Effective: August 2, 2019
Information You Provide Us
In connection with providing our Site and the Service, we obtain certain data, including some data that is personal information. The types of information we may collect about you include:
- If you create an Account for use of the Services, or otherwise communicate with us, your contact information, such as name, phone number, and email and postal address;
- Account information, such as username, password and other log-in details used to access the Service;
- Payment information, such as name, billing address and payment card details, including card number, expiration date and security code;
- If you consent to its collection, the geolocation of your mobile device(s) used to access the service through any mobile applications we make available for the Service;
- Information you enter or submit into Projects;
- Other personal information contained in Content you submit to us through the Service, or otherwise, such as through our “Contact Us” feature or customer support tools on our Site or in the Service.
Information We Collect Through Automated Technologies About Your Interaction With Our Site and the Service
We may use automated technologies, including cookies, web server logs, web beacons and other technologies, to collect information about your interaction with our Site and the Service. We may use these automated technologies to collect information about your devices, browsing actions, and usage patterns. For example, when you use our Service, we may use analytics technologies to retrieve information from your browser, including the site you came from, the search engine(s) and the keywords you used to find our site, the pages you view within our site, your browser add-ons, and your browser’s width and height. We may also use technologies, such as cookies, pixels and web beacons, to collect information about the pages you view, the links you click, and other actions you take on our sites and services. Additionally, we collect certain standard information that your browser sends to every website you visit, such as your IP address, browser type and language, access times, and referring Web site addresses. When using a mobile application, we may use automated technologies to collect information relating to your device, including your device IP address, device identifiers, the type and characteristics of your device, and language preferences.
We also use third-party analytics tools (such as Google Analytics on the Service) to assist us with analyzing and improving our Service. For more information about how your information is collected, used and protected in connection with our implementation of Google Analytics (including information on how you may opt-out of sharing your information or control how your information is shared), please visit http://www.google.com/policies/privacy/partners/.
You may be able to control the settings of your device or browser to stop accepting all or certain types of cookies, or to prompt you before accepting a cookie from the websites you visit. If you set your device or browser to reject cookies, parts of our Sites may not work for you. Please note, depending on your type of device or browser, it may not be possible to delete or disable all tracking mechanisms on your device. Your selection of the “Do Not Track” option provided by your device or browser may not have any effect on our collection of cookie information for analytic and internal purposes. The only way to completely “opt out” of the collection of any information through cookies or other tracking technology is to actively manage the settings on your device and/or browser to delete and disable cookies and other tracking/recording tools. (To learn more about cookies, beacons and related tracking technologies, visit http://www.allaboutcookies.org).
We will use your personal information, and may share your personal information with other parties acting on our behalf, for one or more of the following of our legitimate business interests:
- to conduct research about the use of our website;
- to improve services provided by UPG;
- to assess and respond to any inquiry or complaint you might make to us;
- for our own administrative purposes, including training our staff, conducting internal audits, improving our services or engaging in the sale, purchase or investment in the business;
- to provide the Service or otherwise perform our agreements with you;
- for market research purposes;
- to make informed decisions about business relationships and to prevent inadvertent engagement in illegal or corrupt practices;
- to conduct investigations of suspicious or harmful activity;
- to comply with UPG’s regulatory and legal obligations;
- to manage risks related to UPG’s contracts and services;
- for marketing purposes;
- to prevent or detect fraud or abuses of our website or systems; and
- for our other legitimate business interests.
We may use service providers to perform some of these functions. Those service providers are restricted from sharing your information for any other purpose, and are required to provide the same level of protection to your information that we provide and complies with applicable data protection laws.
We also may use the personal information we collect about you in other ways for which we provide specific notice at the time of collection and obtain your consent if required by applicable data protection law.
If we wish to use your personal information for a purpose beyond that for which it was originally collected, we will ask for your consent or seek to rely on another valid legal ground to process your personal information in accordance with the applicable law. UPG does not sell personal information to others.
We may hire other companies to provide limited services on our behalf, such as handling the processing and delivery of mailings, providing customer support, hosting the Site and the Service, processing transactions and payments, or performing statistical analysis of the Site and Service by you and other users. We also may share personal information with our business partners with whom we jointly offer products and services.
Those service providers and business partners with whom we share your information will be permitted to obtain only the personal information they need to deliver the services they perform for us. They are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose. However, some of our third-party vendors may use anonymized aggregate data to improve their services. For example, with regard to credit card processing services, our fraud detection vendors may use aggregate data to help them more accurately detect fraudulent uses of credit cards.
We may also share or disclose your personal information, including the content of your communications:
- to comply with the law or legal process (such as a subpoena), or to respond to lawful requests of government agencies;
- to establish, exercise or defend our legal rights;
- in connection with an investigation of suspected or actual illegal activity;
- to protect the rights or property of UPG or our customers, including the enforcement of our agreements or policies governing your use of the Service;
- acting on a good faith belief that such access or disclosure is necessary to protect the personal safety of our employees, customers, or the public;
- otherwise with your consent.
When you enter information into Projects, it may be viewed, edited, modified, and/or deleted by other users who have been invited to share such Projects (subject to the access and use privileges for a Project established by its creator).
We may transfer, access, or store personal information about you outside of the European Economic Area (“EEA”), Switzerland, or another country that requires legal protections for international data transfer. When we do, we will ensure that an adequate level of protection is provided for the information by using one or more of the following approaches:
- We may transfer personal information to countries that have privacy laws that have been recognized by the country from which the data are transferred as providing similar protections for the data (i.e, an “adequacy determination”).
- We may enter into written agreements with processors, subprocessors and other recipients that require them to provide an adequate level of protection for the data.
- We may rely on other transfer mechanisms approved by authorities in the country from which the data are transferred.
The European General Data Protection Regulation (“GDPR”) provides residents of EU member states with certain rights discussed below. EU residents may contact us as provided below regarding any of these rights and we will respond within a reasonable period of time, and within any period of time period prescribed by law. Persons exercising these rights will be required to submit a proof of identity. We will honor the requests you make related to your rights as the law allows, which means in some cases there may be legal or other official reasons that we may not be able to address the specific request you make related to your rights.
If you are a resident of the EU, you have the right to:
- Obtain a copy of your personal information. You have the right to obtain a copy of the personal information we hold about you by contacting us as directed above.
- Correct your personal information. You may request that we correct any inaccurate and/or complete any incomplete personal information by contacting us as directed above. If we disagree and believe the information to be accurate and complete, we will advise you and include a notation on the record that you dispute the information’s accuracy.
- Withdraw your consent to processing. You may, as permitted by law, withdraw your consent to the processing of your personal information at any time by contacting us as directed above. Such withdrawal will not affect the lawfulness of processing based on your previous consent.
- Object to processing. You may, as permitted by law, request that we stop processing your personal information by contacting us as directed above.
- Erasure. You may request that we erase your personal information by contacting us as directed above. We will comply, unless there is a lawful reason for not doing so.
- Lodge a complaint. We suggest that you first contact us as provided below regarding any questions or complaints in relation to your rights or how we process your personal information.
UPG uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run our services. Although UPG owns the code, databases, and all rights to the UPG applications, you retain all rights to your data.
We will keep personal information about you for as long as you maintain an account for use of the Service, as long as you work for or with us, or as long as we are addressing a concern, question, complaint, or request you have made to us, as applicable to our interactions with you. If we have a written contract or other agreement with you, we will follow the retention obligations of that agreement.
We may keep data longer if we have a legal obligation to keep it or to maintain necessary records for legal, financial, compliance, or other reporting obligations, and to enforce our rights and agreements. We also may keep data about you for statistical analysis or research purposes.
We take appropriate security measures to protect personal information against loss, misuse, and unauthorized access, alteration, disclosure or destruction. We also have implemented measures to maintain the ongoing confidentiality, integrity and availability of the systems and services that process personal information, and will restore the availability and access to data in a timely manner in the event of a physical or technical incident.
Our Site and the Service are intended for a general audience and are not directed at individuals under the age of majority. We do not knowingly collect information from children or other individuals who are not legally able to contract with us. If we obtain actual knowledge that we have collected information from a child, we will promptly delete it, unless we are legally obligated to retain such data. If you believe that we have mistakenly or unintentionally collected information from a child, please contact us as provided below.
UPG may periodically update this policy. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your UPG service primary account holder account or by placing a prominent notice on our site. You retain the right to access, amend, correct or delete your personal information where it is inaccurate at any time. To do so, please contact [email protected].