PRIVACY POLICY
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Version
Date: ________
GENERAL
Uciarsweligatta (“Company” or “we” or “us”
or “our”) respects the privacy of its users (“user” or “you”) that use our
website located at ____________, including other media forms, media channels,
mobile website or mobile application related or connected thereto
(collectively, the “Website”). The following Company privacy policy (“Privacy
Policy”) is designed to inform you, as a user of the Website, about the types
of information that Company may gather about or collect from you in connection
with your use of the Website. It also is intended to explain the conditions
under which Company uses and discloses that information, and your rights in relation
to that information. Changes to this Privacy Policy are discussed at the end of
this document. Each time you use the Website, however, the current version of
this Privacy Policy will apply. Accordingly, each time you use the Website you
should check the date of this Privacy Policy (which appears at the beginning of
this document) and review any changes since the last time you used the
Website.
The
Website is hosted in the United States of America and is subject to U.S. state
and federal law. If you are accessing our Website from other jurisdictions,
please be advised that you are transferring your personal information to us in
the United States, and by using our Website, you consent to that transfer and
use of your personal information in accordance with this Privacy Policy. You
also agree to abide by the applicable laws of applicable states and U.S.
federal law concerning your use of the Website and your agreements with us. Any
persons accessing our Website from any jurisdiction with laws or regulations
governing the use of the Internet, including personal data collection, use and
disclosure, different from those of the jurisdictions mentioned above may only
use the Website in a manner lawful in their jurisdiction. If your use of the
Website would be unlawful in your jurisdiction, please do not use the Website.
BY
USING OR ACCESSING THE WEBSITE, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN
THIS PRIVACY POLICY.
GATHERING, USE AND
DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION
Users of the Website
Generally
“Non-Personally-Identifying
Information” is information that, without the aid of additional information,
cannot be directly associated with a specific person. “Personally-Identifying
Information,” by contrast, is information such as a name or email address that,
without more, can be directly associated with a specific person. Like most
website operators, Company gathers from users of the Website
Non-Personally-Identifying Information of the sort that Web browsers, depending
on their settings, may make available. That information includes the user’s
Internet Protocol (IP) address, operating system, browser type and the
locations of the websites the user views right before arriving at, while
navigating and immediately after leaving the Website. Although such information
is not Personally-Identifying Information, it may be possible for Company to
determine from an IP address a user’s Internet service provider and the
geographic location of the visitor’s point of connectivity as well as other statistical
usage data. Company analyzes Non-Personally-Identifying Information
gathered from users of the Website to help Company better understand how the
Website is being used. By identifying patterns and trends in usage, Company is
able to better design the Website to improve users’ experiences, both in terms
of content and ease of use. From time to time, Company may also release the
Non-Personally-Identifying Information gathered from Website users in the
aggregate, such as by publishing a report on trends in the usage of the
Website.
Web Cookies
A “Web Cookie” is a
string of information which assigns you a unique identification that a website
stores on a user’s computer, and that the user’s browser provides to the
website each time the user submits a query to the website. We use cookies on
the Website to keep track of services you have used, to record registration
information regarding your login name and password, to record your user
preferences, to keep you logged into the Website and to facilitate purchase
procedures. Company also uses Web Cookies to track the pages that users visit
during each Website session, both to help Company improve users’ experiences
and to help Company understand how the Website is being used. As with other
Non-Personally-Identifying Information gathered from users of the Website,
Company analyzes and discloses in aggregated form information gathered using
Web Cookies, so as to help Company, its partners and others better understand
how the Website is being used. COMPANY USERS WHO DO NOT WISH TO HAVE WEB
COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB
COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN
FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES.
WEBSITE USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY
RESULTING LOSS OF FUNCTIONALITY.
Third-Party Advertisers
We may use third-party
advertising companies to serve ads when you visit the Website. These companies
may use information (not including any Personally-Identifying Information)
about your visits to the Website and other websites that are contained in Web
Cookies in order to provide advertisements about goods and services of interest
to you. Using a tool created by the Network Advertising Initiative, you can opt
out of several third-party ad servers’ and networks’ Web
Cookies simultaneously. If you would like more information about this practice
and to know your choices about not having this information used by these
companies, please follow the following links: http://networkadvertising.org/managing/opt_out.asp, http://preferences-mgr.truste.com/, or http://www.aboutads.info/choices/. Please contact us if you would like to know the identity of the third-party
advertising companies we are currently using to serve ads.
We may allow advertisers to choose the
characteristics of users who will see their advertisements, and we may use any
of the Non-Personally Identifying Information we have collected (including
information you may have decided not to show to other users, such as your birth
year or other sensitive personal information or preferences) to select the
appropriate audience for those advertisements. We do not identify you to the
advertiser.
Web Beacons
A “Web Beacon” is an
object that is embedded in a web page or email that is usually invisible to the
user and allows website operators to check whether a user has viewed a
particular web page or an email. Company may use Web Beacons on the Website and
in emails to count users who have visited particular pages, viewed emails and
to deliver co-branded services. Web Beacons are not used to access users’
Personally-Identifying Information. They are a technique Company may use to
compile aggregated statistics about Website usage. Web Beacons collect only a
limited set of information, including a Web Cookie number, time and date of a
page or email view and a description of the page or email on which the Web
Beacon resides. You may not decline Web Beacons. However, they can be rendered
ineffective by declining all Web Cookies or modifying your browser setting to
notify you each time a Web Cookie is tendered, permitting you to accept or
decline Web Cookies on an individual basis.
Analytics
We may use third-party vendors,
including Google, who use first-party cookies (such as the Google Analytics
cookie) and third-party cookies (such as the DoubleClick cookie) together to
inform, optimize and serve ads based on your past activity on the Website,
including Google Analytics for Display Advertising. The information collected
may be used to, among other things, analyze and track data, determine the
popularity of certain content and better understand online activity. If you do
not want any information to be collected and used by Google Analytics, you can
install an opt-out in your web browser
(https://tools.google.com/dlpage/gaoptout/) and/or opt out from Google
Analytics for Display Advertising or the Google Display Network by using Google’s
Ads Settings (www.google.com/settings/ads).
Aggregated and
Non-Personally-Identifying Information
We may
share aggregated and Non-Personally Identifying Information we collect under
any of the above circumstances. We may also share it with third parties and our
affiliate companies to develop and deliver targeted advertising on the Website
and on websites of third parties. We may combine Non-Personally Identifying
Information we collect with additional Non-Personally Identifying Information
collected from other sources. We also may share aggregated information with
third parties, including advisors, advertisers and investors, for the purpose
of conducting general business analysis. For example, we may tell our
advertisers the number of visitors to the Website and the most popular features
or services accessed. This information does not contain any
Personally-Identifying Information and may be used to develop website content
and services that we hope you and other users will find of interest and to
target content and advertising.
Mobile
Device Additional Terms
• Mobile Device. If you use a mobile device to access the Website or
download any of our applications, we may collect device information (such as
your mobile device ID, model and manufacturer), operating system, version
information and IP address.
• Geo-Location Information. Unless we have received your prior consent, we do not
access or track any location-based information from your mobile device at any
time while downloading or using our mobile application or our services, except
that it may be possible for Company to determine from an IP address the
geographic location of your point of connectivity, in which case we may gather
and use such general location data.
• Push Notifications. We send you push notifications if you choose to receive
them, letting you know when someone has sent you a message or for other
service-related matters. If you wish to opt-out from receiving these types of
communications, you may turn them off in your device’s settings.
• Mobile Analytics. We use mobile analytics software to allow us to better understand
the functionality of our mobile software on your phone. This software may
record information, such as how often you use the application, the events that
occur within the application, aggregated usage, performance data and where the
application was downloaded from. We do not link the information we store within
the analytics software to any Personally-Identifying Information you submit
within the mobile application.
SOCIAL MEDIA
We may provide you the option to
connect your account on the Website to your account on some social networking
sites for the purpose of logging in, uploading information or enabling certain
features on the Website. When logging in using your social network credentials,
we may collect the Personally-Identifying Information you have made publicly
available on the social networking site, such as your name, profile picture,
cover photo, username, gender, friends network, age range, locale, friend list
and any other information you have made public. Once connected, other users may
also be able to see information about your social network, such as the size of
your network and your friends, including common friends. By connecting your
account on the Website to your account on any social networking site, you
hereby consent to the continuous release of information about you to us. We
will not send any of your account information to the connected social
networking site without first disclosing that to you. Each social network may
further allow you to set privacy controls around your information on their
system, and our collection of information will always follow such controls and
permissions. This feature is subject to continuous change and improvement by us
and each social networking site involved, and therefore the available features
and shared information are subject to change without notice to you.
We may use hyperlinks on the
Website which will redirect you to a social network if you click on the
respective link. However, when you click on a social plug-in, such as Facebook’s
“Like” button, Twitter’s “tweet” button or the Google+, that particular social network’s
plugin will be activated and your browser will directly connect to that
provider’s servers. If you do not use these buttons none, of your data will be
sent to the respective social network’s plugin provider. So for example, when
you click on the Facebook’s “Like” button on the Website, Facebook will receive
your IP address, the browser version and screen resolution, and the operating
system of the device you have used to access the Website. Settings regarding
privacy protection can be found on the websites of these social networks and
are not within our control.
COLLECTION, USE AND
DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION
Website Registration
As defined above,
Personally-Identifying Information is information that can be directly
associated with a specific person. Company may collect a range of
Personally-Identifying Information from and about Website users. Much of the
Personally-Identifying Information collected by Company about users is
information provided by users themselves when (1) registering for our service,
(2) logging in with social network credentials, (3) participating in polls,
contests, surveys or other features of our service, or responding to offers or
advertisements, (4) communicating with us, (5) creating a public profile or (6)
signing up to receive newsletters. That information may include each user’s
name, address, email address and telephone number, and, if you transact
business with us, financial information such as your payment method (valid
credit card number, type, expiration date or other financial information). We
also may request information about your interests and activities, your gender,
age, date of birth, username, hometown and other demographic or relevant
information as determined by Company from time to time. Users of the Website
are under no obligation to provide Company with Personally-Identifying
Information of any kind, with the caveat that a user’s refusal to do so may
prevent the user from using certain Website features.
BY REGISTERING WITH OR
USING THE WEBSITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING
INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING
INFORMATION” SECTION.
Online Postings
Certain
Personally-Identifying Information collected from users may be disclosed as a
matter of course as a result of your use of the Website. We may provide areas
on the Website where you can post reviews and other information relating to your
activities on the Website. Such postings are governed by our Terms of Use.
In addition, such postings may appear on other websites or when searches are
executed on the subject of your posting. Also, whenever you voluntarily
disclose personal information on publicly-viewable web pages, that information
will be publicly available and can be collected and used by others. For
example, if you post your email address, you may receive unsolicited messages.
We cannot control who reads your posting or what other users may do with the
information you voluntarily post, so we encourage you to exercise discretion
and caution with respect to your personal information. USERS ASSUME ALL RESPONSIBILITY
FOR ANY LOSS OF PRIVACY OR OTHER HARM RESULTING FROM THEIR VOLUNTARY DISCLOSURE
OF PERSONALLY IDENTIFYING INFORMATION.
Company Communications
We may occasionally use
your name and email address to send you notifications regarding new services
offered by the Website that we think you may find valuable. We may also send
you service-related announcements from time to time through the general
operation of the service. Generally, you may opt out of such emails at the time
of registration or through your account settings, though we reserve the right
to send you notices about your account, such as service announcements and
administrative messages, even if you opt out of all voluntary email
notifications.
Company
Disclosures
Company will
disclose Personally-Identifying Information under the following circumstances:
• By Law or to Protect Rights. When we believe
disclosure is appropriate, we may disclose Personally-Identifying Information
in connection with efforts to investigate, prevent or take other action
regarding illegal activity, suspected fraud or other wrongdoing; to protect and
defend the rights, property or safety of Company, our users, our employees or
others; to comply with applicable law or cooperate with law enforcement; to
enforce our Terms of Use or other agreements or policies, in response to a
subpoena or similar investigative demand, a court order or a request for
cooperation from a law enforcement or other government agency; to establish or
exercise our legal rights; to defend against legal claims; or as otherwise
required by law. In such cases, we may raise or waive any legal objection or
right available to us.
• Marketing Communications. Unless users opt-out from receiving Company marketing materials
upon registration, Company may email users about products and services that
Company believes may be of interest to them. If you wish to opt-out of
receiving marketing materials from Company, you may do so by following the
unsubscribe link in the email communications, by going to your account settings
(if applicable) or contacting us using the contact information below.
• Third-Party Marketing
Communications. Unless users opt-out from
receiving marketing materials upon registration, Company may provide users’
email information to third parties, so that those third parties may directly
contact them about additional products and services. To cease having your email
information provided to third parties, you may do so by going to your account
settings (if applicable) or contacting us using the contact information below.
Even after opting-out, you may continue to receive marketing emails from third
parties to whom Company already has provided your email information. You will
be responsible for directly contacting such third parties to request cessation
of further marketing emails.
• Third-Party Service
Providers. We may share your Personally-Identifying
Information, which may include your name and contact information (including
email address) with our authorized service providers that perform certain
services on our behalf. These services may include fulfilling orders, providing
customer service and marketing assistance, performing business and sales
analysis, supporting the Website’s functionality and supporting contests,
sweepstakes, surveys and other features offered through the Website. We may
also share your name, contact information and credit card information with our
authorized service providers who process credit card payments. These service
providers may have access to personal information needed to perform their
functions but are not permitted to share or use such information for any other
purpose.
• Business Transfers;
Bankruptcy. Company reserves the right to
transfer all Personally-Identifying Information in its possession to a
successor organization in the event of a merger, acquisition, bankruptcy or
other sale of all or a portion of Company’s assets. Other than to the extent ordered
by a bankruptcy or other court, the use and disclosure of all transferred
Personally-Identifying Information will be subject to this Privacy Policy, or
to a new privacy policy if you are given notice of that new privacy policy and
are given an opportunity to affirmatively opt-out of it. Personally-Identifying
Information submitted or collected after a transfer, however, may be subject to
a new privacy policy adopted by the successor organization.
Changing
Personally-Identifying Information; Account Termination
You may at any time review or change your Personally-Identifying
Information by going to your account settings (if applicable) or contacting us
using the contact information below. Upon your request, we will deactivate or
delete your account and contact information from our active databases. Such
information will be deactivated or deleted as soon as practicable based on your
account activity and accordance with our deactivation policy and applicable
law. To make this request, either go to your account settings (if applicable) or
contact us as provided below. We will retain in our files some Personally-Identifying
Information to prevent fraud, to troubleshoot problems, to assist with any
investigations, to enforce our Terms of Use and to comply with legal
requirements as is permitted by law. Therefore, you should not expect that all
your Personally-Identifying Information will be completely removed from our
databases in response to your requests. Additionally, we keep a history of changed information to investigate suspected fraud
with your account.
General Use
Company uses the
Personally-Identifying Information in the file we maintain about you, and other
information we obtain from your current and past activities on the Website (1) to
deliver the products and services that you have requested; (2) to manage your
account and provide you with customer support; (3) to communicate with you by
email, postal mail, telephone and/or mobile devices about products or services
that may be of interest to you either from us, our affiliate companies or other
third parties; (4) to develop and display content and advertising tailored to
your interests on the Website and other sites; (5) to resolve disputes and troubleshoot
problems; (6) to measure consumer interest in our services; (7) to inform you
of updates; (8) to customize your experience; (9) to detect and protect us
against error, fraud and other criminal activity; (10) to enforce our Terms of
Use; and (11) to do as otherwise described to you at the time of collection. At
times, we may look across multiple users to identify problems. In particular,
we may examine your Personally-Identifying Information to identify users using
multiple user IDs or aliases. We may compare and review your Personally-Identifying
Information for accuracy and to detect errors and omissions. We may use
financial information or payment method to process payment for any purchases
made on the Website, enroll you in the discount, rebate, and other programs in
which you elect to participate, to protect against or identify possible
fraudulent transactions and otherwise as needed to manage our business.
COLLECTION AND USE OF
INFORMATION BY THIRD PARTIES GENERALLY
Company contractually
prohibits its contractors, affiliates, vendors and suppliers from disclosing
Personally-Identifying Information received from Company, other than in accordance
with this Privacy Policy. However, third parties are under no obligation to
comply with this Privacy Policy with respect to Personally-Identifying
Information that users provide directly to those third parties, or that those
third parties collect for themselves. These third parties include advertisers, providers
of games, utilities, widgets and a variety of other third-party applications
accessible through the Website. Company neither owns nor controls the
third-party websites and applications accessible through the Website. Thus,
this Privacy Policy does not apply to information provided to or gathered by
the third parties that operate them. Before visiting a third party, or using a
third-party application, whether by means of a link on the Website, directly
through the Website or otherwise, and before providing any
Personally-Identifying Information to any such third party, users should inform
themselves of the privacy policies and practices (if any) of the third party
responsible for that website or application, and should take those steps
necessary to, in those users’ discretion, protect their privacy.
SECURITY
We take the security of
your Personally-Identifying Information seriously and use reasonable electronic,
personnel and physical measures to protect it from loss, theft, alteration or
misuse. However, please be advised that even the best security measures
cannot fully eliminate all risks. We cannot guarantee that only authorized
persons will view your information. We are not responsible for third-party
circumvention of any privacy settings or security measures.
We are dedicated to
protect all information on the Website as is necessary. However, you are
responsible for maintaining the confidentiality of your Personally-Identifying
Information by keeping your password confidential. You should change your
password immediately if you believe someone has gained unauthorized access to
it or your account. If you lose control of your account, you should notify us
immediately.
PRIVACY POLICY CHANGES
Company may,
in its sole discretion, change this Privacy Policy from time to time. Any and
all changes to Company’s Privacy Policy will be reflected on this page and the
date new versions are posted will be stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all
information that we have about you and your account. Users should regularly check this page for
any changes to this Privacy Policy. Company will always post new versions of
the Privacy Policy on the Website. However, Company may, as determined in its
discretion, decide to notify users of changes made to this Privacy Policy via
email or otherwise. Accordingly, it is important that users always maintain and
update their contact information.
CHILDREN
The Children's Online Privacy Protection Act ("COPPA")
protects the online privacy of children under 13 years of age. We do not
knowingly collect or maintain Personally-Identifying Information from anyone
under the age of 13, unless or except as permitted by law. Any person who
provides Personally-Identifying Information through the Website represents to
us that he or she is 13 years of age or older. If we learn that Personally-Identifying
Information has been collected from a user under 13 years of age on or through
the Website, then we will take the appropriate steps to cause this information
to be deleted. If you are the parent or legal guardian of a child under 13 who
has become a member of the Website or has otherwise transferred Personally-Identifying
Information to the Website, please contact Company using our contact
information below to have that
child's account terminated and information deleted.
CALIFORNIA PRIVACY RIGHTS
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 the Personally-Identifying Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of the Personally-Identifying Information that was shared and the names and addresses of all third parties with which we shared Personally-Identifying 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 our privacy officer as listed below.
DO-NOT-TRACK POLICY
Most web browsers and some mobile operating
systems 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. Because there is not yet a common
understanding of how to interpret the DNT signal, the Website currently does
not respond to DNT browser signals or mechanisms.
CONTACT
If you have any
questions regarding our Privacy Policy, please contact our Privacy Officer at:
___________________
Attn: Privacy Officer
___________________
___________________, ___________________ ___________________
Email: ___________________
Phone: ___________________
Fax: ___________________
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