Privacy Notice- Effective & Last Updated 1/1/2023
This privacy notice for Uphold.ai ("Company," "we," "us," or "our"), describes how and why we
might collect, store, use, and/or share ("process") your information when you use our services
("Services"), such as when you:
Questions or concerns? Reading this privacy notice will help you understand your privacy rights
and choices. If you do not agree with our policies and practices, please do not use our Services.
If you still have any questions or concerns, please contact us at support@uphold.ai.
SUMMARY OF KEY POINTS
What personal information do we process? When you visit, use, or navigate our Services, we
may process personal information depending on how you interact with our Services, the choices
you make, and the products and features you use. Learn more below.
Do we process any sensitive personal information? We do not process sensitive personal
information.
Do we receive any information from third parties? We may receive information from public
databases, marketing partners, social media platforms, and other outside sources. Learn more
below.
How do we process your information? We process your information to provide, improve, and
administer our Services, communicate with you, for security and fraud prevention, and to comply
with law. We may also process your information for other purposes with your consent. We
process your information only when we have a valid legal reason to do so. Learn more below.
In what situations and with which parties do we share personal information?
We may share information in specific situations and with specific third parties. Learn more
below. What are your rights? Depending on where you are located geographically, the
applicable privacy law may mean you have certain rights regarding your personal information.
Learn more below.
How do you exercise your rights? The easiest way to exercise your rights is by filling out our
data subject request form available here, or by contacting us. We will consider and act upon any
request in accordance with applicable data protection laws.
Want to learn more about what we do with any information we collect? Read below to review the
notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? 4. DO WE
USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the
Services, express an interest in obtaining information about us or our products and Services,
when you participate in activities on the Services, or otherwise when you contact us.
Sensitive Information. We do not process sensitive information.
All personal information that you provide to us must be true, complete, and accurate,
and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and
device characteristics — may be collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This
information does not reveal your specific identity (like your name or contact information) but may
include device and usage information, such as your IP address, browser and device
characteristics, operating system, language preferences, referring URLs, device name, country,
location, information about how and when you use our Services, and other technical
information. This information is primarily needed to maintain the security and operation of our
Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with law. We may also
process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact
with our Services, including:
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?
In Short: We may share information in specific situations described in this section and/or with
the following third parties.
We may need to share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during
negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion
of our business to another company.
Affiliates. We may share your information with our affiliates, in which case we will require those
affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries,
joint venture partners, or other companies that we control or that are under common control with
us.
Business Partners. We may share your information with our business partners to offer you
certain products, services, or promotions.
4. 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.
5. 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.
6. 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,
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
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.
7. 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).
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.
8. 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 support@uphold.ai.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account at any time.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal
information, you also have the right to complain to your local data protection supervisory
authority. You can find their contact details here:
https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details for the data protection authorities are
available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
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.
Account Information
If you would at any time like to review or change the information in your account or terminate
your account, you can:
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.
10. 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.
11. 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.).
12. 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.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at support@uphold.ai.
14. 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 support@uphold.ai.
