- The information we collect and why we collect it;
- How we use that information;
- How we share information; and
- The choices we offer.
What Personally Identifiable Information Do We Collect About You?
We may ask you for, or you may voluntarily submit, personally identifiable information when you are using the Service. The personally identifiable information which you may provide to us could include, but is not limited to:
- Your name
- Your contact information (including, without limitation, address and email address);
- Your IP address; and
- Other personal information.
What Non-Personal Or Aggregate Information Do We Collect?
When you access our Service, we may automatically collect non-personally identifiable information from you, such as, but not limited to:
- IP host address
- web pages viewed
- browser type and operating system
- the referring service
- search information
- device type
- page views
- usage and browsing habits on the Service
We may also aggregate demographic information collected from our users (such as the number of users in a particular geographical location) in a manner which does not identify any one individual. We may also aggregate information collected offline in connection with the Service, obtain non-personally identifiable information from third party sources and develop aggregate information by anonymizing previously collected personally identifiable information.
It is possible when collecting non-personally identifiable information through automatic means that we may unintentionally collect or receive personally identifiable information that is mixed in with the non-personally identifiable information. While we will make reasonable efforts to prevent such incidental data collection, the possibility still exists. If you believe that we have inadvertently collected your personal information, please notify us at firstname.lastname@example.org and we will agree on a course of action.
How Do We Use Your Personally Identifiable Information?
We will only use your personally identifiable information in the manner described to you at the time of data collection. In most instances the collection of this information will occur on one of UpThink’s web pages, or via a Google Form on Facebook. In both cases we are extremely transparent in explaining exactly what information we are collecting, and why we need that information.
Doing this ensures that UpThink is compliant with the EU General Data Protection Regulations (GDPR) under the lawful basis of ‘Consent’ (GDPR Article 6(1)a).
All unsubscribe or opt-out requests may be made by clicking the “unsubscribe” link at the bottom of the relevant email.
Of course, if you are a client or contractor of/for UpThink then we will also use your personally identifiable information to meet the requirements of any contracts we have in place with you. Typical activities include, but are not limited to using your information for:
- campaign performance monitoring;
- other business as usual activities.
To ensure we deliver on our contractual responsibilities we may also share your personally identifiable information with third parties, however this will only occur after we have obtained your consent, and they will not be permitted to use this information in any way other than that prescribed by UpThink.
We may disclose personally identifiable information:
- as required by law or legal process; or
- to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the terms or policies for our services or our sponsors.
If we collected your personally identifiable information prior to May 25, 2018 then we will only continue to use that information (eg. to offer job opportunities to influencers, or for marketing to other businesses) where an assessment finds that UpThink either obtained ‘consent’ or has a ‘legitimate interest’ as defined by the GDPR. Any personally identifiable information collected prior to May 25, 2018 and not meeting the definition of either ‘consent’ or ‘legitimate interest’ has been deleted.
How Do We Use ‘Cookies’ and Similar Technologies?
If you delete your cookies, change browsers or use a different cookie, our cookie (or an opt-out cookie) may no longer work and you will have to reinput (or opt-out) again.
Analytics and Conversion Tracking
We may collect information about your computer, including your IP address, operating system and browser type, for system administration and in order to create reports. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
Like many services, the Analytics Service uses first-party cookies to track visitor interactions as in our case, where they are used to collect information about how visitors use our site. We then use the information to compile reports and to help us improve our site.
Cookies contain information that is transferred to your computer’s hard drive. These cookies are used to store information, such as the time that the current visit occurred, whether the visitor has been to the site before and what site referred the visitor to the web page.
The Analytics Service collects information anonymously. They report website trends without identifying individual visitors. You can opt out of the Analytics Service without affecting how you visit our site. For more information on opting out of being tracked by Google Analytics across all websites you use, visit https://tools.google.com/dlpage/gaoptout.
We may also use Google conversion tracking and/or similar services to help us understand your and other users’ use of the Service.
Automatically Collected Information
When you access the Service or open one of our HTML emails, we may automatically record certain information from your system by using cookies and other types of tracking technologies. This “automatically collected” information may include Internet Protocol address (“IP Address”), a unique user ID, device type, device identifiers, browser types and language, referring and exit pages, platform type, version of software installed, system type, the content and pages that you access on the Service, the number of clicks, the amount of time spent on pages, the dates and times that you visit the Service, and other similar information. Depending on the law of your country of residence, your IP address may legally be considered personally identifiable information.
How We Protect Your Information
The security of your personally identifiable information is very important to us. When we collect your personally identifiable information online, we use reasonable efforts to protect it from unauthorized access. However, due to the inherent open nature of the Internet, we cannot guarantee that your personally identifiable information will be completely free from unauthorized access by third parties such as hackers and your use of our Service demonstrates your assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. Only those employees who need access to your information in order to perform their duties are authorized to have access to your personally identifiable information. For more information on protecting your privacy, please visit www.ftc.gov/privacy.
Your Disclosures In Blogs And Other Social Media
You should be aware that personally identifiable information which you voluntarily include and transmit online on the Service or in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum such as an in-person panel or survey, may be viewed and used by others without any restrictions. We are unable to control such uses of your personally identifiable information, and by using the Service or any other online services you assume the risk that the personally identifiable information provided by you may be viewed and used by third parties for any number of purposes.
Protection for Children
We generally do not collect personally identifiable information from children under the age of 13. If at any time in the future we plan to collect personally identifiable information from children under 13, such collection and use, to the extent applicable, shall, when required, be done in compliance with the Children’s Online Privacy Protection Act (“COPPA”), the GDPR, and appropriate consent from the child’s parent or guardian will be sought where required by COPPA. If we become aware that personally identifiable information from a child under 13 has been collected without such child’s parent or guardian’s consent, we will use all reasonable efforts to delete such information from our database.
As a convenience to you, we may provide links to third-party Services from within our Service. We are not responsible for the privacy practices or content of these third-party sites. When you link away from our Service, you do so at your own risk.
How Can You Request Access, Correction or Deletion of Your Information?
If you would like to:
- find out what personally identifiable information we store for you;
- correct or update any information associated with your account; or
- delete your personally identifiable information
then please email us at email@example.com, or send us a message via our Contact page.
How Long Will We Store Your Information?
We will store your personally identifiable information, and other information, for as long as your account is active or otherwise for a limited period of time as long as we need it to fulfil the purposes for which we initially collected it, or otherwise required by law.
Financial records, and any personally identifiable information therein, will be kept for at least 7 years, as required by the Inland Revenue Department of Hong Kong.
For questions or concerns relating to privacy, we encourage you to contact us at firstname.lastname@example.org.