduct marketing and analytics activities; and personalize content. To manage your preferences regarding cookies, targeted advertising, and other tracking mechanisms, please see Your Privacy Choices below.

Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while others support the security and performance of the Site, or allow us to track activity and usage data within the Site.

Pixel Tags. Pixel tags (sometimes called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with our Site to, among other things, track the activities of users, help us manage content and compile usage statistics. We may also use these in HTML e-mails we send, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Local Storage Objects. Local storage is a web storage mechanism that allows us to store data on a browser that persists even after the browser window is closed. Local storage may be used by our web servers to cache certain information in order enable faster loading of pages and content when you return to our Site. You can clear data stored in local storage through your browser. Please consult your browser help menu for more information.

Third-Party Analytics and Tools. We use third party tools, such as Google Analytics, which are operated by third party companies. These third-party analytics companies may use cookies, pixels, and other similar tools to collect usage data about our Services in order to provide us with reports and metrics that help us evaluate usage of our Site and improve performance and user experiences. These third parties may also use data for targeted advertising purposes.

To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/partners. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

**

  1. YOUR PRIVACY RIGHTS**

Depending on your jurisdiction and subject to certain limitations, you may have the following rights with respect to the personal information we process about you:

  • Right to know. You may have the right to know about the categories and the specific personal information that we may collect; the purposes for collecting that personal information; the categories of third parties to whom we may disclose that personal information; and whether we disclose personal information for business purposes or for commercial purposes that would be considered a “sale” or “share” of your information.

  • Right to data portability. You may have the right to obtain a copy of the personal information about you that’s being processed by us. To the extent it is technically feasible, we will provide that information to you in a usable and portable format

Upon receipt of a valid and verifiable request from you, we shall disclose to you both the categories and specific pieces of personal information we have collected about you, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting that personal information, the categories of third parties which whom we share that information. Your rights may be subject to certain limitations depending on the laws of your State.

  • Right to delete. You may have the right to request that we delete any personal information we have about you unless retention of that information is permitted or required under applicable law. If you request deletion of your personal information, we may deny your request or may retain certain elements of your personal information if it is necessary for us or our vendors to: - Complete the transaction or request for which the personal information was collected;

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

  • Debug to identify and repair errors that impair existing intended functionality;

  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;

  • To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.

  • Comply with a legal obligation.

  • Otherwise use the personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

  • Right to correct. You may have the right to request the correction of any personal information we maintain about you.

*Exercising Your Rights*

To exercise your rights as set out above, please contact us using our contact details described in the “How to contact us” section, indicating the type of right you would like to exercise and that you are making the request under an applicable U.S. state data privacy law.

In order to process your deletion and/or access request, we are permitted by law to collect certain information about you to verify your identity. If, however, we cannot verify your identity from the information already maintained by us, we may request additional information from you, which shall only be used for the purposes of verifying your identity, and for security or fraud-prevention purposes, such as a passport or driver’s license.

Under the laws of your state, you may have the right to use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. We may also require that you verify (as consumer) verify your identity directly with us and confirm that you have provided the authorized agent permission to act on their behalf.

We will make every effort to respond to your request within 45 days from when you contacted us. If you have a complex request, the law may permit us to take longer to respond. We will still contact you within 45 days from when you contacted us to let you know we need more time.

If we decline to take action on a request that you have submitted, we will inform you of our reasons for doing so, and provide instructions for how to appeal the decision. Depending on your state of residence you may have the right to appeal within a reasonable period of time after you have received our decision. If you have this appeal right, within 45-60 days, depending on the state, of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, we will provide you with a method for contacting your state attorney general’s office to submit a complaint.

*Right to non-discrimination. *

You have the right not to receive discriminatory treatment by us for the exercise of your privacy rights as set forth in this Privacy Notice.

*Explicit Notice – Right to opt-out*

We and our Advertising Partners collect personal information (such as Technical Data) when you use our Site. We, and our Advertising Partners, may use this information to personalize the ads we deliver to you when you visit others’ sites or use others’ apps. To personalise the ads so that they may be more relevant to you, our Advertising Partners may share personal data with other third parties.

If you do not wish for us or our Advertising Partners to use and disclose your personal data in this manner, which may be considered a “sale” under applicable U.S. state privacy laws, select the applicable control from our Cookie Notice.

If you access our Site from other devices or browsers, visit the link below from those devices or browsers to ensure your choice applies to the data collected when you use those devices or browsers. If you use different browsers, devices or platforms, you will need to opt out on each browser, device or platform.

Additionally, although our Cookie Notice will let you opt out of the sale of your personal information for advertising purposes, it will not opt you out of the use of previously collected and sold personal information or all context-based advertising.

10. INTERNATIONAL TRANSFER

Information collected while you use the Site, including your personal information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we may transfer the information, including your personal information, to the United States and process it there. In order to provide adequate protection for the data transfer, we have in place contractual arrangements with our subsidiaries, affiliates and business partners in respect of such transfers. By utilizing our Site, you authorize the international transfer of your data, to the United States, where we are based, and to other locations where we and/or our service providers operate.

11. HOW WE SECURE PERSONAL INFORMATION  

We are committed to keeping personal information secure and we have implemented information security policies, rules and technical measures to protect personal data under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. In addition, our personnel and data processors (third parties that process personal data on our behalf) are obliged to respect the confidentiality of the personal information relating to users of our Site and those who purchase our Services.

12. HOW LONG WE KEEP PERSONAL INFORMATION 

We will only keep your personal information for as long as necessary for the purposes set out in this Privacy Notice. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

If any personal information is only useful for a short period (e.g. for a specific activity, promotion or marketing campaign), we will not retain it for longer than the period for which it is used by us.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal information on a suppression list indefinitely so that we know not to send you further marketing communications in the future. However, we will not use this personal information to send you further marketing unless you subsequently opt back in to receive such marketing.

13. THIRD PARTY LINKS & SERVICES  

This Privacy Notice only applies to personal information collected or used by us. Our Site may contain links to third-party websites, apps or services. We have no control over these third-party websites, apps or services and this Privacy Notice does not apply to your interaction with the relevant third parties.

14. CHILDREN’S ONLINE PRIVACY PROTECTION ACT (COPPA)

Our Site and Services are not intended for use by, or targeted at, minors (individuals under the age of 18). However, this does not prevent minors from providing personal information to us. Where we do process personal information of minors, we will comply with all applicable laws and regulations relating to that processing.

15. YOUR CHOICE TO PROVIDE YOUR PERSONAL INFORMATION

Various parts of our Site offer you the opportunity to provide information to us. To the extent you choose not to provide personal information when requested on the Site, such as in relation to a submission or inquiry form or our ability to collect tracking or usage data, it may limit your ability to interact with the Site.

16. CONTACT US / DPO CONTACT INFORMATION 

Email to: risk.compliance@hugeinc.com.

Processing Activities Schedule

This Schedule sets out detailed information about the purposes for which we process personal information as set out in this Privacy Notice and the lawful bases we rely on to do so.

1. Providing our Site and carrying out other online activities. 

Purpose and Personal Data Processed

Description

Lawful Basis

Delivery of our Site  Technical Data

To provide our Site to you, including ensuring that we are showing you the correct notices and information, and recording your preferences in relation to our Cookies. Essential Cookies are used on our Site for this purpose. Please see the Cookies section for further information.

Legitimate interests – to provide our Site effectively. Compliance with a legal obligation. Performance of a contract.

Support, maintenance and security Identity Data Contact Data Technical Data Registration Data

To administer and protect our Site and users (including troubleshooting, fixing errors, analysis, testing, system maintenance, support, and security, including for fraud monitoring and prevention). To respond to user enquiries/offer support to users. We may use your information to respond to your enquiries and solve any potential issues you might have with the use of our Site. To request feedback and to contact you about your use of our Site. Essential Cookies are used on our Site for this purpose. Please see the Cookies section for further information.

Legitimate interests – to run our business and to protect us and our users from harm. Compliance with a legal obligation.

Site development and improvement Usage Data Technical Data

To develop and improve our Site, including content that we make available, through insight and analysis that we carry out in relation to the use of our Site as described in the Insight and analysis section. Non-essential Cookies are used on our Site for this purpose. Please see the Cookies section for further information.

Consent (where non-essential Cookies are used on our Site). Legitimate interests – to improve and enhance our Site (where non-essential Cookies are not used).

Personalization of our Site Usage Data Technical Data Profile Data

To personalize user experiences when using our Site, such as showing our users content and Site features that we think may be of interest or relevance to our users. Non-essential Cookies are used on our Site for this purpose. Please see the Cookies section for further information. In addition, activities described in the Insight and Analysis, Data Improvement and Personalization section may be relied on to carry out this activity.

Consent (where non-essential Cookies are used on our Site). Legitimate interests – to give users of our Site the best experience (where non-essential Cookies are not used).

2. Customer Services, Feedback and Relationship Management. 

Purpose and Personal Data Processed

Description

Lawful Basis

Customer services and general enquiries Identity Data Contact Data Transaction Data Profile Data Professional Data Communications Data

To manage and respond to any inquiry that you submit to us.

Legitimate interests – to help with your enquiry, provide a good standard of service and improve our customer services.

Social media pages and insights  Identity Data Contact Data Social Media Data

To publish pages on social media (including LinkedIn, Facebook, X or Instagram) relating to our Site, Services and business. These pages help social media users discover and engage with us, and help us promote, and keep social media users updated about, our business. To gain insight into our social media pages, we may receive insights from third-party providers of these social media platforms, about how users interact with our pages. We receive this information so that we can understand how many people saw our social media content, which content people are engaging with the most, actions users are taking on our pages (such as whether they are visiting our Site after visiting our pages, clicking on any content), and the demographics (such as age, gender and location) of those that view our social media pages. These insights are derived from personal data that third-party providers of the social media platform processes and are only provided to us in the form of anonymous and aggregate statistics – we do not receive your personal data or any information that we can use to identify you when we receive these insights. In addition, we may also see who has ‘liked’ or shared content that we post on social media (including when you interact with any ‘like’ or similar embedded feature on our Site). Note: We may be joint controllers with the relevant social media platform in relation to the insights that we receive.

Legitimate interests – to improve our online presence and promote our Site and Services via social media. Legitimate interests – to improve the content that we post on social media, including to ensure that our content is relevant to persons that we would like to engage with on social media.

Managing our relationship with you or the organization you work for Identity Data Contact Data Profile Data Transaction Data Professional Data Communications Data

To manage our relationship with you or the organization you work for (where your organization is our client or supplier to), including to contact you about any matter concerning our Services, to contact our suppliers about goods or services that we have purchased or may purchase from them, and to provide you with other important information (including about changes to our terms and conditions or this Privacy Notice).

Legitimate interests – to provide those that we work with the best experience and to ensure effective business administration. Legitimate interests – to effectively manage our supply chains. Compliance with a legal obligation – to comply with our consumer rights and privacy obligations.

Survey and feedback Identity Data Contact Data Transaction Data Profile Data Communications Data

To help us to monitor and improve our Site and Services, to assist with the selection of future service lines, and to train our personnel, we may carry out surveys or ask you for feedback.

Legitimate interests – to improve our Site and Services and provide them in an effective way.

Public Relations and Media Identity Data Contact Data Profile Data Professional Data Communications Data

To respond to media enquiries and requests (including interview requests, requests for comment, and requests for information) that we receive, or address reports in the media that concern us, we may process personal data relating to journalists, reporters and other media professionals. We may also send these persons corporate communications and other information by email for media and public relations purposes.

Legitimate interests – to ensure that our business is fairly and accurately represented in the media. Legitimate interests – to provide the right information to those who request it or otherwise have an interest in receiving it.

3. Insight and Analysis, Data Improvement and Personalization

Purpose and Personal Data Processed

Description

Lawful Basis

Insight and analysis  Technical Data  Usage Data Profile Data

To carry out insight and analytics, including: to carry out insight and analytics in relation to our Site, including counting user visits to our Site, combining this with general insights about our users’ interests and browsing habits so that we can understand the type of user that our Site appeals to, and learning what content and features of our Site are most popular; to count the open rate and measure the effectiveness of our marketing emails; to measure the effectiveness of our online advertising, including to generate aggregate statistics that do not identify individuals (for example, counting how many people viewed or clicked on our ads and were redirected to our Site through one of our ads); to gain general insights about clients and their purchase or use of our Services, so that we can develop future service lines; and to analyze the success of our events, including assessing sign-up rates, monitoring social media, online forums, and other online content, and collecting and analyzing event feedback. Some of the insights and analysis that we gather may be used by us to support the activities described in the personalization section. Non-essential Cookies are used on our Site for this purpose. Please see the Cookies section for further information.

Legitimate interests – to develop and improve our Site and our Services and to support other activities described in this Privacy Notice (where non-essential Cookies are not used). Consent (where non-essential Cookies are used).

Data improvement  Identity Data Contact Data Profile Data

To improve the quality of our data through the use of services and the data of third-party data suppliers, including to: enrich the data we hold about our clients and users (for example, adding data to information that we already hold); carry out data cleansing and tracing (for example, identifying redundant records and updating records); segment our clients and users (for example, identifying target sub-groups of our clients or users). Some of the activities set out in this section, may be used by us to support the activities described in the Personalization section.

Legitimate interests – to ensure the effective and efficient use of data and to support other activities described in this Privacy Notice. Compliance with a legal obligation.

Personalization  Technical Data  Usage Data Profile Data Advertising Partner Data

To tailor the information and experiences provided to our users and clients, so that they are more likely to be of interest and relevance, including in relation to: user experiences on our Site as described in the  Personalization of our Site section; our marketing communications described in the Marketing communications section; our online advertising described in the Online Advertising Activities section. The activities described in the Insight and analysis and Data improvement  sections may be relied on to carry out this activity. Non-essential Cookies are used our Site for this purpose. Please see the Cookies section for further information.

Legitimate interests – to give users and clients the best experience, and to support our marketing and advertising activities, where non-essential Cookies are not used. Consent (where non-essential Cookies are used).

4. Online Advertising Activities

We may share your personal data with, or otherwise use the services of, third-party social media and advertising technology companies (“Advertising Partners”), so that we can advertise our business, including our Site and our Services, on websites, apps, and other digital platforms, including social media, that are operated by third parties (“Third-party Sites”).

Our online advertising activities are explained in more detail below. If you see one of our ads, this may be the result of one or a combination of these activities.

Please note:

  • Some of the advertising that you see based on these activities may be personalized to you. Please see the Personalization section for further information.

  • We may be joint controllers with our Advertising Partners, or our Advertising Partners may be independent controllers, in relation to the activities described in this section. For more information, please see the Advertising and Social Media Partners section.

Purpose and Personal Data Processed

Description

Lawful Basis

‘Custom Audience’ advertising (also known as ‘Custom Match’ advertising) Contact Data Usage Data (identifiers only) Advertising Partner Data

To enable our Advertising Partners to ‘match’ identifiers which we have obtained (for example, your email address or your device’s advertising identifier) with identifiers that are available to our Advertising Partners, including those relating to registered users of Third-party Sites. The matched identifiers are known as a ‘custom audience’. We and our Advertising Partners create this custom audience so that our ads will be displayed to individuals whose identifiers are included in the custom audience when those individuals use the relevant Third-party Site (e.g. to show you an ad on your Facebook newsfeed). Our custom audience may also be used to exclude individuals from seeing our ads (because we want to show ads to people who are not our existing clients or users).

Consent (in relation to data that we share with our Advertising Partners). Legitimate Interests – to increase the effectiveness of our advertising (to the extent we are a controller of Advertising Partner Data[ or we have not obtained your consent).

‘Lookalike Audience’ advertising   Contact Data Usage Data (identifiers only) Advertising Partner Data

To ask our Advertising Partners to find other people that share similar interests and characteristics to the individuals who are in our custom audience (as described in the ‘Custom Audience’ advertising section), so that we can show our ads to those other individuals when they use Third-party Sites. This activity is known as ‘lookalike audience’ advertising because the individuals who see our ads ‘look like’ the individuals who form part of our custom audience. For example, our Advertising Partners may use their data to identify that 70% of our custom audience are men aged between 20-25. We then ask our Advertising Partners to show our ads to other men aged between 20-25. Our Advertising Partners do not provide their Advertising Partner Data to us, but they may provide us with aggregate insights about the individuals who are shown our ads (for example, their age, gender, approximate location and interests).

Legitimate Interests – to increase the effectiveness of our advertising by finding new people who we may wish to advertise to. See the ‘Custom Audience’ advertising section to understand the lawful basis we rely on to create our custom audience.

Advertising on Third-party Sites using Cookies and our Advertising Partners’ tools  Technical Data  Usage Data Advertising Partner Data

To display ads for our Services or that promote our business to you when you visit Third-party Sites, including to: recognize you as a user of our Site and to display ads for Services that you have viewed on our Site; and reach users of Third-party Sites who meet certain criteria determined by us or our Advertising Partners using selection tools made available by our Advertising Partners (for example, users who are likely to be men or are aged between 20-25). Non-essential Cookies are used on our Site to recognize you as a user of our Site. Please see the Cookies section for further information. In addition, our Advertising Partners may use non-essential Cookies on Third-party Sites, as well as Advertising Partner Data that they have independently collected, for this purpose. We are not responsible for these technologies and you should separately review the information provided to you on the Third-party Site about these technologies.

Consent (where non-essential Cookies are used on our Site). Legitimate interests – to increase the effectiveness of our advertising by displaying our ads to individuals who have previously shown an interest in our Services, or our business, or are most likely interested in our ads based on criteria determined by us and our Advertising Partners (where other personal data is used).

Measuring the effectiveness of our advertising Usage Data Technical Data  Advertising Partner Data

To determine how successful our other advertising activities described in this Online Advertising Activities section have been, and to understand who has viewed or interacted with our ads. We may do this to: generate insight and analysis about our advertising activities, as described in the Insight and analysis section; and personalize experiences, as described in the Personalization section. Non-essential Cookies are used on our Site to recognize you as a user of our Site. Please see the Cookies section for further information. In addition, our Advertising Partners may use non-essential Cookies on Third-party Sites, as well as Advertising Partner Data that they have independently collected, for this purpose. We are not responsible for these technologies and you should separately review the information provided to you on the Third-party Site about these technologies.

Consent (where non-essential Cookies are used on our Site). Legitimate interests – to understand the type of advertising and marketing content that is most likely to be of appeal (where other personal data is used). Legitimate interests – to increase the effectiveness of our advertising by collecting information about which of our ads an individual has responded to, so that we can show that individual similar ads, or other ads that may be of interest to them, in the future.

4. Other Advertising and Marketing Activities

Purpose and Personal Data Processed

Description

Lawful Basis

Marketing communications  Identity Data Contact Data Communications Data

To promote our Site, our Services, or to otherwise promote our business (including events), via email, telephone or post. To ensure that the marketing content that is provided to you is more likely to be of interest, our marketing communications may be personalized. For more information, please see the Personalization section.

Consent (where marketing via email). Legitimate interests (where marketing via telephone and post) – to grow our business. You can unsubscribe from our email marketing by clicking the ‘unsubscribe’ link in our emails. You can also ask us to stop using your personal data for our direct marketing activities by contacting us using the details set out under the How to contact us section.

Third-party marketing (lead generation) Identity Data Contact Data Profile Data Communications Data

To share your personal data with third-party partners and event sponsors to enable them to contact you in relation to an event and to send marketing to you in relation to their products and services.

Consent. Legitimate interests – to provide marketing services to third parties and to help those third parties grow their business, and for our third-party partners’ and event sponsors’ legitimate interests to get the most out of an event and to promote their business to you.

Prize draws, prize competitions and other promotions Identity Data Contact Data Profile Data

To administer prize draws, prize competitions and other promotions that we run. Please note that our prize draws, prize competitions and other promotions are subject to separate terms and conditions and further information about how we use your personal data may be provided when you enter.

Performance of a contract (e.g. the promotion terms and conditions). Legitimate interests – to administer our promotion fairly and effectively and to comply with self-regulatory codes governing the operation of promotions.

6. Business Administration, Compliance and Legal Affairs

Purpose and Personal Data Processed

Description

Lawful Basis

Business administration and legal compliance Identity Data Contact Data Profile Data Usage Data Technical Data Incident Data Communications Data Professional Data

To comply with our legal obligations. To enforce our legal rights or defend against potential legal claims. To protect the rights of third parties. To facilitate a business transition such as a merger, reorganization, acquisition by another company, or sale of any of our assets.

Legitimate interests – to operate our business effectively. Compliance with a legal obligation.

Security Identity Data Contact Data Technical Data  Usage Data 

To protect our Site against fraudulent activity or other violations of our Site Terms of Use.

Legitimate interests – to prevent interference with the function of our Site and our ability to operate the Site securely.

Supplement for European Union and United Kingdom Residents

If you are located in the European Union (EU) or the United Kingdom (UK), you have specific rights under the General Data Protection Regulation (GDPR) and the UK GDPR. These rights are in addition to any other rights described in this Privacy Policy.

Legal Bases for Processing

We process your personal information only when we have a valid legal basis.  Please refer back to our Processing Activities Schedule for details about the purpose for which we collect your personal information and the legal basis for which we collect and process it.

Your Rights

Subject to applicable law, you may exercise the following rights:

  • Right of Access – Obtain confirmation of whether we process your personal information and receive a copy of it.

  • Right to Rectification – Request correction of inaccurate or incomplete personal information.

  • Right to Erasure (“Right to be Forgotten”) – Request deletion of your personal information in certain circumstances.

  • Right to Restrict Processing – Request that we limit the processing of your personal information in certain cases.

  • Right to Data Portability – Receive your personal information in a structured, commonly used, machine-readable format and request that we transfer it to another organization.

  • Right to Object – Object to processing based on our legitimate interests, and object at any time to processing for direct marketing purposes.

  • Rights Related to Automated Decision-Making – Not to be subject to decisions based solely on automated processing, including profiling, that have legal or similarly significant effects on you.

International Data Transfers

Please refer to the section on International Data Transfers in the body of our Privacy Notice.

Contact Information 

To exercise your rights or raise questions about our practices, please contact us at:

risk.compliance@hugeinc.com

You also have the right to lodge a complaint with your local data protection authority (DPA) in the EU or with the UK Information Commissioner’s Office (ICO) if you believe your rights have been infringed.

Supplemental Information for Residents of Canada

If you are a resident of Canada, you have rights under applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and substantially similar provincial laws in Quebec, Alberta, and British Columbia. These rights are in addition to any other rights described in this Privacy Policy.

  • Right to Access – You may request access to the personal information we hold about you and obtain details on how it is used and disclosed.

  • Right to Correction – You may request that inaccurate, incomplete, or outdated personal information be corrected.

  • Right to Withdraw Consent – Where we rely on your consent to process your personal information, you may withdraw that consent at any time, subject to legal or contractual restrictions and reasonable notice.

  • Right to Information – You have the right to know why we collect your personal information, how it is used, and to whom it has been disclosed.

  • Right to Complain – You may raise concerns with us at any time. You also have the right to file a complaint with the relevant privacy commissioner, including the Office of the Privacy Commissioner of Canada or your provincial commissioner, if you believe your rights have not been respected.

Quebec Residents

If you are a resident of the province of Quebec, additional rights apply to you under the Act respecting the protection of personal information in the private sector (CQLR c. P-39.1), as amended by Law 25. These include:

  • Right to Deletion (Right to be Forgotten) – You may request that we stop disseminating your personal information or that we de-index or re-index hyperlinks attached to your name, in cases permitted by law.

  • Right to Data Portability – You may request that we provide your personal information to you, or to another organization, in a structured, commonly used technological format.

  • Rights Regarding Automated Decision-Making – If we make decisions based exclusively on automated processing of your personal information, you have the right to be informed and to request details about the personal information used, the reasons and principal factors leading to the decision, and to submit observations to a member of our team for review.

  • Right to Anonymization – Once the purposes for which your personal information was collected are fulfilled, we may anonymize your personal information instead of deleting it.

Contact Information

We are responsible for the personal information under our control and have appointed a Privacy Officer to oversee compliance with Canadian privacy laws. To exercise your rights, or if you have questions about our privacy practices, please contact us at: Risk.compliance@hugeinc.com.

Colombian Residents

If you are a resident of Colombia, you have specific rights under the Law 1581 of 2012 and Decree 1377 of 2013 regarding your personal information. These rights are in addition to any other rights described in this Privacy Policy.

  • Right to Know and Access – You may request information about whether we hold your personal information and how it is used.

  • Right to Update and Rectify – You may request correction or updating of your personal information if it is incomplete, inaccurate, or outdated.

  • Right to Delete – You may request deletion of your personal information when it is not necessary, excessive, or being processed contrary to applicable law.

  • Right to Proof of Consent – You may request evidence of the consent you have provided for us to process your personal information.

  • Right to Revoke Consent – You may withdraw your consent to the processing of your personal information at any time, subject to legal or contractual restrictions.

  • Right to File Complaints – You may file complaints with the Superintendencia de Industria y Comercio (SIC) if you believe your data protection rights have been infringed.

How to Exercise Your Rights

To exercise these rights, please contact us at risk.compliance@hugeinc.com. We will respond in accordance with the timelines and procedures set out under Colombian law.