Effective May 1, 2023
As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization within the United States or internationally.
• What data do we collect?
• How do we collect your data?
• How will we use your data?
• How do we store your data?
• With whom do we share your data?
• What are cookies?
• What types of cookies do we use?
• How to manage your cookies
• Privacy policies of other websites
• Our policy toward children
• Links to other sites
• How to contact us
• Notice to European Data Subjects
• What are your data protection rights?
What data do we collect?
We collect data in order to provide and improve our Site, Application, services, features and content, to administer your use of the Site, services and Application (together, the “Service”) and to enable users to enjoy and easily navigate the Service. Specifically, our Company collects the following data:
• Personal Identification Information
In order to provide the Service to you, we collect your email address and phone number (“Personal Information”). We collect this Personal Information in connection with your registration to join and use the Service.
Alternatively, you can register to join or use the Service or by logging into your account with certain third-party social networking sites (“SNS”) (including, but not limited, to Facebook) via our Service. If you decide to register by logging into an SNS via our Service, we will obtain the Personal Information you have provided to the SNS (such as your “real” name, profile picture, email address and other information you make publicly available via the applicable SNS) from the account you have with the SNS and use that information to create your account. The information we obtain may depend on the privacy settings you have with the SNS.
• Non-Identifying Information
We also collect other information that you provide as part of your use of the Service, which does not identify you.
We collect device data, such as device IP address (and derived location), device name and operating system, browser type and settings, telecommunications provider, operating system, the date and time of use, interactions with the Service, and the time, frequency, and duration of the interactions.
Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences).
We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other Upward Path Institute Users (defined below) to attempt to provide you with a better experience, to improve the quality and value of the Service and to analyze and understand how our Site, Application and Service are used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.
All Upward Path Institute clients may review, update, correct or delete the Personal Information in their registration profile by contacting us. If you completely delete all such information, then your account may become deactivated. If you would like us to delete your Account in our system, please contact us at email@example.com. with a request that we delete your Personal Information from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes
How do we collect your data?
You directly provide us with most of the data we collect. We collect data and process data when you:
• Register online for our Service;
• Voluntarily complete a customer survey;
• Use or view our Site via your browser’s cookies;
• Participate in a promotion on our website;
• Click on a third-party advertisement on our Site; or
• Log into your account with certain third-party SNS.
Additionally, when you visit the Site and Application, whether as an Upward Path Institute client or a non-registered user just browsing (any of these, a “Upward Path Institute User”). Our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type or the webpage you were visiting before you came to our Site, pages of our Site and Application that you visit, the time spent on those pages, information you search for on our Site and Application, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site, Application and Service and for the Site’s and Application’s technical administration, to increase our Site’s and Application’s functionality and user-friendliness, and to better tailor our Service to our visitors’ needs. For example, some of this information is collected so that when you visit the Site and Application again, it will recognize you and serve advertisements and other information appropriate to your interests. We also use this information to verify that visitors to the Site and Application meet the criteria required to process their requests. We do not treat Log Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.
We also use “web beacons,” “pixel tags,” “clear GIFs” or similar means (individually or collectively “Web Beacons”) on our Service. A Web Beacon is an electronic image, often a single pixel, embedded on web pages. Web Beacons is ordinarily not visible to users. Web Beacons allows us to count the number of users who have visited certain pages of the Service and to generate statistics about how our Service is used.
We support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
How will we use your data?
We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.
As an Upward Path Institute client, you can interact with and use SNSs. By using an SNS via the Service, you understand and agree that Upward Path Institute will access your SNS account information so that it is available to you through your use of the Site, Application and Service. Depending on the SNSs you choose to utilize via the Site, Application and Service, and in accordance with the privacy settings you have set in your SNS account you can post information (including your Personal Information) to your SNS account and information you have posted to an SNS will be available via the Site, Application and Service. Other services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other online services you use.
Although users pay to use our Site, payments are processed by a third-party and we do not store, process or have access to any of this financial data.
How do we store your data?
We store minimal user data on cloud-based servers in the United States. Additionally, we have servers around the world for audio and video delivery only; no data is stored in those servers. Personal data that is collected and processed is not held or further used unless for reasons that are clearly stated and agreed to in advance to support data privacy.
Upward Path Institute is very concerned with safeguarding your information. We employ reasonable physical, technological, and administrative security measures and attempt to ensure they are applicable under the circumstances. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security, and you use the Service at your own risk. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Identity theft and the practice currently known as “phishing” are of great concern to Upward Path Institute. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your login information, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.
With whom do we share your data?
We do not sell Personal Information, but we may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Site-related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Site’s features) or to assist us in analyzing how our Site and Service are used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Upward Path Institute cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Upward Path Institute or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.
Upward Path Institute may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.
If you connect your social media accounts to the Service, we will also inform those companies that you have authorized its access to your accounts with those companies.
If you choose to make any client Content available via the Service and you have connected your use of the Service with an SNS, your SNS friends will be able to access and view such client Content via the Service. We recommend that you guard your anonymity and sensitive information.
The Site has third party advertisements that you may click if you wish. No user’s information will be provided by us unless you click on the advertisement. We do not send any marketing by email.
What are cookies?
Cookies are text files placed on computer’s hard disk for record-keeping purposes, standard Internet log information, and visitor behavior information. When you visit our Sites, we may collect information from you automatically through cookies or similar technology. For further information, visit allaboutcookies.org.
We utilize persistent cookies to save your login information for future logins to the Site, Application and Service. We utilize session ID cookies to enable certain features of the Site and Application, to better understand how you interact with the Site and Application and to monitor aggregate usage by Upward Path Institute Users and web traffic routing on the Site and Application. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Site, Application and Service and then close your browser.
Third party advertisers on the Site may also place or read cookies on your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site or all functionality of the Service.
What types of cookies do we use?
There are a number of different types of cookies. However, our website uses:
Functionality – We use these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. We use a mix of first-party and third-party cookies.
Advertising – We use these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. We sometimes share some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.
How to manage your cookies
You can set your browser not to accept cookies, and allaboutcookies.org tells you how to remove cookies from your browser. However, in a few cases, some of our Site features may not function as a result.
Privacy policies of other websites
Our policy toward children
The Site, Application and Service are not directed to persons under the age of 13. We do not knowingly collect personally identifiable information from children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at firstname.lastname@example.org. If we become aware that a child under the age of 13 has provided us with Personal Information, we will delete such information from our files.
How to contact us
Notice to European Data Subjects
We are providing this supplemental privacy notice to European data subjects, pursuant to European data protection laws (“GDPR”). We are responsible for how your personal data is handled. This means we are the controller of your personal data under the GDPR.
Personal Data We Collect From You and How We Use It. You can read about the personal data we collect from you and how we use it in the sections above: “What data do we collect?” and “How will we use your data?”
Justification for Data Processing. We process data in order to offer our Service to our users. As a result, providing the minimal amount of Personal Information that we collect to open an account is required.
Recipients of Data. We may disclose your personal data to the recipients described in the “With whom do we share your data?” section above.
Retention of Data. We retain only your email and password so that you can sign-in to your account. This information is retained as long as you have an account with us.
Storage. We are based in the United States and rely on cloud storage providers that store user data (email and password) on our behalf in the United States. Additionally, we have servers around the world for audio and video delivery only; no data is stored in those servers.
To exercise these rights, please email us at email@example.com. You also have the right to complain to a data protection authority in your country about our processing of your personal data.
What are your data protection rights?
We would like to make sure you are fully aware of all of the data protection rights granted to European data subjects by the GDPR. Every user is entitled to the following:
The right to access – You have the right to request from us copies of your personal data. We may charge you a reasonable fee for this service. Other than your email, we do not store your personal data.
The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete. Other than your email, we do not store your personal data.
The right to erasure – You have the right to request that we erase your personal data, under certain conditions. Other than your email, we do not store your personal data.
The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions. Other than your email, we do not store or process your personal data.
The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions. However, we only process personal data that you provide to us when registering to use the Service.
The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions. Other than your email, we do not store your personal data.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at firstname.lastname@example.org. or at: Upward Path Institute, Inc., 2100 Geng Rd., Suite 210, Palo Alto, CA 94303.