UPilot INC, and its affiliates (“UPilot INC” or the “Company”) are committed to responsible information-handling practices in relation to their UPilot business.
The following privacy statements describe the different types of personal information the Company handles relating to the UPilot Web sites and the UPilot Service (as defined in the Web Site Privacy Statement) and the Company’s privacy practices with respect to such personal information:
The Web Site Privacy Statement addresses the Company’s handling of personal information collected from visitors to the UPilot Web sites and users of the UPilot Service.
The Indexed Content Privacy Statement addresses the Company’s handling of information, including personal information, obtained from the Internet through the UPilot Service.
Questions about the Company’s information-handling practices as they relate to the UPilot Web sites and UPilot Service should be directed to the UPilot INC Privacy Office:
E-mail address: firstname.lastname@example.org
3500 South DuPont Highway,
Dover, DE 19901
UPilot INC Service Web Site Privacy Statement
Privacy Statement Effective as of August 1, 2020
UPilot INC and its affiliates (“UPilot INC” or the “Company”) are committed to protecting the privacy of individuals who visit the Company’s Web sites and individuals who register to use the Services as defined below. This Web Site Privacy Statement describes the Company’s privacy practices in relation to the use of the Company’s Web sites and the related applications and services offered by UPilot INC under the “UPilot” brand, and which applications and services are accessible via the Company Web site listed below or through Google Play™ or the Apple iTunes App StoreSM (the “UPilot Service” or our “Services”). To learn more about the Company’s privacy practices relating to content that is accessed, used and maintained in connection with the provision of the Services, please visit the Indexed Content Privacy Statement.
1. Web Sites Covered
This Privacy Statement covers the information practices of the Company’s Web sites that link to this Privacy Statement, including www.upilot.com (collectively referred to as the “Company’s Web sites”). The Company’s Web sites may contain links to other Web sites. The information practices or the content of such other Web sites are governed by the privacy statements of such other Web sites. The Company encourages you to review the privacy statements of other Web sites to understand their information practices.
2. Information Collected
THE INFORMATION WE COLLECT AND STORE
UPilot INC collects individually-identifiable information (“Personal Information”) from individuals who visit the Company’s Web sites (“Web Site Visitors”) and individuals who register to use the Services (“Customers”). When expressing an interest in obtaining additional information about the Services or registering to use the Services, UPilot INC may require you to provide the Company with personal contact information, including your name, company name, phone number, and email address (“Required Contact Information”). When purchasing the Services, UPilot INC may require you to provide the Company with Financial qualification and billing information, such as billing name and address, credit card number, and the number of employees within the organization that will be using the Services (“Billing Information”). UPilot INC may also ask you to provide, or otherwise allow you to share, additional information, which you may choose to share in your registration for or use of the Services (“Optional Information”). For example, UPilot INC may obtain Optional Information by asking a Customer to import his or her contacts and email history by granting UPilot INC access to the Customer’s third party services (for example, the Customer’s email account) or to use the Customer’s social networking information if the Customer gives us access to his or her account on a social network service. In order to use the UPilot Service, a Customer must link a third party email account to the Customer’s UPilot Service account. We then import, create, and update versions of the Customer’s address book and emails for the Customer to access in the UPilot Service. A Customer will also have the option to import and update versions of his or her calendar, social media contacts, and mobile phone call history, and the Customer can later choose to upload files to, or provide comments through, our Services. Required Contact Information, Billing Information, and Optional Information about Customers are referred to collectively as “Data About Customers”. With your permission (which you grant by signing up for or using our Services), UPilot INC collects and stores information you provide or that we collect in order to administer our Services and/or as otherwise described in this Privacy Statement or our Terms of Service.
As you navigate the Company’s Web sites or use the Services, UPilot INC may also collect information through the use of commonly-used information-gathering tools, such as cookies and Web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, HTTP header information, and the actions you take on the Company’s Web sites (such as the Web pages viewed and the links clicked). For additional information about the collection of Web Site Navigational Information by UPilot INC and others, please review Section 3 of this Privacy Statement.
3. Web Site Navigational Information
UPilot INC uses commonly-used information-gathering tools, such as cookies and Web beacons, to collect information from your Device as you navigate the Company’s Web sites, interact with e-mails sent by the Company on its own behalf, or use the Services (“Web Site Navigational Information”). This section describes the types of Web Site Navigational Information used on the Company’s Web sites and in connection with the Services, and how this information may be used.
|Type of Cookies
||Because required cookies are essential to operate the Company’s Web sites and the Services, there is no option to opt out of these cookies.
||These cookies collect information about how Web Site Visitors use the Company’s Web site, including which pages Web Site Visitors go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies a Web Site Visitor. All information these cookies collect is aggregated and anonymous. It is only used to improve how the Company’s Web sites function and perform.
From time-to-time, UPilot INC engages third parties to track and analyze usage and volume statistical information from individuals who visit the Company’s Web sites. UPilot INC may also utilize Flash cookies for these purposes. Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored.
|To learn how to opt out of performance cookies using your browser settings,click here.
To learn how to manage privacy and storage settings for Flash cookies click here.
||Functionality cookies allow the Company’s Web sites to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of the Services after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.
UPilot INC may use local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on the Company’s Web sites to personalize your visit.
|To learn how to opt out of functionality cookies using your browser settings click here. Note that opting out may impact the functionality you receive when visiting the Company’s Web sites.
To learn how to manage privacy and storage settings for Flash cookies click here.
|Analytics, Targeting and Advertising cookies
||From time-to-time, UPilot INC may engage third parties to track and analyze usage and volume statistical information from individuals who visit the Company’s Web sites. For example, we use Google Analytics to improve our Web site performance, run tests on the effectiveness of the Company’s Web sites and MARKETING efforts, and improve user experience.
Third parties with whom the Company may partner to provide certain features on our Company’s Web sites or to display advertising based upon your Web browsing activity, may use Flash cookies to collect and store information.
|To learn more about advertising networks and their opt out instructions, click here
To learn how to opt out of these cookies using your browser settings click here, and to learn how to manage privacy and storage settings for Flash cookies, click here.
Cookies that are used as part of the Services (in the proxy) may include cookies of a third party Web site that is being co-browsed, for example, in order to deliver the Web site as intended by the third party Web site operator. The cookie practices of such Web sites are governed by their own respective privacy statements. The Company encourages you to review the privacy statements of other Web sites to understand their information practices.
UPilot INC, or third parties with whom we contract, may use Web beacons alone or in conjunction with cookies to compile information about Customers and Web Site Visitors’ usage of the Company’s Web sites and interaction with emails from the Company. Web beacons are clear electronic images that can recognize certain types of information on your Device, such as cookies, when you viewed a particular Web site tied to the Web beacon, and a description of a Web site tied to the Web beacon. For example, UPilot INC may place Web beacons in marketing emails that notify the Company when you click on a link in the email that directs you to one of the Company’s Web sites. UPilot INC uses Web beacons to operate and improve the Company’s Web sites and email communications and track the clicking of links or opening of emails.
IP ADDRESSES, URLS, AND OTHER SITE DATA
Due to Internet communications standards, when you visit or use the Company’s Web sites, we automatically receive the URL of the Web site from which you came and the Web site to which you go when you leave the Company’s Web sites. We also receive your Device’s Internet Protocol (IP) address (or the proxy server you use to access the World Wide Web), your Device’s operating system, the type of Web browser you are using, and your Internet Service Provider (ISP). We may also collect information about the web page visited before or after you came to our website, information you search for on our website, locale preferences, identification numbers associated with your Devices, your mobile carrier, date and time stamps associated with transactions, system configuration information, metadata, and interactions with the Service. This information is used to analyze overall trends to help us improve the Service and to track and aggregate non-personal information. For example, UPilot INC uses IP addresses to monitor the regions from which Customers and Web Site Visitors navigate the Company’s Web sites.
SOCIAL MEDIA FEATURES
DO NOT TRACK
Currently, various browsers – including Internet Explorer, Firefox, and Safari – offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to Web sites’ visited by the user about the user’s browser DNT preference setting. UPilot INC does not currently commit to responding to browsers’ DNT signals with respect to the Company’s Web sites, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. UPilot INC takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.
4. Use of Information Collected
USE OF DATA ABOUT CUSTOMERS
Data About Customers. Data About Customers is or may be used: (i) to provide and improve our Services, (ii) to administer your use of our Services, (iii) to recommend follow-up reminders, assign tasks, or personalize the service, and (iv) to provide or offer software updates and product announcements. If you no longer wish to receive communications from us that are not required for the Service, please follow the “unsubscribe” instructions provided in any of those communications, or update your account settings information.
Geo-Location Information. Some Devices allow applications to access real-time location-based information (for example, GPS). Our mobile apps do not collect such information from your Device as of the date this policy went into effect, but may do so in the future with your consent to improve our Services and to optimize your experience. Some of the information we do currently collect from a device, such as the Device’s IP address, can sometimes be used to approximate a Device’s location.
Analytics. We also collect some information (ourselves or using third party services) that requires using logging and cookies, such as IP address, which can sometimes be correlated with Data About Customers. We use this information for the above purposes and to monitor and analyze use of the UPilot Service, for the UPilot Service’s technical administration, to increase our Services’ functionality and user-friendliness, and to verify users have the authorization needed for our Services to process their requests.
SHARING OF INFORMATION COLLECTED
No Sale of Data About Customers. We do not sell Data About Customers to third parties.
Service Providers, Business Partners and Others. We may use certain trusted third-party companies and individuals to help us provide, analyze, and improve the UPilot Service (including but not limited to data storage, maintenance services, database management, web analytics, payment processing, and improvement of our Services’ features). These third parties may have access to your information for purposes of performing these tasks on our behalf and under obligations similar to those in this Privacy Statement.
Compliance with Laws and Law Enforcement Requests; Protection of UPilot INC’s Rights. We may disclose to third parties data stored in your UPilot Service account and information about you that we collect or have collected when we have a good faith belief that disclosure is reasonably necessary to (a) comply with a law, regulation, or compulsory legal request, such as to comply with a subpoena; (b) protect the safety of any person from death or serious bodily injury; (c) prevent fraud or abuse of UPilot INC or its users; or (d) to protect UPilot INC’s rights. If we provide any data stored in your UPilot Service account to a law enforcement agency, we will remove our encryption from the information before providing it to law enforcement. However, UPilot INC will not be able to decrypt anything that you encrypted prior to uploading it to UPilot INC.
5. Correcting and Updating Your Information
Customers who are registered users may review, update, change or delete certain Personal Information, Required Contact Information, or Billing Information provided in your registration or account profile by changing your account settings. In some cases, we may retain copies of this information if required by law, to protect UPilot INC’s rights, or if it is not reasonably technically reasonably feasible to remove it. To update a user profile, please login to the UPilot Service with your applicable username and password and edit your user settings. To update Billing Information or have your registration information deleted, or to discontinue your account, please email email@example.com. Requests to access, change, or delete your information will be handled within 30 days. You may also wish to contact the system administrator for your instance of the Services for assistance in correcting or updating your information.
6. Data Retention
Except as otherwise disclosed in the Terms of Service, UPilot INC retains the information we receive as described in this Privacy Statement for as long as your account is active or as needed to provide you with the Services. If you wish to cancel your account or request that we no longer use your information to provide you Services, you may delete your account. We may retain and use your information as necessary to provide our Services, comply with our legal obligations, resolve disputes, establish legal defenses, to conduct audits, pursue legitimate business purposes, and enforce our agreements, or if it is not technically reasonably feasible to remove it. Consistent with these requirements, we will try to delete your information quickly upon request. Please note, however, that there might be latency in deleting information from our servers and backed-up versions might exist after deletion. In addition, we do not delete Indexed Content or information from our servers’ files if you have that information in common with other users.
7. Public Forums and Blogs
UPilot INC may provide bulletin boards, blogs, or chat rooms on the Company’s Web sites. Any Personal Information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. UPilot INC is not responsible for the Personal Information you choose to submit in these forums. To request removal of your personal information from our blog or community forum, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information. If this is the case, we will let you know and indicate why.
8. International Transfer of Information Collected
We never transfer data outside the region in which it is originally agreed upon and stored without prior intimation to the Customer. To facilitate the Company’s global operations, the Company may access Data About Customers from around the world, including the United States and other countries in which the Company has operations. For European Web Site Visitors, please note that your Personal Information may be transferred outside of the European Economic Area (“EEA”). By visiting the Company Web sites, you agree to UPilot INC transferring your Personal Information outside the EEA.
Where there is international transfer of Personal Data to Processor’s Group Companies or to a country which is not a member state of the European Union, or in another signatory state of the European Economic Area Agreement (“EEA Countries”) or an international organisation, the following applies unless explicitly agreed otherwise by the parties in an Appendix:
9. Communications Preferences and Choice
The Company offers Web Site Visitors and Customers who provide contact information a means to choose how the Company uses the information provided. You may manage your receipt of marketing and non-transactional communications using the preference settings available through the Services, if any or by clicking on the “unsubscribe” link located on the bottom of the Company’s marketing emails. Additionally, you may send a request specifying your communications preferences to email@example.com. Customers cannot opt out of receiving transactional emails related to their account with UPilot INC or the Services.
10. Customer Data
As part of using our Services, Customers may submit electronic data or information to the Services (“Customer Data”) which may include Personal Information. The Company generally has no direct relationship with the individuals to whom Customer Data may pertain, which we process on the behalf of our Customers. Any uses of Customer Data by the Company are done so pursuant to the Company’s Terms of Service or a subscription agreement in place between the Company and the relevant Customer (or his/her organization), which exclusively govern the Company’s treatment of Customer Data and supersede this Privacy Statement in case of conflict, or as required by law. If Personal Information pertaining to you as an individual has been submitted to us by a Customer as Customer Data and you wish to exercise any rights you may have to access, correct, amend, or delete such data, please inquire with the Customer (or his/her organization) directly. If an authorized Customer requests that we update or remove the data in question and the Customer has no ability to do so via use of the Services, we will acknowledge their request within 30 business days.
The Company takes precautions, including administrative, technical, and physical measures – to help safeguard Data About Customers against loss, theft, and misuse as well as unauthorized access, disclosure, alteration, and destruction. While we follow generally accepted standards to protect information submitted to us, including the use of secure socket layer (SSL) technology, no method of storage or transmission is 100% secure. Users are solely responsible for protecting their passwords, limiting access to their Devices, and signing out of the Services after their sessions.
12. Contacting Us
Questions regarding this Privacy Statement or the information practices of the Company’s Web sites should be directed to UPilot INC at firstname.lastname@example.org or by mailing:
3500 South DuPont Highway,
Dover, DE 19901
13. Changes to this Privacy Statement
UPilot INC Service Indexed Content Privacy Statement
Privacy Statement Effective as of May 25, 2018
This Indexed Content Privacy Statement describes UPilot INC’s privacy practices relating to content that has (i) been made publicly available on the Internet, (ii) collected from third party data sources, or (iii) obtained from Customers directly or through Customers’ connected email or social media accounts and that is accessed, used and maintained in connection with the provision of the UPilot Service (the “Indexed Content”). To learn more about the Company’s privacy practices regarding handling of personal information collected by visitors to the Company’s Web sites and users of the Services, please visit the UPilot Service Web Site Privacy Statement.
Capitalized terms not defined in this Indexed Content Privacy Statement have the meaning set forth in the UPilot Service Web Site Privacy Statement.
1. Description of the Indexed Content Services
The UPilot Service provides platforms and online tools that allow Customers to: (i) access, update, use, and process Indexed Content relating to the Customer’s email, social media, or other online contacts; (ii) track or monitor online conversations between Customers within those Customers’ client organization and individuals outside of the Customers’ client organization; and (iii) analyze trends in Customers’ contacts with individuals outside of the Customers’ client organization. The use of information collected through our online tools shall be limited to the purpose of providing our Services to our Customers and Clients.
2. Collection of Indexed Content
To provide the Services to our Customers, the Company collects Indexed Content from third-party data providers and a variety of publicly-available portions of Web sites, such as blogs, news Web sites, and social networking Web sites, which may include third party personally identifiable information, from Customers’ email and social networking accounts. The Company has no ownership rights in the Indexed Content or any direct relationship with individuals whose personally identifiable information may be processed as part of providing the Services. The Company obtains Indexed Content using proprietary Web crawler technology, via public APIs, or through agreements with Web site operators or other third party data providers. The Company also may obtain Indexed Content directly from Customers’ social networking Web sites or from Customers’ email accounts upon their request and in accordance with the authentication process established by such social networking Web sites and email service providers. The Company also obtains Indexed Content, including business data, employment and human resources data, and relationship data from third party data sources, including data aggregators and similar entities.
Examples of the types of Indexed Content the Company collects and maintains include: (i) content derived from our Customers connected email and social networking accounts; (ii) content available on a Customer’s social networking Web sites and accounts; and (iii) publicly available data relating to businesses, employees, and inter-company connections.
To provide the UPilot Service, UPilot INC collects information under the direction of its Customers and has no direct relationship with the individuals whose personal data it processes. UPilot INC collects Indexed Content for our Customers. If you are a customer of one of our Customers and would no longer like to be contacted by one of our Customers that use our UPilot Service, please contact the Customer that you interact with directly.
3. Use of Indexed Content
Customers are responsible for their use of Indexed Content. UPilot INC requires Customers to use Indexed Content in accordance with the Company’s Terms of Service or other applicable agreement between the parties and applicable law.
UPilot INC provides various tools within the UPilot Service that permit Clients and Customers to analyze and draw conclusions from Indexed Content, such as evaluating relationships between business or other contacts and the patterns of communication between such business and other contacts and the Clients and Customers, as well as supplementing this information with other data and insights. In some cases, the Company uses third parties to provide additional analysis of and supplemental data for the Indexed Content.
MESSAGING AND MESSAGE TRACKING
The Services allow Customers to engage and communicate with individuals in either a public or a private dialogue, and to track these communications through the UPilot Service in connection with Indexed Content. Customers are responsible as senders of any messages to individuals and must comply with all applicable laws relating to sending unsolicited email or spam and any terms of service of the Web site from which the individuals post was obtained. Any private communications between Customers and individuals through our Services are maintained within our Services in accordance with the Company’s Terms of Service or such other applicable agreement between the parties.
MONITORING PERFORMANCE AND USER ENGAGEMENT
The Services may allow Clients and Customers to monitor Customers’ interactions with other individuals, including Customers’ email or social media contacts, to enable Customers and Clients to optimize their connections with other individuals. Customers are responsible for complying with any legal requirements in using functionality that allows tracking of individuals.
4. How to Access Indexed Content About You
You may have the legal right, upon written request, to access Indexed Content pertaining to you which is held by the Company (subject to limited lawful exceptions), and, as the case may be, to request that such information be corrected, amended or deleted, for example, if it is inaccurate or incomplete. If so, to the extent known, the Company will inform you of the Indexed Content stored about you (subject to others’ privacy interests or legal rights), how it is being used and any other information required under applicable law. The Company’s obligation to correct, amend and delete is only in relation to Indexed Content in our possession and not in relation to any Indexed Content held by our Customers. If you wish to access, correct, amend or delete any personal information pertaining to you which is held by any of our Customers, or opt out of communications from any such Customers, you should direct your query directly to the applicable Customer. We will acknowledge Customer requests to update or remove any Indexed Content pertaining to you from our Services, where the Customer has no ability to do so via use of the Services, within thirty (30) business days.
To make a request, please send a letter or email addressed to our UPilot INC Privacy Office at the address indicated below. For all such requests, please include the following information: your name, contact information, and the nature of your request (such as view information and/or delete information). The Company may require that you provide additional information to assist in finding your Indexed Content or to verify your identity.
If you are a Web site operator and would like to request that the Company cease crawling the public portions of your Web site, you may also contact us at email@example.com.
UPilot INC reserves the right to use or disclose information if required by law or if the Company reasonably believes that use or disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order or legal process. The Company may transfer Indexed Content, including Personal Information, to companies that help us provide our Services. Transfers to third parties are covered by the provisions in this Policy regarding notice and choice, as well as our service agreements with our Clients.
6. Data Security and Retention
The Company takes precautions, including administrative, technical and physical measures, to protect any Indexed Content we collect. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. UPilot INC will retain Indexed Content for as long as needed to provide services to our Client. UPilot INC will retain and use this Indexed Content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights.
7. Changes to this Privacy Statement
8. Contacting Us
Questions regarding this Indexed Content Privacy Statement should be directed to UPilot INC, at firstname.lastname@example.org or by mailing:
UPilot INC 3500,
South DuPont Highway,
Dover, DE 19901