Version 1. Updated on April 27, 2023

This privacy policy (the "Policy") regulates the conditions under which Hügga S.p.A. ("Hügga") processes the personal data of Users of our application (the "Platform").

In particular, through this Policy, we want to explain: who is responsible for your personal data, what personal data we collect, why we use it, in what cases we share it with third parties, and what are your rights as a data subject.

If you have any doubts or questions about the processing of your personal data or this Policy, please write to us at the following email address: [email protected].

The terms used in this Policy and not defined in quotes will have the meaning given to them in the Terms and Conditions of the Platform (the "T&C").

Who is responsible for your personal data?

The controller of personal data is the person, natural or legal, who decides on the purposes and means of the processing of personal data.

Under this Policy, the controller of your personal data is Hügga S.p.A., R.U.T. No. 77.337.638-7, with address at La Concepción 141, Office 601, Providencia commune, Metropolitan Region, Chile, and its legal representative is Mariana Cordero Blando.

What is the lawful basis for processing your personal data?

As a general rule, the lawful basis for processing your personal data will be the informed consent that you give when you expressly and in writing accept this Policy. The authorization you give us to process your personal data extends to the purposes and conditions explained in this Policy.

When we must comply with legal obligations and requirements of an authority, our lawful basis will be the legal authorization and, in such case, we do not need your consent to process the data, but we will always process them in coherence with the purpose of such legal authorization.

What personal data do we collect and process?

Personal data are those data that identify you or that, without identifying you directly, allow you to be identified.

We collect personal data that: (i) you directly provide to us, for example, when you fill out the waiting list form on our landing page, complete your registration on the Platform, self-assess, or contact us in any way; (ii) is provided to us by the third party you have chosen to carry out your registration process (e.g. Google or LinkedIn); (iii) is provided to us by your Employer; and (iv) is obtained through cookies or similar technologies (to see more information about these technologies, please review section 7 of this Policy).

The personal data we collect depends on the context of your interactions with us, the Platform, and the features you use. The types of data we process include:

Minimum data: mandatory data collected and used by Hügga when you create an Account and when you complete the Onboarding Process:

• Identification data, such as names, surnames, and date of birth.
• Contact data, such as your email address (work and/or personal).
• Educational data, such as your academic background and certifications or courses you have taken.
• Labor or professional data, such as your professional profile, current or desired position or role, industry to which you belong, name of the company you work for), area of interest for work, interests related to the use of the Platform, among others.