Privacy Notice

SurgeU takes your privacy seriously. The following privacy notice is intended to provide you (meaning any of our actual or potential students, suppliers, individuals that browse our websites and individuals outside our organization with whom we interact) detailed information about the privacy of your information and how it's secured on SurgeU.com and our community site at community.SurgeU.com and our App (the "Site(s) and the Service") and any other websites owned and operated by Oxlo’s Inc. dba SurgeU (together "We" and "Us") and sets out how we collect and process your personal information. This privacy notice also provides certain information that is legally required and lists your rights in relation to your personal information. Personal information is information that identifies an individual. This Privacy Notice is not intended to apply to personal information collected during the recruitment of employees, for which there is a separate privacy notice.

We reserve the right to change this Privacy Notice at any time. Such changes, modifications, additions, or deletions shall be effectively immediately upon notice thereof, which may be given by means including, but not limited to, issuing an email to the email address listed by registered users, and posting the revised Notice on this page. You acknowledge and agree that it is your responsibility to maintain a valid email address as a registered user, review this site and this Notice periodically and to be aware of any modifications.

Further, each time you use our Site(s) and/or the Service you acknowledge our processing of your information as set forth in this Privacy Notice now and as amended by us. "Processing" means using cookies on a computer or using information in any way, including, but not limited to, collecting, storing, deleting, using, combining, and disclosing information, all of which activities will take place in the United States.

SurgeU and our service providers may be, located in the United States. You acknowledge that if you reside outside the U.S., your personally identifiable information will be transferred to the U.S. and processed and stored there under U.S. privacy standards. Each time you utilize the Site(s) and /or the Service and are providing information to us, you acknowledge such transfer to, and processing in, the U.S. and you acknowledge that the governments, courts or law enforcement or regulatory agencies in the U.S. may be able to obtain disclosure of that personal information through U.S. laws.

If you have any questions or comments about this Privacy Notice or our use of your personally identifiable information, please contact us at [email protected] or by calling us at (833) 867-8743.

Why do we gather information?

We gather, use, and disclose information that allows us to: provide and administer the products and services that you request and enrolling you in programs you request and communicating with you about your use of our products and services; provide you the optimal experience with the Site(s) and the Service and to help us better understand what products and services you're most interested in.

We also collect your personal information to communicate with you and to manage your User account if you have one. To do this, we collect information that helps us understand your needs and preferences.

We will only use or disclose your personal information for the purposes set out in this notice and as otherwise authorized or required by law.

What type of information do we collect and how is it used?

Consumer Information

The contact information we collect comes directly from you.

• A first and last name.
• A home or other physical address, including, street name and name of a city or town.
• An e-mail address.
• A telephone or cellphone/mobile number.
• Information collected via “cookies.” See below concerning your use of our web site and online services.

We may collect this information when you register in our community at SurgeU.com, complete a SurgeU Membership registration form, sign-up for any Class, purchase audio or video content from us, or fill out any other form on any of the Site(s) or through the Service or provide such information to one of our Enrollment Specialists or Instructors. We may also collect information that you provide about others, such as through a refer-a-friend program or on a friend/spouse who may be attending a class or workshop with you.

If you provide information to us about someone else you must ensure that you are entitled to disclose that information to us and that, without our taking any further steps, we may collect, use, and disclose that information as described in this notice. You must also ensure the individual concerned is aware of the various matters detailed in this privacy notice, as those matters relate to that individual, including our identity, how to contact us, the way in which we collect and use personal information and our personal information disclosure practices, that individual's right to obtain access to the personal information and make complaints about the handling of the personal information and the consequences if the personal information is not provided.

We may use your contact information to provide you information about our products, special offers from our marketing alliances, newsletters, updates about our company (including changes to our privacy policy) and other communications we think may be of value to you.

If you provide us with your postal address, you may receive periodic mailings from us with information on new products and services or upcoming events. If you do not wish to receive such mailings, please let us know by sending us an email at [email protected] or by calling us (833)867-8743.

Except as specified for the efficiency of use of the community site at student.SurgeU.com, when you initially provide your contact information to us you will be given the choice of receiving periodic email communications from us or opting out of email communications. If you initially consented to receiving emails from us but would now like to change your preference, please let us know by sending us an email at [email protected] or by calling us at (833) 867-8743.

Persons who supply us with their telephone numbers may receive telephone contact from us with information regarding new products and services or upcoming events. If you do not wish to receive phone calls or texts from us in the future, please let us know by sending us an email at [email protected] or by calling us (833) 867-8743

What is our legal basis?

It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you and we have a legitimate interest in the providing goods and services to you.

We also have a legitimate interest in promoting our business and using your personal information in such a way to ensure that we provide the very best customer service we can to you.

Fulfillment of services.

We collect and maintain personal information that is voluntarily submitted to us during the use of the Sites and/or our Services. We use the contact details which are provided to us so that we can fulfil the supply of services which have been ordered from our Sites. We will use contact information to send you service-related communications relating to these orders. This includes your purchase of services, your attendance at events hosted by us and the processing of returns and refunds. We do not store your payment details and all payments you make to us are done via our suppliers of payment processing services.

What is our legal basis?

It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you.

Business administration and legal compliance.

We use your personal information for the following business administration and legal compliance purposes:

• to comply with our legal obligations;
• to protect our business and your accounts from fraud and other illegal activities
• to enforce our legal rights;
• protect rights of third parties; and
• in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.

What is our legal basis?

Where we use your personal information in connection with a business transition, enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.

"Cookies" and Log Data. A "cookie" is a small data text-file that is placed onto the memory of your browser. We use cookies to personalize information provided to you directly and on the Site(s) and through the Service and to record your visits to the Site(s) and the Service. The cookies do not store any personally identifiable data about you. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. Additionally, we may collect demographic information along with data on how you interact with the Site(s) and the Service and our emails through other tracking devices such as web beacons. The demographic and email interaction data we collect is used in aggregate to allow us to determine what content and offers our Site(s) and the Service visitors find most relevant.

When you visit the Site(s) and use the Service, our servers automatically record your activity on the Site(s) and the Service ("Log Data"). This Log Data may include information such as your IP address, browser type or the domain from which you are visiting, the webpages you visit, the search terms you use, and any advertisements on which you click. For most users accessing the Internet from an Internet service provider the IP address will be different every time you log on. We use Log Data to monitor the use of the Site(s) and the Service, and for technical administration. We do not associate your IP address with any other personally identifiable information to identify you personally, except in case of the investigation of a violation of the Terms of Use.

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other customers.

We will only use your location data for customer insight purposes where we have your consent to do so.

Do we share information collected with other third parties?

Again, we take your privacy very seriously and are committed to keeping your information safe and secure. We do not sell, license, lease or otherwise disclose your personal information to any third party for any reason except as noted earlier and as described below:

• Your personal information may be disclosed to:
  • our group companies, and affiliates or third-party processors, agents or contractors who assist in providing support for our internal operations and who may process data on our behalf to enable us to carry out our usual business practices. We will take reasonable steps to ensure that agents or contractors adhere to privacy procedures and will keep your personal information confidential;
  • our PR agency and provider of our customer feedback;
  • providers of payment services
  • relevant tax authorities in either the US or the UK (as applicable), legal and other regulators or authorities, including those who request your personal data or to report any potential or actual breach of applicable law or regulation;
  • external professional advisers such as accountants, bankers, insurers, auditors and lawyers;
  • law enforcement agencies, courts or other relevant party, to the extent necessary for the establishment, exercise or defense of legal rights;
  • third parties where necessary for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
  • third parties which are considering or have decided to acquire some or all of our assets or shares, merge with us or to whom we may transfer our business (including in the event of a reorganization, dissolution or liquidation);
  • third parties operating plugins or content (such as Facebook, Twitter, Instagram) on our website which you choose to interact with;
• Information that you give us and information about your participation in the Site(s) and the Service may be combined with other personally identifiable information (such as demographic information and past purchase history) available from our records and other sources.
• We subscribe to Google Analytics which is a web analysis service provided by Google Inc. (“Google”). This subscription allows Google to use Information about your participation in the Site(s) and the Service. Google utilizes the information collected to track and examine the use of the Site(s), to prepare reports on its activities and share them with other Google services (such as Google Remarketing and Demographics and Interest Reporting) and to contextualize and personalize the ads of its own advertising network. The aim of the tracking is to provide customized advertising that reflects your online preferences. You can opt-out of Google Analytics for Display Advertising using Google's Ads Settings or to opt-out of Google Analytics using the Opt-out Browser Add-on. Third-party vendors, including Google, may show our ads on sites across the Internet and use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on your past visits to the Site(s).

From time to time, we may use customer information for new, unanticipated uses not previously disclosed in our privacy policy. If our information practices materially change at some time in the future we will disclose the new purpose by posting the notice changes to the Site(s) and if requested providing you a copy of the revised privacy notice at the primary email address you provide to us, and we will seek your consent unless the use is authorized or required by law. Every time you use or visit the Site(s) it will be presumed that you have reviewed and accepted the then current privacy policy.

The information we collect may be disclosed when we are legally required to do so, at the request of governmental authorities conducting an investigation, to verify or enforce compliance with the policies governing our website and applicable laws, or to protect against misuse or unauthorized use of our website.

You should also be aware that when personal information is voluntarily disclosed (i.e. your name, e-mail address, etc.) in the discussion forums or other public areas on the Site(s) or Service, that information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. Such activities are beyond our control and this privacy notice does not apply to such information. Any submissions to chat rooms or other public areas on the Site(s) are accepted with the understanding that they are accessible to all third parties. If you do not want your comments to be viewed by third parties, you are advised not to make any submissions. Ultimately, you are solely responsible for maintaining the secrecy of your password and/or account information. Please be careful and responsible whenever you're online.

How do we protect and secure the information you provide to us?

This site has security measures in place to protect the loss, misuse and alteration of the information under our control. The transfer of confidential information such as credit card numbers and financial data are communicated via state of-the-art encryption. Our Web server and database reside behind a firewall in a secure datacenter with offsite backup and fire protection.

Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personally Identifiable Information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this site cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.

Does this privacy notice apply to other websites that I can link to from the SurgeU and Community websites?

Our Site(s) contains links to other websites that we do not control. This privacy notice does not apply to these linked websites. Therefore, you should review the privacy notice on each linked website. The fact that we link to a website is not an endorsement, authorization, or representation of our affiliation with that third party. We do not exercise control over third party websites.

Accuracy of your personal information

It is important that the personal information we hold about you is accurate and current and we take all reasonable precautions to ensure that this is the case but we do not undertake to check or verify the accuracy of personal information provided by you. Please keep us informed if your personal information changes during your relationship with us either by logging onto your account on the website or by contacting us. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient, or incomplete personal information that you provide to us.

How long we will store your personal information for

We will store your personal information for the time period which is appropriate in accordance with our data retention policy.

Requirements on you to provide personal information

In certain circumstances the provision of personal information by you is a requirement to comply with the law or a contract, or necessary to enter into a contract. is your choice as to whether you provide us with your personal information necessary to enter into a contract or as part of a contractual requirement. If you do not provide your personal information then the consequences of failing to do so are that we may not be able to perform to the level you expect under our contract with you e.g where we are unable to provide you with certain products or services as we do not have your full details, or where we cannot perform our contract with you at all because we rely on the personal information you provide in order to do so.

Will I be notified if there are changes to this Privacy Policy?

If changes are made to this privacy notice, these changes will be promptly posted on our Site(s) and a notice will be posted onto the SurgeU and community homepages at SurgeU.com and community.SurgeU.com informing you of such a change. We will also attempt to email notice of the change, but we are not responsible for you receiving the email. You agree to accept posting of a revised privacy notice electronically on the website as notice to you. The effective date of this privacy notice can be found at the bottom of this document.

Our Notice Towards Children

Neither the Site(s) nor the Service are directed to persons under 18. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us at [email protected]. We do not knowingly collect personally identifiable information from children under 18 without parental consent. If we become aware that a child under 18 has provided us with personal identifiable information without parental consent, we will delete such information from our files and terminate that individual's use of the Service.

Your rights in relation to your personal information

Subject to applicable law including relevant data protection laws, in addition to your ability to withdraw any consent you have given to our processing your personal information, you may have a number of rights in connection with the processing of your personal information, including:

• the right to request access to your personal information that we process or control;
• the right to request rectification of any inaccuracies in your personal information or, taking into account the purposes of our processing, to request that incomplete data is completed;
• the right to request, on legitimate grounds as specified in law: (i) erasure of your personal information that we process or control or (ii) restriction of processing of your personal information that we process or control;
• the right to object, on legitimate grounds as specified in law, to the processing of your personal information;
• the right to receive your personal information in a structured, commonly used and machine-readable format and to have your personal information transferred to another controller, to the extent applicable in law; and

Contact

Any inquiries or questions regarding this privacy notice should be directed in writing to our privacy officer at [email protected].

Last updated 8th of April 2024