SADNUGG

Privacy Policy

Effective Date: August 26, 2026

Contents

1. Introduction 2. Information We Collect 3. How We Collect Information 4. How We Use Your Information 5. Legal Basis for Processing 6. Cookies and Similar Technologies 7. Sharing and Disclosure 8. International Data Transfers 9. Data Retention 10. Your Privacy Rights 11. Privacy for Children 12. Security of Your Information 13. Third-Party Services 14. Data Breach Notification 15. Automated Decision Making 16. Links to Other Websites 17. Changes to This Privacy Policy 18. Contact Information

1. Introduction

We at Sad Nuggie Ltd. respect your privacy and are committed to protecting the personal information you share with us. This policy explains what information we collect, why we collect it, and the choices you have about how it is used. It applies to this website and to all of the computer systems design services we provide to our clients.

The services described in this policy are developed and operated by the developer SadNugg on behalf of Sad Nuggie Ltd., a company registered at 189 Front St W, Strathroy - N7G 1Y3, Canada (CA). By using this website or engaging our services, you agree to the practices described in this document. Please read it carefully and contact us if anything is unclear. We are always happy to explain our practices in plain language.

This policy is written to be read and understood by ordinary people, not just by lawyers. Where technical terms appear, we explain them in everyday words so that you can make informed decisions about your information. If you would like a printed copy of this policy, or if you would prefer to discuss it over the telephone, our contact details are listed in the final section of this page.

2. Information We Collect

Personal information means any data that can identify you as an individual. We collect a limited set of personal information so that we can provide our services, respond to your questions, and keep our business running smoothly. This includes your name, your email address, your telephone number, and the name of the company you represent when you contact us through our website form.

When you engage us for a project, we may also collect billing details, project preferences, and technical information about the systems you ask us to design or maintain. We do not collect sensitive categories of personal data unless it is strictly necessary for the work you request, and we will never collect more than we need. Everything we gather has a purpose that we can explain to you at any time.

3. How We Collect Information

We collect information in three ways. First, you give it to us directly when you fill out a contact form, send an email, or speak to us on the telephone. Second, we collect limited technical information automatically when you visit this website, such as your internet protocol address, browser type, and the pages you view. Third, we may receive information from business partners who refer you to us, always with your consent where the law requires it.

Each of these sources serves a clear purpose, and we never gather information for the sake of gathering it. We treat every piece of information with the same discipline we apply to the systems we build: it is collected deliberately, protected carefully, and used only where it adds genuine value to you or to our work together.

4. How We Use Your Information

We use the information we collect to respond to your inquiries, prepare proposals, and deliver the computer systems design services you request. Your contact details also allow us to send you important updates about your projects, scheduled maintenance windows, or changes to our policies. Where you have asked to receive occasional news or insights, we use your email address for that purpose, and you can opt out at any time with a single click.

We never sell your personal information, and we do not use it for purposes you would not reasonably expect. Aggregated and anonymised statistics may be used to improve our website and the quality of our services. These statistics cannot identify you as an individual. If a new purpose for your information ever arises, we will ask for your consent first or provide you with a clear notice and the chance to object.

We also use contact information to keep our own records accurate, to manage our accounts, and to meet our obligations under tax and business law. In every case, the way we use your information is proportionate to the task at hand, and we never combine data from different purposes in ways that would surprise you.

5. Legal Basis for Processing

Our processing of your personal information is grounded in recognised legal bases under applicable data protection law. We process information to perform a contract with you, to take steps you request before entering into a contract, to comply with legal obligations, and to pursue our legitimate interests in operating a professional services business. Where we rely on consent, we ask for it clearly, and you can withdraw it at any time without penalty.

If you have questions about which basis applies to a particular activity, please write to us and we will explain our reasoning in plain terms. We keep records of our processing decisions so that our practices remain transparent and auditable. You never have to wonder why we hold a piece of information, because we can always tell you.

6. Cookies and Similar Technologies

This website uses a small number of cookies and similar technologies to remember your preferences and to understand how visitors use the site. Functional cookies keep the website working smoothly and remember choices you make. Analytics cookies help us see which pages are useful, so that we can improve the experience for everyone. We do not use advertising cookies, and we do not build profiles of visitors for advertising purposes.

You can disable cookies in your browser settings at any time, although some parts of the website may not work as well without them. Where changes to our use of cookies are significant, we will inform you before the change takes effect. Our cookie practices are reviewed regularly to keep them simple, honest, and aligned with your expectations.

7. Sharing and Disclosure

We do not sell, rent, or trade your personal information to anyone. We share information only with trusted service providers who help us operate our business, such as hosting providers, email services, and payment processors, and only to the extent needed for them to perform their role. Every provider is bound by a written agreement that requires them to protect your information to the same standard we do.

We may disclose personal information when the law requires it, such as in response to a lawful court order or a request from a recognised regulator. If our business is ever reorganised or transferred to a new owner, we will require that new owner to honour the promises in this policy. Sharing remains the exception rather than the rule, and we would always rather hold your information than pass it along.

8. International Data Transfers

Sad Nuggie Ltd. is based in Canada, and our primary processing facilities are located in Canada. Some of the tools we use, such as analytics and email services, are operated by providers whose servers sit in other countries, including the United States and the European Union. When we transfer personal information across borders, we rely on appropriate safeguards, including standard contractual clauses and adequacy decisions where they are available.

Your information may therefore be stored and processed in countries where data protection laws differ from your own. We take reasonable and documented steps to ensure that the same level of protection travels with your information, wherever it goes. If you would like details of the safeguards in place for a particular transfer, we are glad to share them with you.

Before engaging a provider whose servers are located abroad, we review its security posture, its published data protection commitments, and any relevant certifications. This review is part of our ordinary vendor selection process, and it applies to every tool we use that handles personal information.

9. Data Retention

We keep personal information only for as long as it is needed for the purposes described in this policy. Inquiries are typically retained for twenty-four months so that we can follow up on ongoing conversations and refer back to what was discussed. Records related to active projects are kept for the duration of the engagement, and then for the period required by applicable tax and accounting law, which is usually seven years after the end of the project.

When information is no longer needed, we delete it securely or anonymise it so that it can no longer identify you. Our retention schedules are reviewed on a regular basis and updated whenever the law changes. We would always rather delete data too early than hold it too long, because holding information you do not need is a burden on everyone.

10. Your Privacy Rights

You have rights over the personal information we hold about you. Depending on where you live, these may include the right to access your information, correct inaccurate information, request deletion, restrict processing, object to processing, and receive a portable copy of your information. These rights help you stay in control of how businesses handle your personal data.

To exercise any of these rights, contact us at serve@sadnugg.hair, and we will respond within the time frame required by law, usually thirty days. We may ask you to verify your identity before acting on your request, which protects your information from unauthorised access. You also have the right to lodge a complaint with your local data protection authority if you are unhappy with how we have handled your request or your information.

You can exercise many of these rights informally and at no cost. You are never required to use a particular form, and you may withdraw a request at any time. If we need more information to process your request, we will tell you exactly what we need and why, so that the process stays clear and straightforward for you.

11. Privacy for Children

This website and our services are directed at adults and are not designed for children under the age of sixteen. We do not knowingly collect personal information from children. If you believe that a child has provided us with personal information without parental consent, please contact us immediately, and we will delete that information from our records without undue delay.

When a business client works with us on a project that touches the information of minors, we rely on that client to comply with its own obligations under applicable law, including the requirements of parental consent and age verification. We encourage parents and guardians to take an active role in supervising the online activity of young people and to speak with them about sharing information responsibly.

12. Security of Your Information

We take the security of your information seriously. We use encryption in transit, secure storage for information at rest, and access controls that limit information to the staff members who genuinely need it to do their work. Regular reviews of our security practices keep our defences current, and our team is trained on careful data handling as part of their professional discipline.

We apply the same security standards in our own operations that we recommend to our clients in their systems. No method of transmission or storage is completely infallible, so we cannot guarantee absolute security, but we work hard to keep risks low and to act quickly if a concern is identified. Protecting your trust is part of the service we provide, not an afterthought.

13. Third-Party Services

This website may include links to third-party services and tools that we use to operate, such as email platforms, analytics, and document services. Those third parties have their own privacy policies, and we encourage you to read them before you share any information with them. When you click a link that takes you away from our website, our policy no longer applies to that destination.

We review the providers we work with to confirm that they maintain appropriate privacy and security measures. We do not accept responsibility for the practices of third parties outside our control, and we recommend that you apply the same care to their websites that you apply to ours. A cautious approach to sharing information online is always a good idea.

14. Data Breach Notification

In the unlikely event of a data breach affecting your personal information, we will act quickly and responsibly. We will investigate the cause, contain the impact, and assess which records may have been affected. Our incident response plan is tested regularly so that our team knows exactly what to do and who to tell.

If there is a real risk of harm to you, we will notify you without undue delay and provide clear guidance on what happened, what we are doing about it, and what you can do to protect yourself. We will also report the breach to the relevant supervisory authority if the law requires it. Honest and timely communication is part of how we earn and keep your trust.

15. Automated Decision Making

We do not use your personal information for automated decision making that produces legal effects or similarly significant outcomes. Where we use simple automation, such as automatic email replies or scheduling reminders, it supports a human process rather than replacing one. A person remains involved in every meaningful decision about your project and your information.

If we ever introduce automated decision making that could significantly affect you, we will update this policy, explain the logic involved in plain language, and give you the opportunity to request human review. We believe that important decisions about people should always involve a person, and we have designed our processes around that belief.

16. Links to Other Websites

Our website may contain links to websites operated by other organisations, including our clients and business partners. Once you leave our website, the information you provide on those websites is governed by their own privacy policies, not by ours. We recommend that you read the privacy policy of every website you visit before you share any personal information.

We have no control over the content, security, or practices of external websites, and we accept no responsibility for them. A link to another website does not mean that we endorse its content or the way it handles personal information. We will always give you a clear indication when you are leaving our website and entering a space outside our control.

17. Changes to This Privacy Policy

We may update this privacy policy from time to time to reflect changes in our services, our technology, or the law. When we make significant changes, we will update the effective date at the top of this page and, where appropriate, notify you by email or through a notice on our website. We encourage you to review this page periodically so that you stay informed about how we protect your information.

Continued use of our website or services after a change takes effect means that you accept the updated policy. Earlier versions of this policy are available on request, so you can always compare what has changed. If we ever intend to use your information in a way that is materially different from what this policy describes, we will ask for your consent before doing so.

18. Contact Information

If you have any questions, concerns, or requests relating to this privacy policy or to your personal information, please reach out to us. You can email us at serve@sadnugg.hair, call us at +17128542815, or write to our office at Sad Nuggie Ltd., 189 Front St W, Strathroy - N7G 1Y3, Canada (CA). Our privacy team will respond to you promptly and will do our best to resolve any issue you raise.

We value your trust and we treat every question seriously. If we cannot resolve your concern to your satisfaction, you have the right to complain to the data protection authority where you live. We would always prefer to solve a problem together, so please contact us first and give us the chance to make things right.

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