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Privacy Policy

1. Privacy policy notice

Our Privacy Policy explains how So-Mo Co Ltd collects, uses, and discloses information about you. The terms “So-Mo,” “we,” “us,” and “our” include So-Mo Co Ltd and our affiliates. We use the terms “you,” and “your” to mean the person using our website or attending related events, including any organisation or person using the website on an organisations behalf. This Privacy Policy applies to the processing of information about members and other individuals that we collect when you use our website, services we offer, or when you communicate with us.

This Privacy Policy does not apply to the information you may provide to third parties, such as attendees at events, and other with whom you may share information about yourself.

2. collection of information

information you provide to us

We collect information that you provide directly to us. For example, we collect information that you provide when you sign up to our mailing list, choose interest or groups, fill out a form, or communicate with us. The types of information that we may collect include your name, email address, postal address, phone number, payment method data, photos, choices of interests and groups, and any other information that you choose to provide. Information about your gender and interests is optional.

On occasion, the information that you give us may include information about your beliefs, political views, health conditions; or your sexual identity. This, and other kinds of sensitive information, is given special protection.

Log information

When you use our website, we automatically collect information about you, including:

· Log information: We collect log information about your use of the website, including the type of browser that you use; the time, duration and frequency of your access, website pages viewed; your IP address; and the pages you visited before visiting our website.

· Device information: We collect information about the computer or mobile device that you use to access our website, including the hardware model, operating system and version, unique device identifiers, and mobile network information.

· Location information: We may collect information about the location of your device each time you use our website based on you consent to the collection of this information.

information we collect from other sources

We may collection information about you from other sources, but only where these third parties have your consent or are otherwise legally permitted or required to disclose your information to us. Examples include:

· Social media services: If you view our social media accounts, we will have access to some of your information from that service. This information is similar to ‘Section 2 Log information’ and is accessible via Twitter Analytics.

· Information from other third-party sources: We may obtain information about you from publicly and commercially available sources and other third parties as permitted by law.

3. use of information

operating our service

We may use information about you for various purposes related to operating our service, including to:

· provide, maintain, and improve our service, including development of new products and services, and manage the performance of our service;

· monitor and analyse trends, usage, and activities in connection with our service;

· inform a current project

communicating with you

We may use information about you for various purposes related to communicating with you, including to:

· respond to your comments, questions, and requests, and provide customer service;

· communicate with you, about products, services, and events offered by us and others, to provide news and information that we think will be of interest to you, to conduct online surveys, to contact you about events that are being held near your locations, and to otherwise communicate with you in accordance to Section 3;

· send you technical notices, updates, security alerts and support, and administrative messages.

other uses

We may use information about you for various other purposes, including to:

· carry out any other purposes described to you at the time that we collected the information.

legal basis for processing

Our legal basis for collecting and using the information described above will depend on the type of information and the specific context in which we collect it.

· We process information about you in order to provide our consultancy services where your data relates or informs a current project

· We also process information about you where it is in our legitimate interest to do so and not overridden by your rights (for example, in some cases for direct marketing and responding to your communications).

· Sometimes you provide us with sensitive information about yourself; for instance, the mere fact of joining a certain group may indicate information about your health, religion, political views, or sexual identity. Providing this information is entirely voluntary and done with your explicit consent.

· In some cases, we may have a legal obligation to collect information about you or may otherwise need the information to protect your vital interests or those of another person.

· We may also process information to comply with a legal requirement or to perform a contract.

4. sharing of information

with our service providers

We may use service providers in connection with operating and improving our service to assist with certain function, such as payment processing, email transmission, conducting surveys or contests, data hosting, and some aspects of our technical and customer support. We take measures to ensure that these service providers access, process, and store information about you only for the purposes we authorise, subject to confidentiality obligations.

following the law and protecting so-mo

We may access, preserve, and disclose information about you to third parties including content of messages, if we believe disclosure is in accordance with, or is required by, applicable law, regulation, legal process, or audits. We may also disclose information about you if we believe your actions are inconsistent with our guidelines and policies, or if necessary to protect the rights, property, or safety of, or prevent fraud or abuse of So-Mo or others.

affiliate sharing and merger, sale, or other asset transfers

If So-Mo is involved in a merger, acquisition, financing, reorganisation, bankruptcy, or sale of our assets, information about you may be shared, sold or transferred as part of that transaction. We may also share information about you with current or future corporate partners, subsidiaries or affiliates.

other situations

We may de-identify or aggregate information about you and share it freely, so that you can no longer be identified. We may also share information about you with your consent or at your direction or where we are legally entitled to do so.

5. additional details

analytics and advertising services provided by others

With your permission, we may allow others to use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the website and other online services. See third party Cookie Policies for details about these technologies and the information that they collect, use or share, including how you may be able to control or disable these services. We currently use:

· Google Analytics

· Twitter Analytics

transfer of information to other countries

So-Mo is based in the U.K. Information about you will be processed in the U.K. However, some third-party providers may be based in countries other than which you are resident. These countries may have data protection laws that are different to the laws of your country and, in some cases, may not be as protective. We have taken appropriate safeguard to require that your information will remain protected in accordance with this Privacy Policy.

security

We employ technical and organisational measures designed to appropriately protect your information that is under our control. We store all information that you provide to us on secure servers. We train employees regarding our data privacy policy and procedures and permit authorised employees to access information on a need to know basis, as required for their role. We use firewalls designed to protect against intruders and test for network vulnerabilities. However, no method of transmission over the internet or moth of electronic storage is completely secure.

data retention

We retain certain information that we collect from you for the following reasons:

· so that we can communicate with you

· to ensure that we do not communicate with you if you have asked us not to

· to inform an ongoing or previous project where your data has been identified as being useful to a future project

· to comply with legal, tax or accounting requirements.

When we have no ongoing legitimate business need to process your information, we will either delete or anonymise it.

policy scope

This Privacy Policy does not apply to information that you provide to third parties, such as other members, including group organisers and network administrators, and others with whom you may share information about you. Our website may direct you to a third-party service, such as social media services, or a portion of our website may be controlled by a third-party. Disclosure of information to these third parties is subject to relevant third-party’s Privacy Policy. We are not responsible for the third-party Privacy Policy or content, even if we link to those services from our website or if we share information with these third parties.

revisions to this policy

We may modify this Privacy Policy from time to time. To gain access to the most recent version of this policy please email:

hello@so-mo.co

6. your choices

personal information

You may view, update or correct your current information by sending a subject access request to hello@so-mo.co

You may request to have data removed by sending an email to hello@so-mo.co

You will be able to choose what information you update or remove.

promotional communications

You can control messages you receive from So-Mo by selecting the unsubscribe link in the message that you receive, or by adjusting the communication preferences in your account settings. We will also send you a link to these settings when you first sign up and in subsequent messages. If you opt out, we may still send you non-promotional messages, such as those about your account or ongoing business relations.

7. data rights

We respond to all requests that we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. You can contact us by sending an email to hello@so-mo.co

Rights that you may have, depending on the country in which you live, include:

· accessing, correcting, updating, or requesting deletion of your information.

· objecting to processing of your information, asking us to restrict processing of your information, or requesting the portability of your information.

· opting out from receiving marketing communications that we send you at any time. You can exercise this right by selecting the “unsubscribe” or “opt-out” link in the marketing emails we send you. Additionally, you may update your email preferences by changing the settings in your account.

· withdrawing your consent at any time if we have collected and processed your information with your consent. Withdrawing your consent will not affect the lawfulness of processing that we conducted prior to your withdrawal, nor will it affect processing of your information conducted in reliance on lawful processing grounds other than consent.

· complaining to a data protection authority about our collection and use of your information. For more information, please contact your local data protection authorities.