1. Introduction
This Privacy Policy explains how UPGRD® (referred to as "the Company", "We", "Us", or "Our") collects, uses, and discloses Your information when You use our services. It also outlines Your privacy rights and how the law protects You.
By using our services, You consent to the collection and use of information in accordance with this Privacy Policy.
2. Interpretation and Definitions
2.1 Interpretation
The words with initial capital letters have meanings defined in this Privacy Policy. These definitions apply whether the terms appear in singular or plural.
2.2 Definitions
For the purposes of this Privacy Policy:
- Account: A unique account created for You to access our services or parts of our services.
- Affiliate: An entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares or equity interest.
- Company: Refers to UPGRD®, including its affiliates and subsidiaries.
- Cookies: Small files placed on Your Device that contain details of Your browsing history.
- Country: Refers to [Your Country].
- Device: Any device that can access our services, such as a computer, cellphone, or digital tablet.
- Personal Data: Any information relating to an identified or identifiable individual.
- Service: Refers to the custom training programs and other services provided by UPGRD®.
- Service Provider: Any natural or legal person who processes data on behalf of the Company.
- Third-Party Social Media Service: Any website or social network through which You can log in or create an account to use our services.
- Usage Data: Data collected automatically from the use of the Service or its infrastructure.
- Website: Refers to UPGRD® accessible from [Your Website URL].
- You: The individual accessing or using the Service or the company or entity on whose behalf the individual is accessing or using the Service.
3. Data Collection and Use
3.1 Types of Data Collected
- Personal Data: Includes but is not limited to:
- Email address
- First and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Usage Data: Includes information such as IP address, browser type, pages visited, time and date of visit, and other diagnostic data.
- Information from Third-Party Social Media Services: Personal data from services such as Google, Facebook, Instagram, Twitter, and LinkedIn, if You choose to register or log in through these platforms.
3.2 Tracking Technologies and Cookies
We use cookies and similar technologies to track activity and store information. This includes:
- Necessary / Essential Cookies: Session cookies essential for providing and securing our services.
- Cookies Policy / Notice Acceptance Cookies: Persistent cookies to remember your cookie preferences.
- Functionality Cookies: Persistent cookies to remember your preferences and settings.
- Tracking and Performance Cookies: Persistent cookies used by third parties to analyze traffic and usage.
4. Use of Personal Data
We use Personal Data for:
- Providing and maintaining our Service.
- Managing Your Account and improving service functionality.
- Performing contracts and managing transactions.
- Communicating with You, including updates and offers.
- Managing requests and providing targeted advertising.
- Conducting business transfers and evaluating company changes.
- Analyzing data and improving our services.
5. Data Sharing and Disclosure
We may share Your Personal Data:
- With Service Providers: For monitoring and analyzing Service usage, processing payments, and communicating with You.
- For Business Transfers: During mergers, acquisitions, or asset sales.
- With Affiliates: To honor this Privacy Policy and support our services.
- With Business Partners: To offer products or services.
- With Other Users: When You interact publicly or through Third-Party Social Media Services.
- With Your Consent: For any additional purposes with Your permission.
6. Data Retention
We retain Personal Data only as long as necessary for the purposes outlined and to comply with legal obligations. Usage Data is retained for shorter periods, except when used to improve Service functionality or required by law.
7. Data Transfer
Your Personal Data may be processed and stored outside Your jurisdiction. We will ensure adequate protection measures are in place to safeguard Your data during such transfers.
8. Data Deletion
You have the right to request deletion of your Personal Data. You can update or delete information via your account settings or by contacting us directly.
9. Disclosure of Personal Data
We may disclose Personal Data if required by law or to protect our rights, prevent wrongdoing, or ensure safety.
10. Security of Personal Data
While we strive to use commercially acceptable means to protect Your data, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security.
11. Detailed Information on Data Processing
Our third-party Service Providers may access and process Your data. We use services like Google Analytics and Matomo for monitoring and analysis.
12. Email Marketing
We may use Your data to send newsletters or promotional materials. You can opt-out by following unsubscribe instructions in emails or by contacting us.
13. Payments
Payment details are processed by third-party services. We do not store payment card details. Payment processors adhere to PCI-DSS standards.
14. Behavioral Remarketing
We use remarketing services like Google Ads and Facebook to serve personalized ads. You can opt-out of personalized advertising through various platforms and settings.
15. Children's Policy
Our services are not intended for individuals under 13. If we collect data from minors without consent, we will take steps to remove it.
16. Links to Other Websites
Our Service may contain links to other websites. We are not responsible for their content or privacy practices.
17. Changes to This Privacy Policy
We may update this Privacy Policy and will notify You via email or a prominent notice on our Service. Changes are effective when posted.
18. Contact Us
For any questions about this Privacy Policy, please contact us at:
Email: support@upgrd.com