Privacy Policy

NOTICE: The Privacy Policy below will become effective January 29, 2019.

Upspring cares about your privacy. For this reason, we collect and use personal data only as it is needed for us to deliver to you our products and services (collectively, our “Services”). Your personal data includes information such as:

  • Name
  • Company
  • Telephone number
  • Email address
  • Other data collected that could directly or indirectly identify you.

Our Privacy Policy is intended to describe to you how and what data we collect, and how and why we use your personal data. It also describes options we provide for you to access, update or otherwise take control of your personal data that we process. If at any time you have questions about our practices or any of your rights described below, you may reach our Data Protection Officer (“DPO”) and our dedicated team that supports this office by contacting us at info@upspringdigital.com

WHAT INFORMATION DO WE COLLECT?

We collect information so that we can provide the best possible experience when you utilize our Services. Much of what you likely consider personal data is collected directly from you when you:

  1. Submit a Contact form submission (ex: name, company, email address, phone number)

However, we also collect additional information when delivering our Services to you to ensure necessary and optimal performance. These methods of collection may not be as obvious to you, so we wanted to highlight and explain below a bit more about what these might be (as they vary from time to time) and how they work:

Account related information is collected in association with your use of our Services, such as information requests.

Cookies and similar technologies on our website allow us to track browsing behavior, links clicked, and to collect various data, including analytics, about how you use and interact with our Services. This allows us to provide a better experience on our sites, and to collect, analyze, and improve the performance of our Services.

HOW WE UTILIZE INFORMATION.

We strongly believe in both minimizing the data we collect and limiting its use and purpose to only that (1) for which we have been given permission, (2) as necessary to deliver the Services you purchase or interact with, or (3) as we might be required or permitted for legal compliance or other lawful purposes. These uses include:

Delivering, improving, updating and enhancing the Services we provide to you. We collect various information relating to your purchase, use and/or interactions with our Services. We utilize this information to:

  • Improve and optimize the operation and performance of our Services (including our website and in-person interactions)
  • Diagnose problems with and identify any security risks, errors, or needed enhancements to the Services
  • Detect and prevent fraud and abuse of our Services and systems
  • Collecting aggregate statistics about the use of our website

Often, much of the data collected is aggregated or statistical data about how individuals use our Services and is not linked to any personal data, but to the extent it is itself personal data or is linked or linkable to personal data, we treat it accordingly.

Sharing with trusted third parties. We may share your personal data with affiliated companies within our corporate family, with third parties with which we have partnered to allow you to integrate their services into our own Services, and with trusted third-party service providers as necessary for them to perform services on our behalf, such as:

  • Screen for risk, fraud, or other similar types of issues
  • Communicating with you, such as by way email or phone call

We only share your personal data as necessary for any third party to provide the services as requested or as needed on our behalf. These third parties (and any subcontractors) are subject to strict data processing terms and conditions and are prohibited from utilizing, sharing or retaining your personal data for any purpose other than as they have been specifically contracted for (or without your consent).

Communicating with you. We may contact you directly regarding products or services you have signed up or purchased from us, such as necessary to deliver transactional or service-related communications. We may also contact you with offers for additional services we think you’ll find valuable if you give us consent, or where allowed based upon legitimate interests. You don’t need to provide consent as a condition to purchase our goods or services. These contacts may include:

  • Email
  • Telephone calls

If we collect information from you in connection with a co-branded offer, it will be clear at the point of collection who is collecting the information and whose privacy policy applies. In addition, it will describe any choice options you have in regard to the use and/or sharing of your personal data with a co-branded partner, as well as how to exercise those options.

Transfer of personal data. If you utilize our Services from a country other than the United States of America where our servers are located, your communications with us will result in transmitting your personal data across international borders. In these cases, your personal data is handled according to this Privacy Policy.

Compliance with legal, regulatory and law enforcement requests. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (such as subpoena requests), to protect our property and rights or the property and rights of a third party, to protect the safety of the public or any person, or to prevent or stop activity we consider to be illegal or unethical.

To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of legal process.

Website analytics. We use web analytics tools provided by service partners such as Google Analytics to collect information about how our customers interact with our website, including what pages are visited, what websites referred customers to our website, how much time is spent on each page, what operating system and web browser is used and network and IP information. We use the information provided by these tools to improve our Services. These tools place persistent cookies in your browser to identify you as a unique user the next time you visit our website. Each cookie cannot be used by anyone other than the service provider (Google Analytics). The information collected from the cookie may be transmitted to and stored by these service partners on servers in a country other than the country in which you reside. Though information collected does not include personal data such as name, address, billing information, etc., the information collected is used and shared by Google in accordance with their individual privacy policies. You can control the technologies we use by utilizing settings in your browser or third-party tools, such as Disconnect, Ghostery, and others. In addition, you can choose to opt out of Google Analytics by installing the Google Analytics Opt-out Browser Plugin in your browser.

HOW YOU CAN ACCESS, UPDATE OR DELETE YOUR DATA.

If you would like to view, update, delete or port your personal data (where available), or to update your account preferences, please contact us at info@upspringdigital.com.

If you make a request to delete your personal data and that data is necessary for the products or services you have purchased, the request will be honored only to the extent it is no longer necessary for any Services purchased or required for our legitimate business purposes or legal or contractual record keeping requirements.

HOW WE SECURE, STORE AND RETAIN YOUR DATA.

We follow generally accepted standards to store and protect the personal data we collect, both during transmission and once received and stored, including utilization of encryption where appropriate.

We retain personal data only for as long as necessary to provide the Services you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods:

  • mandated by law, contract or similar obligations applicable to our business operations;
  • for preserving, resolving, defending or enforcing our legal/contractual rights; or
  • needed to maintain adequate and accurate business and financial records.
  • If you have any questions about the security or retention of your personal data, you can contact us at info@upspringdigital.com.

‘DO NOT TRACK’ NOTIFICATIONS.

Some browsers allow you to automatically notify websites you visit not to track you using a “Do Not Track” signal. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track”, you may wish to visit www.allaboutdnt.com.

AGE RESTRICTIONS.

Our Online Services are available for purchase only for those over the age of 18. Our Services are not targeted to, intended to be consumed by or designed to entice individuals under the age of 18. If you know of or have reason to believe anyone under the age of 18 has provided us with any personal data, please contact us.

CHANGES IN OUR PRIVACY POLICY.

We reserve the right to modify this Privacy Policy at any time. If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy and any other places we deem appropriate, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make material changes to this Privacy Policy, we will notify you here, by email, or by means of a notice on our home page, at least thirty (30) days prior to the implementation of the changes.

DATA PROTECTION OFFICER.

If you are a resident of the European Economic Area (EEA) and believe we maintain your personal data subject to the General Data Protection Regulation (GDPR), you may direct questions or complaints to our lead supervisory authority, as noted below:


Upspring Information Services

1000 Bishop Street, Suite 909
Honolulu, HI 96813

Phone: (808) 534-7580
Email: info@upspringdigital.com



CONTACT US.

If you have any questions, concerns or complaints about our Privacy Policy, our practices or our Services, you may contact our Office of the DPO by email at info@upspringdigital.com. In the alternative, you may contact us by either of the following means:



Last Revised: January 4, 2019

Copyright ©2019 Upspring LLC All Rights Reserved.