Privacy Policy

Privacy Policy

Welcome to UPGADE CORP, LLC ("UPGADE," "we," "us," "our") and thank you for visiting our website located at www.upgade.com (the "Site"). We are committed to protecting the privacy of our users ("user" or "you"). This Privacy Policy explains how we collect, use, disclose, and protect your personal information.

At UPGADE, we are committed to addressing your privacy concerns. Our Global Privacy Statement outlines the types of personal information we collect, how we use it, who we share it with, and your options for managing your information. We also describe the security measures we use to protect your information and provide contact information for any privacy-related inquiries.

This Global Privacy Policy applies to all UPGADE websites, mobile apps, and both online and offline processing of personal information, except where explicitly stated otherwise in a separate privacy statement. Our privacy policies may vary by country to comply with local customs and regulatory standards.

Information We Collect

We may collect information about you through various means, including our websites, subscription agreements, and other forms that you or others provide to us. The personal information we collect includes your contact details (such as name, address, and phone number), birthdate, online account information, records of your interactions with us, and additional information provided by you via emails, subscription documents, and other forms.

If you are a job applicant, we may also collect additional information, such as national identifiers, employment and educational backgrounds, language proficiency, and criminal background check findings.

You provide this personal information voluntarily, but without certain information, we may not be able to provide goods and services, or you may not be able to access certain website features.

We may also obtain personal information from other sources, such as credit bureaus, regulatory bodies, and third parties involved in managed investment schemes, to operate our business and market our products and services, in compliance with applicable laws.

We collect information via automated methods

While visiting our Sites, using UPGADE-related widgets, plug-ins or reading emails, we may automatically gather information about you through various means like cookies, web beacons, web server logs and JavaScript. A cookie is a text file that websites use to recognize a visitor's browser and to store information or settings in it. A web beacon, also known as an Internet tag, pixel tag or clear GIF, is a connection between web pages or apps and web servers which can send data back to a server.

We collect technical information such as IP addresses, browser and operating system characteristics, unique device identifiers, clickstream data, language preferences, information on actions taken, referring/exit URLs, dates and times of activity, and other similar data to provide you with personalized services and enhance your experience on our Sites. These technologies help us to remember your information, understand how you use and interact with our products and services, customize our products and services to your preferences, evaluate the effectiveness of our communications, and improve our products, services, and Sites in other ways.

If you wish to disable cookies, you can do so by adjusting your browser's or device's settings. Most browsers provide options to prevent new cookies from being accepted, to be informed when a new cookie is received, and to disable existing cookies. On mobile devices, you can manage how your device and browser share some device data by changing your privacy and security settings. However, please be aware that disabling cookies may limit some features of our Sites. You can find more information on managing cookies by visiting www.aboutcookies.org.

Services provided by third-party analytical tools

We use third-party web analytics platforms, like Google Analytics, Sitecore, and Webtrends, on our websites to understand how visitors use the sites. These analytics companies use technologies such as cookies, web beacons, and web server logs to gather information, including your IP address and other automatically collected data, to help us evaluate site usage. This information is shared with third-party service providers and other relevant third parties who use it to analyze site usage. To learn more about these analytics services and how to opt out (if applicable), please visit the following link:

Google Analytics
Sitecore
Webtrends

Internet Tracking and Advertising Based on User Interests

When you visit our Websites, we may collect information about your online activities across various third-party websites to present you with targeted advertisements about products and services, subject to your permission in compliance with relevant laws. Our partnership with advertising networks allows us to target visitors based on their demographic information, inferred interests, and browsing context. To achieve this, the networks use technologies like cookies, web beacons, and web server logs to collect information about users' online behavior over time. This information is then used to display advertisements that align with users' interests and to create a profile of their online browsing activities. Our ad networks may also collect information about users' visits to sites and apps that are part of the ad networks, including the pages or ads viewed and actions taken. This data collection occurs on the Sites and on third-party websites and apps that are part of the ad networks. We use this process to evaluate the success of our marketing efforts.

Our Websites may not fully adhere to browser-based "do not track" signals. If you wish to opt out of interest-based advertising from ad networks in the United States or the European Union, please visit the following links: www.aboutads.info/choices, www.networkadvertising.org/choices, preferences-mgr.truste.com, and www.youronlinechoices.eu.

How We Use Your Information

The personal information we gather may be utilized in the following ways:

To offer and administer our goods, services, and websites, including managing your accounts and creating a UPGADE online account. To communicate with you through various means and address your concerns. To validate your identification and perform background checks for goods or services applications. To analyze data for market and consumer research. To develop, manage, and improve our business, products, services, and Sites, including accounting and finance functions, auditing, billing, and reconciliation, and safeguarding against fraud and illegal activities. To conduct investigations and ensure compliance with relevant laws, regulations, contractual obligations, and policies.

We may use personal information for any other reason permitted by law or for which you have provided consent. Generally, we use personal information to comply with legal requirements, fulfill contractual obligations, and pursue legitimate business purposes. We will seek consent where necessary under applicable laws, and we may also use personal information in ways not originally disclosed.

Data We Share with Others

We do not sell or disclose your personal information, except as stated in this Policy. We share your personal information with our affiliates for the reasons specified in this Global Privacy Policy. Additionally, we share information with service providers who perform functions on our behalf, but we do not allow them to use or disclose information about you unless it is necessary to perform services on our behalf or to comply with applicable laws. Service providers include account administrators and companies that provide web hosting, analytics, and other information technology services. Your authorized agents may also have access to your personal information.

We may disclose information about you in certain circumstances, such as when required by laws and regulations, in response to a legitimate request from law enforcement or other government agencies, or to establish, exercise, or protect our legal rights. We may also disclose information if we believe it is necessary to prevent harm or financial loss or in connection with an investigation into fraudulent or illegal activities. In the event that we sell or transfer all or part of our company or assets, we may also disclose personal information about you. Additionally, we may use the personal information we collect in ways that were not disclosed at the time of collection.

Transfers of Data

We may share your personal information with recipients located in other countries outside of the country where you originally submitted the information. These countries may have different levels of data protection compared to the country where you provided the information. We will take measures to protect your information when transferring it to recipients in other countries, to the extent permitted by applicable laws (such as to the United States, Singapore, Australia, or Indonesia).

If you are a resident of the European Economic Area ("EEA") or Switzerland, we will comply with applicable legal requirements to provide adequate safeguards for the transfer of personal information to recipients in countries where the European Commission has not issued an adequacy decision. If you are a resident of the United Kingdom, we will comply with relevant legal obligations to provide adequate protections for the transfer of personal information to recipients in countries where the Official has not issued an adequacy decision. These protections may include data transfer agreements, which you can obtain by contacting us as described in the How to Contact Us section of this Global Privacy Policy.

Your Rights and Alternative solutions

We offer you several options regarding the personal information we collect about you. If you want to change your preferences, unsubscribe from our mailing lists, or make a request concerning your personal information, you can contact us using the information provided in the "How To Contact Us" section of this Global Privacy Policy. Moreover, you can opt-out of receiving our marketing emails by clicking the "Unsubscribe" link in any of our emails.

Depending on the applicable laws, you may have the right to (1) access the personal information we have about you, (2) request corrections, updates, deletion, or limitations to your data, or (3) exercise your right to data portability by contacting us as indicated below. If you are not satisfied with our response, you may, depending on your region, have the right to file a complaint with a governmental authority. You can withdraw any consent you previously provided to us or object to our processing of your personal information at any time, based on reasonable grounds related to your particular circumstances, and we will respect your choices going forward. To ensure the privacy and security of your information, we may take steps to verify your identity before granting access to your information. Depending on the relevant law, we may charge a fee for providing you with a copy of your personal information.

Hyperlinks Connections to Third-Party Sites, Applications, and Other Third-Party Features

Our Sites may contain links to other websites, applications, and features for your convenience and information. These websites, applications, and features may collect information about your interactions with them and your use of our Sites through automated means. They may operate independently of us and have their own privacy policies or notices, which we recommend that you review. We are not responsible for the content, practices, or privacy policies (including cookie practices) of any website, application, or feature that we do not own or manage.

Security

We utilize administrative, technological, and physical measures to ensure the safety and security of the personal information we collect. Our goal is to prevent unauthorized or unlawful use, disclosure, access, loss, destruction, or damage to the information we collect.

Personal Information Retention

We will retain your personal information as long as it is necessary and permitted by law, either to fulfill the purpose for which it was collected as stated in this Global Privacy Policy or if we have legal grounds to retain it beyond that time.

Personal Information about Children

The Sites are designed for a wide range of individuals and are not intended for minors under the age of 13. We do not intentionally gather or request personal information from minors under the age of 13 through the Sites. If we become aware that we have received personally identifiable information from a person under the age of 13 through the Sites, we will promptly remove the information from our records. If you believe that a child under the age of 13 may have provided us with personal information via the Sites, please contact us using the information provided in the How to Contact Us section of this Global Privacy Policy.

Global Privacy Policy Updates

We may change this Global Privacy Statement periodically to reflect modifications in our privacy practices, without providing prior notification to you. The date of the last revision will be indicated at the bottom of this Policy.

Addenda specific to Australia's region

If you are residing in Australia, the Australia Addition applies to you in lieu of and in addition to the relevant parts of the UPGADE Global Privacy Policy. In the event of a discrepancy between the UPGADE Global Privacy Policy and the Australia Addition, the Australia Additional point shall take precedence.

By agreeing to our Global Privacy Policy, you authorize UPGADE to collect, use, and disclose your personal information, including sending promotional and advertising messages. You may opt-out of receiving promotional messages from us at any time by following the instructions provided in such communications or by contacting us at legal(at)upgade.com.

By providing us with personal information, you acknowledge and consent to UPGADE transferring the information to foreign entities in the United States of America, Singapore, Indonesia, Hong Kong, Dubai, the United Kingdom, and the Cayman Islands. If an overseas recipient breaches the Australian Privacy Principles, you agree that UPGADE will not be held liable under the Privacy Act of 1988 (Cth), and that you will have no recourse under the Privacy Act. You may opt-out of receiving promotional messages from us at any time by following the instructions provided in such communications or by contacting us at legal(at)upgade.com.

• We are authorized to collect tax file numbers under the Income Tax Assessment Act 1936 (Cth) to manage investments in specific UPGADE products. Although it is not mandatory to provide your tax file number to receive our goods and services, failure to do so may result in additional deductions from payments due to you as per tax laws. You may opt-out of receiving promotional messages from us at any time by following the instructions provided in such communications or by contacting us at legal(at)upgade.com.

• If we obtain personal information that we did not solicit, we will assess whether we could have obtained the information legally had we sought it, within a reasonable time. If we determine that we could not have legally obtained the personal information, we will delete or de-identify the information as soon as possible, but only if it is legal and appropriate to do so. If we obtained the information legally, the Australian Privacy Principles 5 to 13 will apply to the information as if it were obtained in accordance with Australian Privacy Principle 3. You may opt-out of receiving promotional messages from us at any time by following the instructions provided in such communications or by contacting us at legal(at)upgade.com.

Contact Us

If you have any questions about this Privacy Policy or our practices, please contact us at privacy(at)upgade.com.

This Privacy Policy was last updated on March 1st 2023.