UPFOLIO PRIVACY POLICY

Effective Date: January 18, 2018

This Website is the property of Upfolio LLC, doing business as Upfolio.com (“Upfolio,” “We” or “Us”).  We understand the importance of the information you entrust to us, and have published this Privacy Policy to describe our practices concerning the information we collect from you when you use the Upfolio website (the “Site”) and any mobile or desktop application we may develop.

This policy is incorporated into our Terms of Service as if fully set forth therein, and describes: (i) the types of information we collect when you use our Site (ii) how we use and protect that information; and (iii) third parties we may share your information with; (iv) how long we retain it; and (v) your rights and options as they pertain to the information we collect.  By using our Site, you consent to our collection and use of your information as described in this Privacy Policy.

1.  WHAT INFORMATION DO WE COLLECT?

We collect two basic types of information:

(a) Personally identifiable information (PII):  PII is information that identifies you as an individual. As of the effective date of this Privacy Policy, when you request to receive newsletter, emails, or other communications, complete surveys, or participate in sweepstakes, contests or other promotions, we ask you to provide us with your first name, last name, and email address.  If you contact us with questions or requests, you may also be asked to provide additional PII if it is required for us to respond.  If you are selected as the winner of a sweepstakes, contest, or any other promotion that we sponsor or promote, we may request additional information in order to deliver your prize, including your shipping address, phone number, and any other information we may need to fulfill your prize.

If you contact us or we contact you through the Site, via a customer support messaging system, through third party sites including but not limited to social media sites, or by any other means, you may also be asked to provide additional PII if needed for us to respond.  

If you upload your PII to the Site, it will also be stored on the Site. This information may include your investment portfolio amounts, investment assets, profile information, and other information, if you chose to share it with us.

Also, if you choose to login to our Site through a social networking site, you are granting us permission to access and use certain information about you as permitted by the social network. For example, if you use Facebook to login, it may provide us with access to whatever information you choose to include in your public profile, such as friends’ names, pictures, genders, user Ids, connections, and any other shared content.

NOTE:  If you post any comments, information, or other content on our Site that include PII, you are making that information available to all of our visitors, and this Privacy Policy will not apply in that instance. This includes, but is not limited to, information posted to any public area of the Site, including but not limited to any forum, comments, testimonial, feedback, and review sections of the Site. Please think carefully before disclosing PII or other information on the Site. All such information is not confidential and Upfolio shall be free to reproduce, disclose, use, and distribute such information to others without limitation or attribution and it may be used by others in ways Upfolio cannot prevent.

(b) General Information:  General Information consists of information that is anonymous in nature and does not identify you as an individual. We use cookies to collect General Information.  A “cookie” is a type of software used to gather and store visitor information. The General Information we collect includes (but is not limited to) your computer IP address (when not tied to your particular account), unique mobile device identifier, browser type, ISP or carrier name, searches, date and time of your visit, clicks on the Site, functions and features you used, and the URL of the last webpage you visited before visiting our Site.  We may also use persistent cookies to collect General Information. Persistent cookies will remain stored until it expires or you delete your cookies. We also use analytical tracking and usage analysis software to collect General Information about online behaviors, which are further discussed in Section 7 below. We may also use tracking pixels. A tracking pixel is a tiny pixel-sized image that allows us to track your Site visits, advertising impressions, and other types of Internet activity. It's also sometimes called a web bug, beacon, or page tag. We may use the information collected for various reasons, including analysis, service improvements, research, statistics, Site improvements, to compile anonymous and aggregate information about usage of the Site, and more.

Most browsers accept cookies by default. You can disable cookies in your browsers or refuse to accept them. If you do so, certain parts and functions of the Site may not function properly.

Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en

We use Google AdSense Advertising on our Site.

Google, as a third-party vendor, uses cookies to serve ads on our Site. Google's use of the DART cookie enables it to serve ads to our users based on previous visits to our Site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.

We have implemented the following:
   • Remarketing with Google AdSense
   • Google Display Network Impression Reporting
   • Demographics and Interests Reporting
   • DoubleClick Platform Integration

We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our Site.

Opting out: Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

(c) Registration and Paying Users:  In order to access certain areas of the Site and to use certain free and paid functionality of the Site, you will need to complete a registration form. During registration you will be required to provide us either:

- Your email address, password, and a username
- Your account information with one of the following social internet services: Facebook, Twitter, Google+, Yahoo!, LinkedIn, or a similar social internet service

We use this information to keep accounts secure and unique, and to contact you should any problems occur.

When you sign into the Site using your social network credentials, such service sends Us your username, email address, and other PII associated with the credentials you've used.

In addition, users registered for any paid premium accounts (“Paid Users”) must provide payment information (name, credit card information, or PayPal account information). This information is used for billing purposes only and is processed by PayPal or Stripe, our payment processors. Our partners may also collect PII such as your billing address. This information is protected by our processors' privacy policies, which is stated on their websites. When you are making a payment, We do not have access to your personal and credit card information. Should We have any issues with processing an order, the provided email address will be used to contact you.

(d) Information Sent by Your Mobile Device: We collect certain information that your mobile device sends when you use our services, like a device identifier, user settings and the operating system of your device, as well as information about your use of our services.

Location Information. When you use our App, we may collect and store information about your location by converting your IP address into a rough geo-location or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.

2.  HOW DO WE USE THE INFORMATION WE COLLECT?

(a) How We Use PII:  We use your PII to interact with you on a personal level.  For example, we use your name and email address to respond to your questions or comply with your requests (i.e., send you our newsletter or enter you into a sweepstakes, contest, or other promotion), and to send you important information (such as changes to this policy or our Terms of Service) and to send promotional emails, some of which may contain product offers from third parties. You may opt-out of receiving non-account related emails by clicking on the “unsubscribe” link located at the bottom of the email.  

(b) How We Use General Information:  We use the General Information we collect to obtain insights on how people use our Site.  For examples, we may use aggregated (not personally identifiable) information from all users for our research, business, and marketing purposes and we reserve the rights to share any and all of that data with third parties, including for commercial and marketing use. We may offer ads and services based on how people invest, the nature of their portfolios, etc. We also use this information for various internal business purposes, and to ensure that our Site continues to appeal to our users.

3.  HOW DO WE SHARE INFORMATION?  We will share information with third parties in the following ways:  

(a) We contract with other companies and individuals to perform functions or services on our behalf, such data storage and analysis, hosting the Site, sending email messages, monitoring Site activity, sweepstakes administration, and promotional assistance.  We necessarily have to share your PII with such third parties as may be required to perform their functions. As of the effective date of this policy, we share information with the following third party service providers, including:

(i) MailChimp, Microsoft, Google, GoDaddy, Webflow, MailShake: Email services;
(ii) RaffleCopter, MailChimp, MailShake, Microsoft, Google:  Sweepstakes, and other promotional administration;
(iii) Webflow, Amazon AWS, GoDaddy:  Hosting
(iv) Facebook, Twitter, Instagram, Google, Microsoft, Reddit, StumbleUpon: Social media services and promotions;

Note that we may change or add other service providers at our discretion. We will only share as much of your information with these parties as may be required for them to perform their services.

(b) If requested or required by law enforcement authorities, courts, or regulators, we may disclose any information we have about our users. We also may disclose your PII to exercise or protect legal rights or defend against legal claims.

(c) In some cases, we may choose to buy or sell assets. In these business transfers, customer information, including PII, is typically one of the business assets that are transferred.  If all or substantially all of our business assets were acquired, or in the unlikely event that we go out of business or enter into bankruptcy, customer information (including your PII), would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any assets may continue to be used according to your PII as set forth in this policy.

(d) We may reserve and have the right to disclose any information about you or your use of our Site without your prior permission, if we in good faith believe that such action is necessary to: (i) protect and defend the rights, property or safety of our company or its affiliates, other users of the Site, or the public; or (ii) to enforce our Terms of Service.

4. HOW DO WE PROTECT YOUR INFORMATION?  We use appropriate technical and organizational measures, including SSL encryption, to protect your personal information against unauthorized or unlawful access, processing and against accidental loss, destruction or damage.  We also limit access to personal information about you to employees who reasonably need access to it to provide our Site, or in order to do their jobs.  However, because no security system can be 100% effective, we cannot completely guarantee the security of any information we may have collected from or about you.  In addition, we have no control over the security of other web sites on the Internet that you might visit even when a link may appear to those websites from our Site. If you share your computer or use a computer that is accessed by the general public, remember to log off and close your browser window when you have finished your session.  

5.  HOW LONG DO WE KEEP INFORMATION?  We reserve the right to retain PII and General Information we collect from you for as long as we deem necessary to satisfy a business purpose.  If you unsubscribe from our email list, we will delete your email address; however, unless you participated in a sweepstakes or other promotion, in which case we will maintain the record as required by law.

6. CAN I CONTROL HOW MY INFORMATION IS USED? You may opt-out of receiving non-account related emails by clicking on the unsubscribe link included with every email.  We do not currently offer any additional options on the use of PII.

7.  HOW WE USE TRACKING TECHNOLOGY.  We employ certain technologies, such as Google Analytics, Heap Analytics, Hotjar, DoubleClick, and others provided by Google, Microsoft, Amazon, Etsy, Facebook, Twitter, Instagram, AffiliateWindow, Apple, CommissionJunction, Fastly, Shareaholic, and others, that enable us and third parties to track your online activities on our Site over time, and to a certain extent across third-party websites.  We offer no response to browser Do-Not-Track requests, but you can prevent certain online tracking applications (such as Google Analytics) from recognizing you on return visits to this Site by disabling cookies on your browser.

8.  CHILDREN UNDER 13.  Children under the age of 13 are not permitted to subscribe for email newsletters or participate in our promotions.  We do not knowingly collect any personal information from children under 13.  If we become aware that someone attempting to register on our Site is under 13, we will attempt to delete the information he or she provided as soon as possible.  

9. THIRD-PARTY LINKS. Our Site includes advertisements and links to other websites through which you may access information or purchase items featured on this Site. If you choose to visit any linked website, the collection and disclosure of your information by the operator of that website will be governed solely by that entity's privacy policy. We make no representations or warranties regarding these websites. In addition, our Site may include social media features and widgets, such as the Facebook “Like” button, the “Share This” button and other interactive mini-programs (collectively, the “Social Media Features”). The Social Media Features may collect Information such as your IP address and which page you are visiting on the Site, and may also set a cookie to enable the Social Media Feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Site. Your interactions with the Social Media Features are subject to the privacy policy of the company providing it.

10. FOR CALIFORNIA USERS. In addition to the rights set forth in this Privacy Policy, Residents of California ("California Users"), may request information regarding the types of personal information we share with third parties for direct marketing purposes, and the identities of the third parties with whom we have shared such information during the immediately preceding calendar year. California Users may request further information about our compliance with this law by sending us a message via the email address set forth below. Please note that we are only required to respond to one request per customer each year concerning this law, and we are not required to respond to requests made by means other than via email.

11. CHANGES TO THIS PRIVACY POLICY. We reserve the right to amend, alter, or otherwise change this Privacy Policy at our sole and absolute discretion. If we make any changes regarding the disclosure of Personal Information to third parties, we will inform all registered Users, and post notice of the new Policy from the privacy link on our Site.  Further use of this Site following any such change constitutes your agreement to follow and be bound by the amended Privacy Policy.

12. DO YOU HAVE ANY QUESTIONS? If you ever have any questions about our online privacy policy, please contact us. We respect your rights and privacy, and will be happy to answer any questions or concerns you might have.   You may direct any such questions to us via the email address below or the Contact Us page on our Site.

Upfolio LLC
simon@upfolio.com