Privacy Statement

This UPG Privacy Statement (“Privacy Statement”) describes how UPG Company LLC and its subsidiaries and affiliates (“UPG”) collect, use, transfer, and disclose data including personally identifiable information (“Personal Information”) obtained through UPG’s websites (the “Site(s)”) and via other methods.  By using the Sites or submitting any Personal Information to UPG, you acknowledge that you have read, understood, and agree to be bound by this Privacy Statement and the UPG Terms of Use.

Data UPG Collects

UPG collects data to provide customers with products and services, and to operate UPG’s business. Some of this data is provided directly, such as when you create a UPG account, connect a UPG device to the Internet or a Cloud service, provide equipment for maintenance, or contact UPG for support or to perform other services.  UPG receives some data by recording how users interact with UPG products and services by, for example, using technologies like Cookies, receiving error reports, usage data or location data from software running on UPG products or from utilizing UPG services.

The data UPG collects depends on the products, services and features used, and can include the following:

Name and contact data. Information, including Personal Information, collected through the Sites or through other means, may include name and salutation, job title, physical address, time zone, telephone number (including work or home office, mobile, and fax numbers), photograph, e-mail address, and other contact information. UPG also collects marketing contacts and preferences (phone, email, postal mail, fax, and text messages), name and nature of your business, language preference, and delivery and fulfillment information.

Credentials. UPG collects information used for authentication and account access.

Payment data. UPG or its payment processor collects data necessary to process payments for purchases from UPG, such as credit/debit card information, bank information, wire transfer and/or any other financial or payment information associated with a payment.

Usage data. UPG collects data about how users and devices interact with UPG products and services. For example, UPG collects:

Product use data. UPG collects product feature use data, website activity data, performance data, product preference information, purchase history, and the webpages you visit.

Device data. UPG may collect data about a device, its operational state, configuration, past usage data, device performance data, and information on the network used to connect and use UPG products. This includes data about the operating systems, applications and other software installed on the device, including product keys. This also includes Internet Protocol (IP) address, network authentication, MAC address, other device identifiers, regional and language settings.

Error reports and performance data. UPG collects data about the performance of UPG products and problems experienced. This data helps diagnose problems in the products to improve UPG’s products, and to provide solutions. Depending on product and settings, error reports may include data such as the type or severity of the problem, details of the software or hardware related to an error, device status, usage data, contents of data or files that were processing when an error occurred, and data about other devices, networks, or software with which the device interacts.

Support data. When UPG is engaged for support, UPG’s contact with any data or information stored on a device will be incidental in most instances.  Devices returned to UPG for repair should be wiped of all data.  UPG will collect data about any hardware, software, and other details related to the support incident for the purpose of tracking device performance and product improvement.

Location data. UPG may collect data about your location, which can be either precise or imprecise. Precise location data can be Global Position System (GPS) data, as well as data identifying nearby cell towers and Wi-Fi hotspots UPG collects when location-based products or features are enabled. Imprecise location data includes, for example, a location derived from your IP address or other data that indicates the geolocation of an IP address with less precision including latitude, longitude, city, region, country or postal code.

Cookies. Sites may collect certain kinds of data which could encompass Personal Information during your visit, including through the use of Cookies. Cookies are small text files sent from a site to the hard drive of a user’s device to store bits of information related to that user or device. Cookies can store information about the device and users, including IP addresses, navigational data, server information, data transfer times, user preferences, and passwords needed to access the special areas on UPG Sites. UPG uses Cookies to assist with the downloading of documents from Sites and for other business purposes such as traffic analysis of Sites. If you choose to create a user profile, UPG will use Cookies to store the Personal Information for your profile. Your browser may be able to be configured to block, reject, remove or disable Cookies and other tracking technologies. However, if you reject or remove Cookies or other tracking technology, you might not be able to access certain pages or use important functions on Sites, including downloading documents and establishing a user profile.

Other Technology. Sites also use IP addresses, log files and other technology to identify Site problems and usage. UPG also uses Web beacons to perform standard traffic analysis on the Sites in a manner similar to how UPG uses Cookies and to track Site(s) usage for statistical purposes. UPG reserves the right to introduce new tracking technologies and techniques related to the use of the Sites, although UPG will do so subject to and in accordance with applicable data protection laws and regulations.

How Upg Uses Personal Information

UPG uses, discloses, transfers, and otherwise processes data, including Personal Information, in several ways. UPG uses the data it collects for three basic purposes: (1) to process transactions for the sale and support of UPG products and/or services, (2) to operate UPG’s business, and to provide and support the products and services UPG offers (including improving and personalizing), and (3) to send certain communications, including promotional communications. When customers place an order, UPG uses the Personal Information provided, including any payment information necessary to provide the products or services requested.  If you create a user profile, UPG will store Personal Information as requested to manage the profile and communicate with the user.  If you are located outside of the United States, please be aware that any information you provide to UPG through the Sites may be transferred to the United States.  Please also be aware that by using the Sites and giving UPG your information, you consent to such transfer. You also understand that the U.S. may not provide the same level of protections as the laws of your country.

Personal Information may also, subject to the requirements of applicable law, be used, disclosed and transferred to law enforcement personnel and other persons in situations where UPG believes that it is necessary to identify, contact, or bring legal proceedings against someone who may be misusing the Sites, interfering with the rights of UPG or other users, or when UPG reasonably believes that the law requires or permits such disclosure.

Why Upg Shares Personal Information

UPG shares Personal Information with consent or as necessary to complete any transaction or provide any product or service requested or authorized. UPG also may disclose and transfer Personal Information to channel partners, strategic partners, suppliers and other third parties for the purposes described in this Privacy Statement and to assist with the operation of the Sites and/or the associated business transactions.  If UPG sells or divests all or part of its business, makes a transfer of assets, or otherwise becomes involved in a change of control transaction, or in the unlikely event of bankruptcy, UPG may transfer Personal Data covered by this Privacy Shield Policy to one or more third parties as part of the transaction including the due diligence process.

Additionally, UPG will access, transfer, disclose, and preserve Personal Information when UPG has a good faith belief that doing so is necessary to:

1. comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies;
2. protect our customers, for example to prevent unsolicited emails or attempts to defraud users of UPG products, or to help prevent the loss of life or serious injury of anyone;
3. operate and maintain the security of UPG’s products and services, including to prevent or stop an attack on UPG’s computer systems or networks; or
4. protect the rights or property of UPG, including enforcing the terms governing the use of the products or services; however, if UPG receives information indicating that someone is using UPG products or services to traffic in stolen intellectual or physical property, UPG may refer the matter to law enforcement.

Data Security

Pursuant to applicable regulations, UPG maintains reasonable technical and administrative procedures to protect data including Personal Information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, but UPG cannot ensure or warrant the security of any data against any possible loss or unauthorized access.

Access And Correction Of Personal Information

If you wish to access or update the Personal Information submitted through the Sites, or to make any inquiries (including requests of cancellation or deletion) about the collection or processing of such information, please contact us as described below in the section labeled “Contact”.  UPG provides individuals with access to their Personal Information where required by applicable data protection and privacy laws.  Individuals will be required to sufficiently verify their identity. Declining to provide Personal Information may limit UPG’s ability to respond to your inquiry.

Links To Other Internet Sites

The statements set forth in this Privacy Statement are for the Sites and other activities.  Other sites hosted by third parties may have different practices. If you link to or otherwise visit any other sites managed by third parties, you must review the privacy policies posted at those sites.  UPG has no control over those sites and is not responsible or liable for the policies and practices followed by third parties.

Retention Of Data

UPG will keep your data, which may include Personal Information, for as long as necessary for the purposes for which it was collected, to provide you with products or services, to conduct legitimate business interests, and where otherwise required or permitted by law.

Outside Marketing

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include: (i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.

Revisions To This Privacy Statement

UPG reserves the right to change this Privacy Statement from time to time at UPG’s discretion.  Please check this Privacy Statement frequently and particularly before you submit Personal Information via the Sites.

Contact

If you have any questions about this Privacy Statement, please contact us at:

UPG Company LLC
7865 Northcourt Dr, Suite 100
Houston, TX 77040