Effective as of May 30, 2020
INFORMATION COLLECTION AND USE
What Information does UGAA collect about me? When you interact with our Site, Software, and/or Services, we collect Information that, alone or in combination with other data, could be used to identify you (“Personal Data”). Some of the Information we collect is stored in a manner that cannot be linked back to you (“Non-Personal Data”).
When you browse our site, application, purchase a tour or otherwise use our Services, you voluntarily give us certain Personal Data, including:
Your username, email address, and contact information.
Other Information we collect
We collect this Information as you use the Site, Software, and/or Services:
This consists of all text, documents, or other content or information uploaded, entered, or otherwise transmitted by you in connection with your use of the Services and/or Software.
Automatically collected Information
Certain data about the devices you use to connect with UGAA and your use of the Site, Software, and/or Services are automatically logged in our systems, including:
This is the geographic area where you use your computer and mobile devices (as indicated by an Internet Protocol [IP] address or similar identifier) when interacting with our Site, Software, and/or Services while using the services. Otherwise this information is not stored, collected or used.
As with most technology services delivered over the internet, our servers automatically collect data when you access or use our Site, Software, and/or Services and record it in log files. This log data may include the IP address, browser type and settings, the date and time of use, information about browser configuration, language preferences, and cookie data.
This is information about the UGAA Site, Software, and/or Services you use and how you use them. We may also obtain data from our third-party partners and service providers to analyze how users use our Site, Software, and/or Services. For example, we will know how many users access a specific page on the Site and which links they clicked on. We use this aggregated information to better understand and optimize the Site. Device information. These are data from your computer or mobile device, such as the type of hardware and software you are using (for example, your operating system and browser type), as well as unique device identifiers for devices that are using UGAA Software.
HOW DOES UGAA USE MY INFORMATION?
We use, process, and store your Information as necessary to perform our contract with you and for our legitimate business interests, including:
- to help us administer our Site, Software, and/or Services, authenticate users for security purposes, provide personalized user features and access, process transactions, conduct research, develop new features, and improve the features, algorithms, and usability of our Site, Software, and/or Services.
- to communicate with you about your use of our Site, Software, and/or Services, product announcements, and software updates, as well as respond to your requests for assistance, including providing account verification support if you’re having difficulty accessing your account.
- to send you direct marketing emails and special offers about UGAA, from which you can unsubscribe at any time. For more information, please see the section entitled, “Will UGAA send me emails?” If you are located in the European Economic Area (EEA), we will only send you marketing information if you consent to us doing so at the time you create your account or any point thereafter.
- to display User Content associated with your account and make sure it is available to you when you use our Services.
- to calculate aggregate statistics on the number of unique devices using our Site, Software, and/or Services, and to detect and prevent fraud and misuse of those.
INFORMATION ACCESS AND DISCLOSURE
Does UGAA share my information?
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety.
We believe it is necessary to investigate potential violations of the Terms and Conditions, to enforce those Terms and Conditions, or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, or potential threats against persons, property, or the systems on which we operate our Site, Software, and/or Services.
We determine that the access, preservation, or disclosure of your Personal Data is required by law to protect the rights, property, or personal safety of UGAA and users of our Site, Software, and/or Services, or to respond to lawful requests by public authorities, including national security or law enforcement requests.
We may disclose Non-Personal Data publicly and to third parties – for example, in public reports about word usage, to partners under agreement with us, or as part of progress reports we may provide to users.
UGAA does not share your Personal Data with third parties for the purpose of enabling them to deliver their advertisements to you.
WILL UGAA SEND ME EMAILS?
From time to time, we may want to contact you with information about product announcements and special offers. You may opt out of such communications at any time by clicking the “unsubscribe” link found within UGAA emails and changing your contact preferences. All UGAA account holders will continue to receive transactional and tour logistics messages related to our Services, even if you unsubscribe from promotional emails.
For EEA users: We only send marketing communications to users located in the EEA with your prior consent. Please see the section “For EEA users” below.
Does UGAA ever make any of my Personal Data or User Content public?
No, we do not share Personal Data or User Content except in the limited circumstances described in the “Does UGAA share my Information?” section of the Policy.
DATA STORAGE, TRANSFER, RETENTION, AND DELETION
Where is my Information stored?
Information submitted to UGAA will be transferred to, processed, and stored in the United States in accordance with the policies of our website host. When you use the Software on your computing device, User Content you save will be stored locally on that device and synced with our servers. If you post or transfer any Information to or through our Site, Software, and/or Services, you are agreeing to such Information, including Personal Data and User Content, being hosted and accessed in the United States.
HOW SECURE IS MY INFORMATION?
UGAA is committed to protecting the security of your Information and takes reasonable precautions to protect it. However, Internet data transmissions, whether wired or wireless, cannot be guaranteed to be 100% secure, and as a result, we cannot ensure the security of Information you transmit to us, including Personal Data and User Content; accordingly, you acknowledge that you do so at your own risk.
We use industry-standard encryption to protect your data in transit. This is commonly referred to as transport layer security (“TLS”) or secure socket layer (“SSL”) technology.
Once we receive your data, we protect it on our servers using a combination of technical, physical, and logical security safeguards. The security of the data stored locally in any of our Software installed on your computing device requires that you make use of the security features of your device. We recommend that you take the appropriate steps to secure all computing devices that you use in connection with our Site, Software, and Services.
If UGAA learns of a security system breach, we may attempt to notify you and provide information on protective steps, if available, through the email address that you have provided to us or by posting a notice on the Site. Depending on where you live, you may have a legal right to receive such notices in writing.
HOW CAN I DELETE MY PERSONAL DATA FROM UGAA?
In order to remove your Personal Data please send an email to info@UGAA.com with your first and last name, email address and phone number. UGAA will request additional authentication information from you to verify your identity before we delete any information.
How long is Personal Data retained?
You can remove your Personal Data from UGAA at any time by requesting your account be deleted as described above. However, we may keep some of your Personal Data for as long as reasonably necessary for our legitimate business interests, including fraud detection and prevention and to comply with our legal obligations including tax, legal reporting, and auditing obligations.
FOR EEA USERS
UGAA uses, processes, and stores Personal Data, including those listed in the “What Information does UGAA collect about me?” section, as necessary to perform our contract with you, and based on our legitimate interests in order to provide the Services. We rely on your consent to process Personal Data to send promotional emails and to place cookies on your devices. In some cases, UGAA may process Personal Data pursuant to legal obligation or to protect your vital interests or those of another person.
What rights do I have, and how can I exercise them?
Individuals located in the European Economic Area (EEA) have certain rights in respect to their personal information, including the right to access, correct, or delete Personal Data we process through your use of the Site, Software, and/or Services. We provide the same rights regardless if you are an EEA user or an American user. If you’re a user based in the United States or the EEA, you can:
Request a Personal Data report by submitting through our info@UGAA.com account. This report will include the Personal Data we have about you, provided to you in a structured, commonly used, and portable format. Please note that UGAA may request additional information from you to verify your identity before we disclose any information.
How can I have my Personal Data corrected or deleted?
You can remove your Personal Data from UGAA by requesting deletion of your account from firstname.lastname@example.org
How can I object to us processing your Personal Data?
You can ask us to stop using your Personal Data, including when we use your Personal Data to send you marketing emails. We only send marketing communications to users located in the EEA with your prior consent, and you may withdraw your consent at any time by clicking the “unsubscribe” link found within UGAA emails and changing your contact preferences. Please note you will continue to receive transactional messages related to our Services, even if you unsubscribe from marketing emails.
How can I complain to a regulator?
If you’re based in the EEA and think that we haven’t complied with data protection laws, you have a right to lodge a complaint with your local supervisory authority.
As UGAA evolves, we may need to update this Policy to keep pace with changes in our Site, Software, and Services, our business, and laws applicable to us and you. We will, however, always maintain our commitment to respect your privacy. We will notify you of any material changes that impact your rights under this Policy by email (to your most recently provided email address) or post any other revisions to this Policy, along with their effective date, in an easy-to-find area of the Site, so we recommend that you periodically check back here to stay informed of any changes. Please note that your continued use of UGAA after any change means that you agree with, and consent to be bound by, the new Policy. If you disagree with any changes in this Policy and do not wish your information to be subject to it, you will need to delete your UGAA account.
CALIFORNIA ONLINE PRIVACY PROTECTION ACT COMPLIANCE
Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your personal information to outside parties without your consent.
CHILDREN’S ONLINE PRIVACY PROTECTION ACT COMPLIANCE
We are in compliance with the requirements of COPPA (Childrens Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our website, products and services are all directed to people who are at least 13 years old or older. If you are under the age of 13, please do not submit any personal information through the Site, Service, and/or Software. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Site, Service, and/or Software without their permission.
TERMS AND CONDITIONS
Please also visit our Terms and Conditions section establishing the use, disclaimers, and limitations of liability governing the use of our website.