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Privacy Policy

Effective as of 13th June 2025

Fugo ('Fugo', 'we', 'us', and 'our') takes data protection very seriously and we are committed to protecting your personal information. This privacy policy governs the privacy of its users who choose to use it. It explains how we comply with the GDPR and the Data Protection Act 2018.

This policy explains what information we gather about you, what we use that information for, and to whom we give that information. It also sets out your rights in relation to your information, how long we keep it and whom you can contact for more information. Additionally, it will explain the use of cookies or software, advertising or commercial sponsorship from third parties and the download of any documents, files or software made available to you (if any) on our website (www.fugo.ai).

It is our policy to collect only the minimum information required from you. If you believe we have collected excessive information about you, please contact us at security@fugo.ai to raise any concerns you may have.

Although you do not have to provide any of your personal information to us, if we ask you to do so and you refuse, we may be unable to provide you with the information, goods or services you want from us.

Users are responsible for any third-party personal data obtained, published or shared through fugo.ai and confirm that they have the third party's consent to provide the data to us.

Data Protection Officer

Our Data Protection Officer can be contacted at dawid@fugo.ai for all data protection matters.

Categories of Data Subjects and Personal Information

Customer Data

We process personal information for the following categories of data subjects:

Service Users:

  • Account holders and authorised users of the Fugo platform
  • Trial users and prospects
  • Support ticket creators

Data Categories:

  • Contact information (name, email, telephone, company)
  • Account credentials and authentication data
  • Usage analytics and service interaction data
  • Support communications and ticket history
  • Digital signage content metadata (excluding personal content uploaded by users)

Website Visitors

Data Categories:

  • IP address and browser information
  • Website interaction data and analytics
  • Cookie preferences and tracking data
  • Form submissions and download requests

Business Contacts

Data Categories:

  • Contact information from business cards and networking
  • Event registration and attendance data
  • Marketing communication preferences

Employment Candidates

Data Categories:

  • CV/curriculum vitae information and employment history
  • Interview records and assessment data
  • References and background check information

What is Personal Information?

Personal information is anything that enables you to be identified or identifiable, such as your:

  • First and last names
  • Postal and email addresses
  • Telephone numbers
  • Identity documents (e.g. passports and driving licences)
  • Identity numbers (e.g. National Insurance numbers and bank account details)
  • Career and educational documents (e.g. curricula vitae and qualifications)
  • Contact information

Your personal information is sometimes called personal data. We collectively refer to handling, collecting, protecting or storing your personal information as 'processing'.

Collecting Personal Information

Below are examples of how you may provide personal information to us:

  • Placing an order with us
  • Registering for a trial with us
  • Completing our contact form
  • Searching, browsing and entering information on our website
  • Downloading guides or content
  • Subscribing to our newsletters
  • Using our live chat
  • Opening a support ticket
  • Registering for or attending our events
  • Submitting curricula vitae or work history information to us
  • Providing us with business cards or other contact information
  • Accessing our online publications
  • Entering our surveys
  • Uploading personal data to the Fugo service

Purpose of Using Personal Information and Legal Basis

When you provide personal information to us, we process it for the following purposes with their corresponding legal basis under GDPR Article 6:

Service Delivery (Legal Basis: Performance of Contract - Art. 6(1)(b))

  • To provide services to you that you have requested
  • To establish and maintain your user profile on the Service
  • To facilitate your login to the Service via third-party identity and access management providers
  • To provide support and maintenance for the Service
  • To respond to your requests, questions and feedback

Security and Service Operations (Legal Basis: Legitimate Interests - Art. 6(1)(f))

  • To enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in
  • To communicate with you about the Service, including by sending you announcements, updates, security alerts, and support and administrative messages
  • Personal information for research and development to analyse use of the Service to improve the Service and to develop new products and services, including by studying user demographics and use of the Service

Marketing Communications (Legal Basis: Consent - Art. 6(1)(a))

  • To send you marketing and promotional communications as permitted by law
  • You will have the ability to opt out of our marketing and promotional communications as described in the opt-out of marketing section below

Employment Processing (Legal Basis: Legitimate Interests - Art. 6(1)(f))

  • To consider whether to offer someone employment with us

Business Development (Legal Basis: Legitimate Interests - Art. 6(1)(f))

  • To develop our businesses and services
  • To understand your needs and interests, and personalise your experience with the Service and our communications
  • To communicate with you about events and contests in which you participate

Legal Compliance (Legal Basis: Legal Obligation - Art. 6(1)(c))

  • To comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities

Safety and Fraud Prevention (Legal Basis: Legitimate Interests - Art. 6(1)(f))

  • To protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims)
  • To enforce the terms and conditions that govern the Service
  • To protect, investigate and deter against fraudulent, harmful, unauthorised, unethical or illegal activity

Legitimate Interest Assessments

Where we process personal data based on legitimate interests, we have conducted balancing tests to ensure our interests do not override your fundamental rights and freedoms. Details of these assessments are available upon request at security@fugo.ai.

Our primary legitimate interests include:

  • Maintaining service security and preventing fraud
  • Improving our services through analytics
  • Direct marketing to existing customers
  • Protecting our business operations and legal rights

We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyse and improve the Service and promote our business.

Security of Personal Information

We have implemented generally accepted standards of technology and operational security in order to protect personally identifiable information from loss, misuse, alteration or destruction.

Only authorised persons are provided access to personally identifiable information we have collected, and such individuals have agreed to maintain the confidentiality of this information.

Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by email) is never completely secure.

We endeavour to protect personal data, but we cannot guarantee the security of data transmitted to or by us.

Sharing Personal Information and Recipients

We do not share your personal information with third parties without your consent, except in the following circumstances or as described in this Privacy Policy:

Internal Recipients

Affiliates - We may share your personal information with our affiliates, for purposes consistent with this Privacy Policy.

External Recipients

Service providers - We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Service, including:

  • Cloud hosting providers (Google, Hetzner, AWS)
  • Customer support platforms (Intercom)
  • Analytics services (Google)
  • Email delivery services (Google)
  • Marketing platforms (Google, PostHog)
  • Payment processing services (Stripe)
  • Database management services (AWS)

These third parties may use your personal information only as directed or authorised by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.

Third-party platforms and social media networks - If you have enabled features or functionality that connect the Service to a third-party platform or social media network (such as by logging in to the Service using your account with the third party, providing your API key or similar access token for the Service to a third party, or otherwise linking your account with the Service to a third party's services), we may disclose the personal information that you authorised us to share. We do not control the third party's use of your personal information.

Other users of the Service and the public - We may provide functionality that enables you to disclose personal information to other users of the Service or the public. You may also be able to submit content to the Service (such as comments, reviews, surveys, blogs, photos, and videos which you may display using our digital signage software). We may make available settings through the account management page that enable you to exercise choice regarding certain information that is displayed publicly or to other users. We do not control how other users or third parties use any personal information that you make available to other users or the public.

Professional advisers - We may disclose your personal information to professional advisers, such as solicitors, barristers, accountants and insurers, where necessary in the course of the professional services that they render to us.

Business transfers - We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganisation or sale of assets, or in the event of bankruptcy or dissolution.

Other Disclosures

We may also disclose personal information to third parties under the following circumstances:

  • When explicitly requested by you
  • When required to deliver goods or services requested by you
  • When required to facilitate our conferences or events that you have asked to attend which are hosted by a third party
  • As otherwise set out in this privacy policy

We may also disclose your personal information to law enforcement, regulatory and other government agencies and to professional bodies and other third parties, as required by and/or in accordance with applicable law or regulation.

International Data Transfers

All primary data processing operations take place within the United Kingdom and European Union (Germany). Where we engage third-party service providers that may process data outside the UK/EU, we ensure appropriate safeguards are in place through:

  • Adequacy regulations under the GDPR
  • International data transfer agreements
  • Standard contractual clauses
  • Other legally recognised transfer mechanisms

Data Breach Procedures

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner's Office within 72 hours of becoming aware of the breach, as required by GDPR Article 33. Where the breach is likely to result in a high risk to your rights and freedoms, we will also notify affected individuals without undue delay.

Your Choices

Users of our services can choose to:

Update your information - If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account. Data export available in JSON/CSV format upon request to security@fugo.ai.

Data deletion - Deletion requests are processed within 30 days of verified request, subject to legal retention requirements.

Access requests - Personal data access requests fulfilled within one month as required by GDPR Article 15.

Opt out of marketing communications - You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email. You may continue to receive service-related and other non-marketing emails.

Cookies and browser web storage - We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Service and third party websites (see cookie policy below).

Targeted online advertising - Some of the business partners that collect information about users' activities on or through the Service may be members of organisations or programmes that provide choices to individuals regarding the use of their browsing behaviour or mobile application usage for purposes of targeted advertising.

Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative or the Digital Advertising Alliance. European users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by selecting the user's country, and then clicking "Choices" (or similarly titled link). Users of our mobile applications may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app and selecting the user's choices. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.

In addition, your mobile device settings may provide functionality to limit our, or our partners', ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device.

If you choose to opt out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioural advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.

Do Not Track - Some internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals.

Third-party platforms or social media networks - If you choose to connect to the Service via a third-party platform, you may have the ability to limit the information that we may obtain from the third party at the time you login to the Service using the third party's authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third party's platform or service.

Retention of Personal Information

We retain personal information for specific periods based on the purpose for which it was collected:

Service Data

  • Account information: Retained for the duration of your account plus 7 years for legal and tax purposes
  • Usage logs and analytics: Retained for 2 years for service improvement purposes
  • Support communications: Retained for 3 years for quality assurance and legal purposes

Marketing Data

  • Email marketing data: Retained until consent is withdrawn or 2 years of inactivity
  • Website analytics: Retained for 2 years for website optimisation

Employment Data

  • Successful candidates: Retained according to employment law requirements
  • Unsuccessful candidates: Retained for 1 year for equal opportunities monitoring

Legal and Financial Data

  • Contract and billing information: Retained for 7 years for legal and tax compliance
  • Legal communications: Retained for 7 years or until legal matters are resolved

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Marketing

Where we are legally required to obtain your consent to provide you with marketing materials, we will only provide you with such marketing materials if you have provided consent for us to do so.

If you opt into any subscriptions you will receive emails known as newsletters. If you want to unsubscribe from any subscriptions, you should look for and follow the instructions we will provide in the relevant communications to you.

If you choose to unsubscribe from any or all mailings, we may retain information sufficient to identify you so that we can honour your request.

Cookie Policy

Our website uses cookies to better the users' experience whilst visiting the website. As required by legislation, where applicable this website uses a cookie control system, allowing the user to give explicit permission or to deny the use of/saving of cookies on their computer/device.

Cookie Categories

Essential Cookies (No consent required)

  • Session management and authentication
  • Security and fraud prevention
  • Basic website functionality

Non-Essential Cookies (Consent required)

  • Analytics and performance monitoring
  • Marketing and advertising cookies
  • Social media integration cookies

What are cookies? Cookies are small files saved to the user's computer's hard drive that track, save and store information about the user's interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website. Our site may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them).

Users are advised that if they wish to deny the use and saving of cookies from this website on to their computer's hard drive they should take necessary steps within their web browser's security settings to block all cookies from this website and its external serving vendors or use the cookie control system if available upon their first visit. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the sites may not work properly.

For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org. If you do not accept our cookies, you may experience some inconvenience in your use of our sites. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our sites.

Rights in Relation to Your Information

You have certain rights in relation to the personal information we hold about you. In particular, you have the right to:

  • Request a copy of personal information we hold about you
  • Ask that we update the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete
  • Ask that we delete personal information that we hold about you, or restrict the way in which we use such personal information
  • Object to our processing of your personal information
  • Withdraw your consent to our processing of your personal information (to the extent such processing is based on consent and consent is the only permissible basis for processing)
  • Request portability of your personal information in a structured, commonly used and machine-readable format

You may submit these requests by email to security@fugo.ai. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the Information Commissioner's Office. You can find the ICO at https://ico.org.uk.

Automated Decision Making

We will not use your personal information for automated decision making or profiling.

Children and Minors

The Service is not intended for use by children under 16 years of age. If we learn that we have collected personal information through the Service from a child under 16 without the consent of a parent or guardian, we will take steps to delete that information as soon as possible.

Our Website

Our website may link to third-party sites not controlled by us and which do not operate under our privacy practices. When you link to third-party sites, our privacy practices no longer apply. We encourage you to review each third-party site's privacy policy before disclosing any personally identifiable information.

We do not intend to collect special category (also known as sensitive) personal information through our website (unless we are legally required to do so). Examples of special category information are: race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and criminal records.

We ask that you do not provide us with special category personal information when using our website.

Changes to this Privacy Policy

Fugo reserves the right to make changes to this privacy policy at any time by giving notice to its users on our webpage and possibly sending a notice to users via any contact information available to us. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

Contact Us

If you have any questions or complaints about the way your personal information is processed by us, or would like to exercise one of your rights set out above, please contact us at support@fugo.ai

Location of Data Processing

All information is processed and stored within the United Kingdom and European Union. Our primary data processing operations take place in Germany through our infrastructure providers:

  • Hetzner (Germany)
  • Google (EU regions)
  • AWS (London, UK)

Links to Other Websites

fugo.ai may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.

Your Rights

Under the GDPR and the Data Protection Act 2018, you have rights as an individual which you can exercise in relation to the information we hold about you.