5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and
store your information.
We may use cookies and similar tracking technologies (like web beacons
and pixels) to access or store information. Specific information about how
we use such technologies and how you can refuse certain cookies is set out
in our Cookie Notice:
https://upmoni.com/cookie-policy.
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our Services using a social
media account, we may have access to certain information about you.
Our Services offer you the ability to register and log in using your
third-party social media account details (like your Facebook or Twitter
logins). Where you choose to do this, we will receive certain profile
information about you from your social media provider. The profile
information we receive may vary depending on the social media provider
concerned, but will often include your name, email address, friends list,
and profile picture, as well as other information you choose to make
public on such a social media platform.
We will use the information we receive only for the purposes that are
described in this privacy notice or that are otherwise made clear to you
on the relevant Services. Please note that we do not control, and are not
responsible for, other uses of your personal information by your
third-party social media provider. We recommend that you review their
privacy notice to understand how they collect, use, and share your
personal information, and how you can set your privacy preferences on
their sites and apps.
7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other
than your own.
Our servers are located in
the
United States. If you are accessing our Services from outside
the
United States, please be aware that your information may be transferred to, stored, and
processed by us in our facilities and by those third parties with whom we may
share your personal information (see "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"
above), in
the
United States, and other countries.
If you are a resident in the European Economic Area (EEA) or United
Kingdom (UK), then these countries may not necessarily have data
protection laws or other similar laws as comprehensive as those in your
country. However, we will take all necessary measures to protect your
personal information in accordance with this privacy notice and applicable
law.
European Commission's Standard Contractual Clauses:
We have implemented measures to protect your personal information,
including by using the European Commission's Standard Contractual Clauses
for transfers of personal information between our group companies and
between us and our third-party providers. These clauses require all
recipients to protect all personal information that they process
originating from the EEA or UK in accordance with European data protection
laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party
service providers and partners and further details can be provided upon
request.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to
fulfill
the purposes outlined in this privacy notice unless otherwise required
by law.
We will only keep your personal information for as long as it is
necessary for the purposes set out in this privacy notice, unless a longer
retention period is required or permitted by law (such as tax, accounting,
or other legal requirements). No
purpose in this notice will require us keeping your personal information
for longer than
the period of time in which users have
an account with us.
When we have no ongoing legitimate business need to process your personal
information, we will either delete or
anonymize
such information, or, if this is not possible (for example, because your
personal information has been stored in backup archives), then we will
securely store your personal information and isolate it from any further
processing until deletion is possible.
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of
organizational
and technical security measures.
We have implemented appropriate and reasonable technical and
organizational
security measures designed to protect the security of any personal
information we process. However, despite our safeguards and efforts to
secure your information, no electronic transmission over the Internet or
information storage technology can be guaranteed to be 100% secure, so we
cannot promise or guarantee that hackers, cybercriminals, or other
unauthorized
third parties will not be able to defeat our security and improperly
collect, access, steal, or modify your information. Although we will do
our best to protect your personal information, transmission of personal
information to and from our Services is at your own risk. You should only
access the Services within a secure environment.
10. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to
children under 18 years of age.
We do not knowingly solicit data from or market to children under 18
years of age. By using the Services, you represent that you are at least
18 or that you are the parent or guardian of such a minor and consent to
such minor dependent’s use of the Services. If we learn that personal
information from users less than 18 years of age has been collected, we
will deactivate the account and take reasonable measures to promptly
delete such data from our records. If you become aware of any data we may
have collected from children under age 18, please contact us at
[email protected].
11. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the
European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over
your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, and
Canada), you have certain rights under
applicable data protection laws. These may include the right (i) to
request access and obtain a copy of your personal information, (ii) to
request rectification or erasure; (iii) to restrict the processing of your
personal information; and (iv) if applicable, to data portability. In
certain circumstances, you may also have the right to object to the
processing of your personal information. You can make such a request by
contacting us by using the contact details provided in the section
"HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"
below.
We will consider and act upon any request in accordance with applicable
data protection laws.
Withdrawing your consent: If we are relying on
your consent to process your personal information,
which may be express and/or implied consent depending on the applicable
law, you have the right to
withdraw your consent at any time. You can withdraw your consent at any
time by contacting us by using the contact details provided in the section
"HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"
below.
However, please note that this will not affect the lawfulness of the
processing before its withdrawal nor,
when applicable law allows,
will it affect the processing of your personal information conducted in
reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at
any time by clicking on the unsubscribe
link in the emails that we send, or
by contacting us using the details provided in the section
"HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"
below. You will then be removed from the marketing lists. However, we may
still communicate with you — for example, to send you service-related
messages that are necessary for the administration and use of your account,
to respond to service requests, or for other non-marketing purposes.
Account Information
If you would at any time like to review or change the information in your
account or terminate your account, you can:
-
Log in to your account settings and update your user account.
-
Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete
your account and information from our active databases. However, we may
retain some information in our files to prevent fraud, troubleshoot
problems, assist with any investigations, enforce our legal terms and/or
comply with applicable legal requirements.
Cookies and similar technologies: Most Web
browsers are set to accept cookies by default. If you prefer, you can
usually choose to set your browser to remove cookies and to reject
cookies. If you choose to remove cookies or reject cookies, this could
affect certain features or services of our Services. You may also
opt out of interest-based advertising by advertisers
on our Services.
For further information, please see our Cookie Notice:
https://upmoni.com/cookie-policy.
If you have questions or comments about your privacy rights, you may email
us at [email protected].
12. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile
applications include a Do-Not-Track ("DNT") feature or setting
you can activate to signal your privacy preference not to have data about
your online browsing activities monitored and collected. At this stage no
uniform technology standard for
recognizing
and implementing DNT signals has been
finalized. As such, we do not currently respond to DNT browser signals or any
other mechanism that automatically communicates your choice not to be
tracked online. If a standard for online tracking is adopted that we must
follow in the future, we will inform you about that practice in a revised
version of this privacy notice.
13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific
rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the
"Shine The Light"
law, permits our users who are California residents to request and obtain
from us, once a year and free of charge, information about categories of
personal information (if any) we disclosed to third parties for direct
marketing purposes and the names and addresses of all third parties with
which we shared personal information in the immediately preceding calendar
year. If you are a California resident and would like to make such a
request, please submit your request in writing to us using the contact
information provided below.
If you are under 18 years of age, reside in California, and have a
registered account with Services, you have the right to request removal of
unwanted data that you publicly post on the Services. To request removal
of such data, please contact us using the contact information provided
below and include the email address associated with your account and a
statement that you reside in California. We will make sure the data is not
publicly displayed on the Services, but please be aware that the data may
not be completely or comprehensively removed from all our systems
(e.g.,
backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a
"resident"
as:
(1) every individual who is in the State of California for other than a
temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is
outside the State of California for a temporary or transitory
purpose
All other individuals are defined as
"non-residents."
If this definition of "resident"
applies to you, we must adhere to certain rights and obligations regarding
your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the
past twelve (12) months:
|
Category
|
Examples
|
Collected
|
|
A. Identifiers
|
Contact details, such as real name, alias, postal address,
telephone or mobile contact number, unique personal identifier,
online identifier, Internet Protocol address, email address, and
account name
|
YES
|
|
B. Personal information categories listed in the California
Customer Records statute
|
Name, contact information, education, employment, employment
history, and financial information
|
YES
|
|
C. Protected classification characteristics under California or
federal law
|
Gender and date of birth
|
NO
|
|
D. Commercial information
|
Transaction information, purchase history, financial details, and
payment information
|
YES
|
|
E. Biometric information
|
Fingerprints and voiceprints
|
NO
|
|
F. Internet or other similar network activity
|
Browsing history, search history, online
behavior, interest data, and interactions with our and other websites,
applications, systems, and advertisements
|
YES
|
|
G. Geolocation data
|
Device location
|
YES
|
|
H. Audio, electronic, visual, thermal, olfactory, or similar
information
|
Images and audio, video or call recordings created in connection
with our business activities
|
NO
|
|
I. Professional or employment-related information
|
Business contact details in order to provide you our Services at
a business level or job title, work history, and professional
qualifications if you apply for a job with us
|
NO
|
|
J. Education Information
|
Student records and directory information
|
NO
|
|
K. Inferences drawn from other personal information
|
Inferences drawn from any of the collected personal information
listed above to create a profile or summary about, for example, an
individual’s preferences and characteristics
|
YES
|
|
L. Sensitive Personal Information
|
|
NO
|
We will use and retain the collected personal information as needed to
provide the Services or for:
-
Category A -
As long as the user has an account with us
-
Category B -
As long as the user has an account with us
-
Category D -
As long as the user has an account with us
-
Category F -
As long as the user has an account with us
-
Category G -
As long as the user has an account with us
-
Category K -
As long as the user has an account with us
We may also collect other personal information outside of
these categories through instances where you interact with us
in person, online, or by phone or mail in the context of:
-
Receiving help through our customer support channels;
-
Participation in customer surveys or contests; and
-
Facilitation in the delivery of our Services and to respond
to your inquiries.
How do we use and share your personal information?
Upmoni, LLC collects and shares
your personal information through:
-
Targeting cookies/Marketing cookies
You may contact us
by email at [email protected],
or by referring to the contact details at the bottom of
this document.
If you are using an
authorized
agent to exercise your right to opt out we may deny a
request if the
authorized
agent does not submit proof that they have been validly
authorized
to act on your behalf.
Will your information be shared with anyone
else?
We may disclose your personal information with our
service providers pursuant to a written contract between
us and each service provider. Each service provider is a
for-profit entity that processes the information on our
behalf, following the same strict privacy protection
obligations mandated by the CCPA.
We may use your personal information for our own
business purposes, such as for undertaking internal
research for technological development and
demonstration. This is not considered to be
"selling"
of your personal information.
Upmoni, LLC has not sold or
shared any personal information to third parties for a
business or commercial purpose in the preceding twelve
(12) months. Upmoni, LLC has disclosed the following categories of
personal information to third parties for a business
or commercial purpose in the preceding twelve (12)
months:
-
Category A. Identifiers, such as contact details
like your real name, alias, postal address,
telephone or mobile contact number, unique
personal identifier, online identifier, Internet
Protocol address, email address, and account
name.
-
Category B. Personal Information, as defined in the
California Customer Records law, such as your name,
contact information, education, employment, employment
history, and financial information.
-
Category D. Commercial information, such as
transaction information, purchase history,
financial details, and payment information.
-
Category F. Internet or other electronic network
activity information, such as browsing history,
search history, online
behavior, interest data, and interactions with our and
other websites, applications, systems, and
advertisements.
-
Category G. Geolocation data, such as device
location.
-
Category K. Inferences drawn from any of
the personal information listed above to
create a profile or summary about, for
example, an individual's preferences and
characteristics.
Your rights with respect to your personal
data
Right to request deletion of the data —
Request to delete
You can ask for the deletion of your
personal information. If you ask us to
delete your personal information, we will
respect your request and delete your
personal information, subject to certain
exceptions provided by law, such as (but not
limited to) the exercise by another consumer
of his or her right to free speech, our
compliance requirements resulting from a
legal obligation, or any processing that may
be required to protect against illegal
activities.
Right to be informed — Request to know
Depending on the circumstances, you have a
right to know:
-
whether we collect and use your personal
information;
-
the categories of personal information
that we collect;
-
the purposes for which the collected
personal information is used;
-
whether we sell or share personal
information to third parties;
-
the categories of personal information
that we sold, shared, or disclosed for a
business purpose;
-
the categories of third parties to whom
the personal information was sold, shared,
or disclosed for a business purpose;
-
the business or commercial purpose for
collecting, selling, or sharing personal
information; and
-
the specific pieces of personal information
we collected about you.
In accordance with applicable law, we are
not obligated to provide or delete consumer
information that is de-identified in
response to a consumer request or to
re-identify individual data to verify a
consumer request.
Right to Non-Discrimination for the
Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you
exercise your privacy rights.
Right to Limit Use and Disclosure of
Sensitive Personal Information
We do not process consumer's sensitive personal
information.
Verification process
Upon receiving your request, we will need
to verify your identity to determine you are
the same person about whom we have the
information in our system. These
verification efforts require us to ask you
to provide information so that we can match
it with information you have previously
provided us. For instance, depending on the
type of request you submit, we may ask you
to provide certain information so that we
can match the information you provide with
the information we already have on file, or
we may contact you through a communication
method (e.g.,
phone or email) that you have previously
provided to us. We may also use other
verification methods as the circumstances
dictate.
We will only use personal information
provided in your request to verify your
identity or authority to make the request.
To the extent possible, we will avoid
requesting additional information from you
for the purposes of verification. However,
if we cannot verify your identity from the
information already maintained by us, we may
request that you provide additional
information for the purposes of verifying
your identity and for security or
fraud-prevention purposes. We will delete
such additionally provided information as
soon as we finish verifying you.
Other privacy rights
-
You may object to the processing of your
personal information.
-
You may request correction of your
personal data if it is incorrect or no
longer relevant, or ask to restrict the
processing of the information.
-
You can designate an
authorized
agent to make a request under the CCPA on
your behalf. We may deny a request from an
authorized
agent that does not submit proof that they
have been validly
authorized
to act on your behalf in accordance with
the CCPA.
-
You may request to opt out from future
selling or sharing of your personal
information to third parties. Upon
receiving an opt-out request, we will act
upon the request as soon as feasibly
possible, but no later than fifteen (15)
days from the date of the request
submission.
To exercise these rights, you can contact
us by
email at
[email protected],
or by referring to the contact details at the
bottom of this document. If you have a complaint
about how we handle your data, we would like to
hear from you.
14. DO WE MAKE UPDATES TO THIS
NOTICE?
In Short: Yes, we
will update this notice as necessary to
stay compliant with relevant laws.
We may update this privacy notice from time
to time. The updated version will be
indicated by an updated
"Revised"
date and the updated version will be
effective as soon as it is accessible. If we
make material changes to this privacy
notice, we may notify you either by
prominently posting a notice of such changes
or by directly sending you a notification.
We encourage you to review this privacy
notice frequently to be informed of how we
are protecting your information.
15. HOW CAN YOU CONTACT US ABOUT
THIS NOTICE?
If you have questions or comments about
this notice, you may
email us at
[email protected] or contact us by post at:
Upmoni, LLC
9450 SW Gemini Dr PMB 84485
Beaverton,
OR
97008-7105
United States
16. HOW CAN YOU REVIEW, UPDATE, OR
DELETE THE DATA WE COLLECT FROM
YOU?
Based on
the applicable laws of your country, you may
have the right to request access to the
personal information we collect from you,
change that information, or delete it.
To
request to review, update, or delete your
personal information, please
contact us at
[email protected].