At Citizens Reserve, Inc. dba/ “Suku”, we respect your privacy and are committed to protecting it.
This privacy notice has been drafted to explain how Suku collects, uses, discloses, and protects information that we collect about you and your rights concerning that information.
This notice covers information we collect from or about you when you give it to us, use our Platform through our website, or interact with our advertisements. It also covers information that we may receive from other persons or companies who have received your information and can share it with us.
If, in any case, our privacy practices differ from those explained in this notice, we will let you know at the time we ask for or collect your information.
We may collect the following types of information about you, which we have grouped together as follows:
Some of the information we collect about you may be personal information, or personal data, that can be used to identify you including, for example, your name, email address, mailing address or delivery address. In some jurisdictions, certain unique identifiers like IP addresses and other usage or technical information may be considered personal information. Personal information does not include data where your identity has been removed so that we can no longer identify you (anonymous data), which we may use for any purpose.
The Platform is not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on the Platform. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on the Platform or through any of its features, use any of the interactive or public comment features of the Platform, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at support@suku.world.
We collect information from and about you in the following ways:
When you provide it to us. You may give us information about you by filling in forms or by communicating with us by email or otherwise. This includes information you provide when you register for an account, subscribe to one of our communications, enroll in a loyalty program, place an order, participate in one of our events, write a review, or when you otherwise contact us about our Platform, products, or services.
From our Platform and emails. As you interact with our Platform and use our cookies, or our emails, we may automatically collect Technical Information about your equipment, browsing actions and patterns. We collect this information by using cookies, server logs, web beacons, and other similar technologies. Our Cookies and automatic data collection technologies section contains more information and options to control or opt-out of certain data collection or uses.
From others. We may receive information about you from third parties including, for example, our affiliated companies, business partners, subcontractors, analytics providers, and service providers. We may also receive information about you from commercially available sources such as data aggregators and public databases.
The Platform uses automatic data collection technologies to distinguish you from other Platform users. This helps us deliver a better and more personalized service when you use the Platform. It also allows us to improve the Platform by enabling us to:
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). For more information, see the Interest-based advertising section of this privacy notice.
The technologies we use for this automatic data collection may include:
We may use Google Analytics to provide certain analytics services for us. More information about Google Analytics can be found in the Google Analytics Terms of Use and the Google Analytics Privacy Policy We do not respond to or honor “do not track” (a/k/a DNT) signals or similar mechanisms transmitted by web browsers.
We may use your information to conduct our business operations, including for the following purposes:
We may use information that is not personal information for any purpose. For example, we may aggregate usage data from many people in a way that does not identify any individuals to calculate the percentage of users accessing a feature on the Platform.
We may share non-personal information without restriction. We may share your personal information with:
We may also disclose your personal information:
We may also use your information to contact you about our own and third parties’ products and services that may interest you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile or opt out as directed when you receive such an email from us. For more information, see Your rights and choices.
Some content or applications on the Platform, including advertisements, are served by third parties, including advertisers, ad networks, servers, content partners, or application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Platform. The information they collect may be associated with your personal information, or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. Our partners may use non-cookie technologies on which browser settings that block cookies might have no effect. Your browser may not permit you to block such technologies.
For this reason, keep in mind that you can block the collection and use of information related to you by advertising companies to serve interest-based advertising by visiting the following self-regulatory programs of which those companies are members:
Some content or applications on our websites may be served by third parties, content providers, and application providers, including the following:
Your rights may vary depending on where you are located. We have created mechanisms to provide you with the following control over your information.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Platform. Any transmission of personal information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Platform.
The California Consumer Privacy Act of 2018 (“CCPA”) The requires us to provide the following notice to California residents. This notice does not apply to employment-related information of California-based employees, job applicants, contractors, or similar individuals. Where noted in this notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B information”) from some of its requirements.
The information we have collected about California residents in the last 12 months is described in What information we collect above. That information corresponds with the following categories of personal information under the CCPA.
A. Identifiers.
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
YES
Category
Examples
Collected
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
NO
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
NO
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
YES
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
NO
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
YES
G. Geolocation data.
Physical location or movements.
NO
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
NO
I. Professional or employment-related information.
Current or past job history or performance evaluations.
NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
NO
K. Inferences drawn from other personal information.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
NO
In the last 12 months, we have collected personal information from the sources described in How we collect your information above.
In the last 12 months, we have used your personal information for the business and commercial purposes described in How we use your information above.
The business and commercial purposes that we have shared your personal information in the last 12 months are described above in Disclosure of your information. More specific information on that sharing is as follows:
Sharing your personal information for business purposes. We have shared the following categories of personal information with our affiliated companies, service providers and public or government (including enforcement) authorities for our business purposes:
Category A: Identifiers. We are collecting your email address as a unique identifier for your unique log-in. The email address may be used to send you information about upcoming or other activity on the platform.
Category F: Internet or other similar network activity. Each of your transactions are recorded on the platform, and each transaction can be viewed by other platform users. Additionally, the transaction information is being recorded on a distributed ledger, which is publically available.
As described above, examples of business purposes include performing transactions, registering accounts, managing our relationship with you, and monitoring for security threats and fraud.
Sharing your personal information for commercial or other purposes: We have not shared any of your personal information with business partners and other third parties in a manner that is likely to be considered to be a “sale” under the CCPA.
As described above, this information may be shared for personalization, analytics, marketing, retargeting, and sales. We do not sell the personal information of consumers who are younger than 18 years of age.
You have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your personal information over the past 12 months. Once we verify your request, we will disclose to you:
We do not provide access rights to B2B information.
At CRI’s sole discretion, it may require you to submit any disputes arising from the use of these Terms or the Services, including disputes arising from or concerning their interpretation, violation, invalidity, non-performance, or termination, to final and binding arbitration under the Rules of Arbitration of the American Arbitration Association applying the laws of the State of California.
You further agree that you will resolve any disputes on an individual basis, and that any claims brought under these Terms or in connection with the Services must be brought in your individual capacity, and not as a plaintiff or class member in any purported class, collective, or representative proceeding. You further agree that you will not participate in any class action (existing or future) brought by any third party arising under these Terms or in connection with the Services. If any court or arbitrator determines that the class action waiver set forth in this paragraph is void or unenforceable for any reason or that an arbitration can proceed on a class basis, then such class action is not subject to arbitration and must be litigated in state or federal court in Santa Clara County in the State of California.
You have a right to obtain a copy of the specific pieces of personal information we collected about you (also called a data portability request). Once we verify your request, we will provide you a copy of your personal information that is responsive to your request. We do not provide portability rights to B2B information.
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we verify your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We do not provide deletion rights to B2B information.
We may share information with third parties in a way that is considered a “sale” under the CCPA. Where that is the case, we will comply with California “Do Not Sell” requirements.
To exercise your right to know, right to obtain a copy, or right to delete your personal information as described above, please submit your request to us by either: Contacting us at support@suku.world.
To exercise the right to opt out of sale of your personal information, you can submit a request to us by visiting the following link: Do Not Sell My Personal Information.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by visiting the following link: Opt-in to Sales of My Personal Information.
Before fulfilling your request, we take steps to verify you are who you say you are or that you have authority to act upon someone else’s behalf. Therefore, upon receipt of your request, we will request additional information that we need to verify you and, if you are submitting a request on behalf of someone else, to verify that you are permitted to act on that person’s behalf.
When we contact you to request verification information, please respond and provide the information that we have requested. Depending on the nature of the request you make, we may require you to verify your identity to either a reasonable degree of certainty or high degree of certainty. This may mean that we need to match two or three pieces of information that we hold about you with the information you provide. In some cases, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request or that you are authorized to make the request on behalf of someone else.
In addition to providing the information we need to verify you or your authority, you must provide us with enough information to understand, evaluate, and respond to your request. We cannot respond to your request or provide you with personal information if we cannot confirm the personal information relates to you.
We will only use personal information provided in a verifiable consumer request to verify your identity or authority to make the request and to locate relevant information. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and to understand, evaluate, and respond to your request. We cannot delete personal information in those situations where our retention is required for our own internal business purposes or otherwise permitted by the CCPA (such as fraud prevention or legal compliance). In these situations, we will retain your information in accordance with our records retention program and securely delete it at the end of the retention period.
Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may also make request on behalf of your minor child. You may designate an authorized agent to make a request on your behalf by registering such person or entity with the California Secretary of State.
You may make a CCPA consumer request twice within a 12-month period.
We make every attempt to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. When you request a copy of your personal information, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity easily.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. You have a right not to receive discriminatory treatment by us for exercising your privacy rights.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@suku.world.
NEVADA PRIVACY RIGHTS Nevada residents have the right to opt out of the sale of certain “covered information” collected by operators of websites or online services. We currently do not sell covered information, as “sale” is defined by such law, and we do not have plans to sell this information.
14. GDPR privacy rights This GDPR Privacy Notice is a supplement to our Privacy Policy and concerns certain personal data we have collected about residents of the countries in the European Union, consisting of the European Economic Area, Switzerland, and to the extent that the United Kingdom is no longer a member of the European Union, the United Kingdom (the “EU” or the “European Union”). It explains why we have that information, how we use and handle it, and your rights to that information, all as required by the European Union’s General Data Protection Regulation (“GDPR”).
Data You Provide to Us. We may collect your personal contact information such as name, email address, phone number, and country of residence, and financial account information in order to process payment for your purchases.
Data from Others. We may receive personal data about you from our vendors or affiliates, such as your personal contact information (name, home or business address, email address, phone number, and country of residence), in the context of providing to servicing and support to our customers.
We collect your personal data when you ask us to contact you or when you place an order for our products and services. Your failure to provide this information means we cannot fulfill your request. We may also collect your contact information when you provide it by using our Website, as well as your IP address and other information about your activity on our Website, such as what pages you visit. We may also receive personal data when we are working on the resolution of our customer's problems.
Our lawful basis for holding your information depends on the circumstances under which we acquired it:
Type of Information
Lawful Basis for Processing
Customer and prospective customer contact information collected in connection with an order or an inquiry
For fulfillment of a contract
Customer and prospective customer contact information collected for use in marketing additional products and services
Consent or Legitimate Interest
Personal data of our customers’ customers collected for use in filling orders for our products and services
For fulfillment of a contract
We use your details so that we can communicate with you by email or phone and inform you of our services, the status of your order, or questions about payment of your invoice. We may also collect your IP address and details concerning your activity while on our Website in order to understand your interests and preferences. The personal data we hold is stored and processed securely in line with the information security measures and guidance standard in our industry. We have implemented appropriate technical and organizational measures designed to prevent the unauthorized disclosure of your personal data, taking into account the level of risk associated with the processing of your personal data. If we receive your personal data in the context of providing problem solving services to our customers, we will securely accept that data, segregate it from other customer data, and limit access to the data. We will delete the data once the issue is resolved.
Your personal data may be transferred to and stored at our servers located in the United States. The United States has personal data privacy laws that are different from your country. While the United States has not received an adequacy decision from the European Union Commission, we will ensure that it is protected in a manner that is consistent with how your personal data is protected if it was processed in your country. What we don’t do with your personal data.
We do not pass your information to anyone else apart from our business services partners as necessary to provide you with the products and services you have requested. We do not use any automated systems relating to your personal data. We do not use your information for profiling.
We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law or we have obtained your consent.
You have the following rights concerning your personal data that we hold and process that you can exercise at any time:
We may use information that is not personal information for any purpose. For example, we may aggregate usage data from many people in a way that does not identify any individuals to calculate the percentage of users accessing a feature on the Platform.
We may share non-personal information without restriction. We may share your personal information with:
All of the above requests will be forwarded to other parties holding and processing your personal data where appropriate.
Please contact our Privacy Officer at [support@suku.world].
If you wish to raise a complaint on how we handle your personal data, you can contact our Privacy Officer as follows:
By Email: support@suku.world
By Mail: 2840 Blake St., Apt 540, Denver, CO, 80205, US
Attention: Privacy Officer
We will post any changes we may make to our privacy notice on this page. If the changes materially alter how we use or treat your information, we will notify you by email to the primary email address specified in your account (if you have an account with us), and/or through a notice on the Platform. The date the privacy notice was last revised is identified at the top of the page. You are responsible for ensuring that we have an up-to-date email address for you and for periodically visiting the Platform and this page to check for any changes.
If you have any comments or questions about our privacy notice, please use our Help page to reach out to us at (650) 838-4434.
