UPLINX PRIVACY POLICY - www.uplinx.com

UPLINX PRIVACY POLICY

Last Updated: 19 September 2018

Who We Are

UPLINX SLU ("UPLINX", "we" or "us" or "our") gather and process your personal information in accordance with this Privacy Policy and in compliance with the relevant data protection regulation and laws. The terms Privacy Policy, Privacy Notice or notice in short are used interchangeable. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

UPLINX SLU registered office is at Av. Sant Antoni 26, 1-1, AD400 La Massana, ANDORRA, with company registration number 925983 and tax registration L-711298-N. The GDPR regulation of the European Union applies to our business.

We are the provider of the website www.uplinx.com and licensing.uplinx.com (containing our licensing portal and shop) (hereinafter referred to as the "Website" and act as the responsible data controller when processing your data. Our Data Protection Officer can be contacted by  'Contact Us'. We are processing personal data only in accordance with this Privacy Policy.

Information That We Collect

UPLINX processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice. Personal data refers to any information that tells us something about you or that we can link to you. We process the following categories of information:

Information You Give to Us

We collect your personal information that we received from you when you use the Website, including personal information you provide to us including when you: enquire or make an application for one of our products or our service, register to use and/or use any of our services and when you communicate with us through e-mail, the Website, or any other electronic means.

The personal data that we collect may include your name including first name and family name, e-mail addresses, billing address, telephone numbers, username, password.

Information We Automatically Collect from Your Use of the Website

We collect information about the services that you use and how you use them, like when you visit our Website, licensing portal or online shop and interact with our content. This information includes:

  • Device information. We collect device specific information such as IP address, access dates and times, hardware and software information, device information, cookie data.

  • Geo-location Information. When you use certain features of the Website, we may collect information about your approximate location as determined through data such as your IP address.

  • Usage Information. We collect information about your interactions with the Website such as the content you view, your searches queries and other actions on the Website.

  • Cookies and Similar Technologies. We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers. We may also allow our business partners to use these tracking technologies on the Website, or engage others to track your behaviour on our behalf. For more information on our use of these technologies, see our Cookie Policy.

  • Payment Transaction Information. We collect information related to your payment transactions through the payment platform, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details.

Information We Collect from Third Parties

We may collect information, including personal information that others provide about you when they use the Website, or obtain information from other sources and combine that with information we collect through the Website. We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

UPLINX does not collect or store Credit Card information

UPLINX uses 3rd party payment processors to receive payment for orders. Credit card information is not supplied to UPLINX by a 3rd party payment processor. Credit card information is entered directly on the 3rd party payment processor web page . The 3rd party payment processor will only transmit the result of a payment operation such as payment successful or failed. UPLINX will only store the result of a payment operation and has no access to Credit card information.

How We Use Your Personal Data (Legal Basis for Processing)

UPLINX takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time. The purposes and reasons for processing your personal data are detailed below:

Provide our Services and Products

  • We collect your personal data in the performance of a contract or to provide a service and to ensure that orders are completed and can be sent out to your preferred address.
  • We collect and store your personal data as part of our legal obligation for business accounting and tax purposes.
  • We will occasionally send you license renewal notifications or license keys that or requested or marketing information where we have assessed that it is beneficial to you as a customer and in our interests. Such information will be non-intrusive and is processed on the grounds of legitimate interests.
  • Operate, protect, improve, and optimize the Website, such as by performing analytics and conducting research.
  • Provide customer service and support.
  • To identify and resolve issues in our software products, we may request log files or screenshots that may contain your personal information. We will only analyze these log files for the purpose to resolve the issue. We will not collect or process any personal information included in these log files.
  • Send you service or support messages, updates, security alerts, and account notifications.
  • To operate, protect, improve, and optimize the Website, and personalize and customize your experience (such as making suggestions or ranking search results), we conduct profiling based on your interactions with the Website, your search and viewing history, your profile information and preferences, and other content you submit to the Website.

Protect us and our Users and Comply with Legal Obligations

  • Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
  • Conduct security investigations and risk assessments.
  • Comply with our legal obligations.
  • Resolve any disputes with any of our users and enforce our agreements with third parties.
  • Enforce our Terms of Service and other policies.

We process this information given our legitimate interest in protecting the Website or pursued by a third party and to comply with applicable laws.

Legitimate Interests

As noted in the 'How We Use Your Personal Data' section, we occasionally process your personal information under the legitimate interests' legal basis. Where this is the case, we have carried out a thorough Legitimate Interests' Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.

We use the legitimate interests' legal basis for processing of orders and quotes, email notifications for license or contract renewals for you or your users by us or our automated systems and have identified that our interests are to provide you with timely notifications or security alerts about our services and products.

COOKIES POLICY AND GOOGLE ANALYTICS

We use cookies to collect information about how the Website is used

Cookies are text files that are placed by the browser in the memory of a user's device when our website is visited. Our website uses session cookies and persistent cookies. The user can disable the cookie function in his browser options. Please see the specific information of the browser used for visiting this website. For details how to control and/or delete cookies, see aboutcookies.org. If cookies are disabled the user might not be able to use all the functions and services of the Website.

In addition, we use Google Analytics, a web analytics service provided by Google, Inc. (hereinafter referred to as "Google"), using third-party cookies that enable Google to analyze the use of the Website. The information generated by the cookie about the use of this website is transferred to a Google server in North America.

Google will use this information on our behalf to evaluate the use of the Website, to compile reports for activities on the Website, and to provide other services to us relating to the Website.

Google Analytics operates under the following terms:

The user can prevent Google from collecting and processing the data concerning the use of the Website (including the IP address) by installing a browser-plug-in which is available under https://tools.google.com/dlpage/gaoptout.

SECURITY

Note that all data is kept in a secure environment. We protect personal data by using appropriate safeguard procedures and measures, in particular:

  • We encrypt our services using SSL (you can reach our SSL protected website under https://www.uplinx.com/).
  • We use firewalls to protect your information.
  • We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems.
  • We restrict access to personal information to employees, contractors and agents who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations.

If you know or have reason to believe that your account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please 'Contact Us'.

YOUR RIGHTS

You have the right to access any personal information that UPLINX processes about you and to request information about:

  • What personal data we hold about you
  • The purposes of the processing
  • The categories of personal data concerned
  • The recipients to whom the personal data has/will be disclosed
  • How long we intend to store your personal data for
  • If we did not collect the data directly from you, information about the source

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information by  'Contact Us' and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified. If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

Sharing and Disclosing Your Personal Information

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement.

We use trusted third party payment processors (Mora Banc, Paypal, 2Checkout, Digital River) to process your payment by credit card, PayPal or bank transfer. Information that you entered in our online shop may be transmitted to these payment processors for the purpose to process your payment.  All processors acting on our behalf process your data in accordance with their own policies and data protection laws and not our privacy policy.

Rectification of Inaccurate or Incomplete Information

You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your account).

How Long We Keep Your Data

We only ever retain personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under Andorran tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed. If you no longer want us to use your information to provide any services to you, you can request that we erase your personal information and close your account. Please note that if you request the erasure of your personal information:

  • We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an account for fraud or safety reasons, we may retain certain information from that account to prevent that user from opening a new account in the future.

  • We may retain and use your personal information to the extent necessary to comply with our legal obligations.

  • Because we maintain the Website to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

Lodging Complaints

Any comments, complaints or questions concerning this policy or complaints or objections about our use of your personal information should be addressed by directing your comments to UPLINX's Data Protection Officers, whose contact information is found in 'Contact Us'.

Transfers Outside the EU

Personal data in the European Union is protected by the General Data Protection Regulation (GDPR) but some other countries may not necessarily have the same high standard of protection for your personal data.

We utilise some products or services (or parts of them) that may be hosted or stored in the United States, which means that we may transfer any information which is submitted by you through the website outside the European Economic Area ("EEA") for the below purposes:

  • Web Server (www.uplinx.com) that is fully managed by UPLINX
  • Email is processed according to Inmotion Hosting Privacy Policy.
  • Third party payment processors such as Paypal, 2Checkout, Digital River that are all located in the United States. Information that you entered in our online shop may be transmitted to these payment processors for the purpose to process your payment.  All processors acting on our behalf process your data in accordance with their own policies and data protection laws and not our privacy policy.

Therefore, when you use our website, send us an email, contact us, the personal information you submit may be stored on servers which are hosted in the United States. Where this is the case, we will take steps to ensure that those providers use the necessary level of protection for your information.

UPLINX's websites or services may include links to third-party websites. In using such links, please be aware that each third-party website is subject to its own privacy and data protection policies and is not covered by our Privacy Policy.

CHANGES TO THIS PRIVACY POLICY

Please note that UPLINX's Privacy Policy is reviewed periodically. We reserve the right to modify its Privacy Policy at any time without notice. Any changes to the Privacy Policy will be posted on this page and will become effective on the date of posting. We encourage you to periodically review this page for the latest information on our privacy practices.

CONTACT US

You may contact our Data Protection Officer at DPO Email - image to protect or by mail to:

DPO
Uplinx SLU
Av. Sant Antoni 26, 1-1
AD400 La Massana
ANDORRA