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Privacy
Policy

Security and Privacy are our priority.

PRIVACY POLICY

Last Modified May 22, 2018

Upclick Malta Limited dba Upclick (“Company”, “UpClick” or “We”) is committed to protect your privacy. This privacy policy (“Privacy Policy”) describes our practices of processing data from (i) visitors to our site available at: www.upclick.com (“Website”); (ii) our Customers using our Services (all as detailed and defined below); and (iii) our affiliates and merchants (“Business Partners”).


We have included below information about which data is collected, how we process and use your data, but before, we would like to explain the basis on which we do so:

  • Where a Business Partner registers for any of our Services, we process a Business Partner’s Personal Information in order to perform our contract with the Business Partner;
  • Where a Customer uses our Services to facilitate payment to our Business Partners or purchase the good and services we offer, we process the Customer’s Personal Information in order to perform our contract with the Customer;
  • When visitors access our site, we collect certain online identifiers which we have a legitimate interest in processing such data;
  • For direct marketing of either our Business Partner or Customers we have legitimate interest to process such data; or
  • We will also process your Personal Information where you have provided us with consent to do so.

 

Information Collection

Depending on your interaction with us (meaning, if you are just browsing our Website, or if you have registered to our Services and opened an account, etc.), we may collect two types of information you, as follows:

  • Non-Personal Information: The first type of information is non-identifiable information which may be made available or gathered through your use of the Services. To clarify, we are not aware of your identity due to such information (“Non-Personal Information”). The Non-Personal Information which is being collected may include your aggregated usage information and technical information transmitted or automatically collected such as (but not limited to): the time and date you access our Website, your actions within our Services (e.g., registration, pages viewed, etc.), type of operating system, type of browser, language preference and approximate geo-location (country level). 
  • Personal Information: The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Personal Information includes either: (i) contact information such as your name, phone number, address, email address, etc., which you have submitted voluntarily; (ii) your Internet Protocol (“IP”) address and MAC address or other Online Identifiers. Note that, while IP and MAC address are considered personally identifiable information in many jurisdictions (such as the EEA), there are some jurisdictions in which such data is not considered as Personal Information. Therefore, we treat such information as Personal Information, in accordance with applicable laws; (iii) payment information such as, individual taxpayer number, BIN and last four digits of the credit card number. All payment information is handled through industry standard secure protocols and where appropriate in accordance with relevant Payment Card Industry (“PCI”) compliance standards.

You are not required by law to provide us with any information. You can always avoid providing us certain Personal Information; however, you acknowledge that it may prevent us from providing you certain Services.

In the event we combine Personal Information with Non-Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.

 

Information we collect from visitors of our Website

Type of Information

How Do We Use It?

In the event you contact us for support or other inquiries, either through the online form available on the Website, by sending us an email or by other means of communications we make available, you will be requested to provide us your name and email address.

We will use this information solely for the purpose of responding to your inquiries and provide you with the support or information you have requested.

In the event you are interested in joining our team, and wish to submit your CV, you will be required to provide us your name, email address, and phone number.

Your provision of personal information in connection with recruiting is voluntary, and you determine the extent of information you provide us. We do not request or require sensitive personal information concerning religion, health, sexual orientation, or political affiliation in connection with recruiting. We will use the information you have provided solely to communicate with you, to manage our recruiting and hiring processes, and for compliance with corporate governance and legal and regulatory requirements. If you are hired, the information may be used in connection with employment and corporate management.

If you voluntarily subscribe to our newsletter you will be asked to provide us with your email address. You can unsubscribe at any time using the unsubscribe option within the body of the newsletter or rather or by contacting customer support at compliance@upclick.com

We will use your email address in order to send you information related to our Services and to keep you up to date regarding new Services, as well as provide you with tips related to sales strategy.

IP or other online identifiers such as cookies, agents, device identifiers, etc. (“Online Identifiers”)

We either directly or indirectly may collect our visitors’ IP. We use this for our legitimate interests of (i) operating, providing, maintaining, protecting, managing, customizing and improving our Website and Services and the way in which we offer them; (ii) enhancing your experience with the Services; and (iii) our legitimate interests of auditing and tracking usage statistics and traffic flow.

We also collect certain technical Non-Personal Information (as detailed above) which relates to your use of the Website.

We use this technical data in order to operate and manage our Website. 

 

Information We Collect from Business Partners

Type of Information

How Do We Use It?

You can sign up as a Business Partner through our site, during which you will be required to register and open an account. During the registration flow you will be requested to provide us with certain information such as your full name, email address, phone number, company name and address. Further, during the registration process, you will be required to create a password, at which time you thereby represent and warrant that you are responsible for maintaining the confidentiality of your details and password. You represent and warrant that you will not provide us with inaccurate, misleading or false information.

We will use this information for the purpose of performing our contract with you, provide you with the Services you have requested, and designate your account. We will use your email address and phone number in order to send you needed information related to the Services and our business engagement (e.g., send you a Welcome massage, to notify you regarding any updated to our Services, send applicable invoices, and additional occasional communications related to the Services) as well as verify your identity.

We also collect certain technical Non-Personal Information (as detailed above) as a visitor to the Website and as detailed above.

see the table above.

 

Information We Collect from Customers of the Service

Type of Information

How Do We Use It?

When you purchase a product through our Service you will be requested to provide us with certain information such as your full name, email address, postal code, email address, country and payment information.

We will use this information for the purpose of performing our contract with you, provide you with the Services you have requested and facilitate your payment to the goods, products or services you purchase.  

We also collect certain technical Non-Personal Information (as detailed above) as a visitor to the Website and as detailed above.

see the table above.

 

Sharing Personal Data

We do not share any Personal Information collected from you with third parties or any of our partners except in the following events:

 

  • Third Party service providers- share your information with third parties that perform services on our behalf (e.g. API providers, payment process, tracking, servers, service functionality and support, marketing, etc.) these third parties may be located in different jurisdictions;
  • Law Requirement- we will share your information, solely to the extent needed to comply with any applicable law, regulation, legal process or governmental request (i.e., to comply with courts injunction, etc.); 
  • Policy Enforcement- we will share your information, solely to the extent needed to enforce our policies including investigations of potential violations thereof or to detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues;
  • Company’s Rights- we will share your information, solely to the extent needed to establish or exercise our rights to defend against legal claims;
  • Third Party Rights- we will share your information, solely to the extent needed to prevent harm to the rights, property or safety of us, our users, yourself or any third party or for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.
  • Corporate Transaction- We may share Personal Information, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy.

 

We may store Non-Personal and Personal Information on our servers or our cloud servers, use or share Non-Personal Information in any of the above circumstances, as well as for the purpose of providing and improving our Service as detailed above. Furthermore, we reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed data to third parties, including, inter alia, affiliates, for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.

 

Data Retention

We retain the information we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out. We may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.

 

Safeguard your Information

We take great care in implementing and maintaining the security of Company’s Website, Services and your information. We employ PCI compliance (all systems are PCI Level 1 Service Provider certified. Company is PCI-DSS level 1 requirements compliant), we have implemented, technical organizational monitoring protections, and established an extensive information and cyber security program, all with regards to Personal Information processed by Company. For more information regarding our security measures please see https://www.upclick.com/security.html.

Further, in the event of a data incident, in which we discover your Personal Information may be at risk, then we will take reasonable efforts to notify you and the applicable authority (if required, subject to applicable laws).

 

User Rights

Individuals have the right to know what information we hold about them and, in some cases, to have such information communicated to them. Individuals may also ask for our confirmation as to whether or not we process their Personal Information. Subject to the limitations in applicable law, individuals may also be entitled to obtain from us the Personal Information they have provided to us in a structured, commonly-used, and machine-readable format, and may have the right to transmit such Personal Information to another party.

 

The principal rights under applicable data protection law in relation to Personal Information are as follows:

the right to access any information which is provided to us;

the right to rectification;

the right to erasure;

the right to restrict processing;

the right to object to processing;

the right to data portability;

the right to complain to a supervisory authority; and

the right to withdraw consent (to the extent applicable).

 

We provide you with the ability to exercise certain choices and controls in connection with our treatment of your Personal Information, depending on your relationship with us. For more information, please review our user right policy available at: https://www.upclick.com/userrights.html.

If you wish to exercise any or all of the above rights, please either use the dashboard of your account or please contact our Data Protection Officer at: dpo@upclick.com and let us know that you wish to exercise your right of access and specify what Personal Information you would like to receive.

Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. In addition, the process of locating and deleting the data may take up to one (1) month (following the receipt of the validation proof we require) in accordance with applicable law.

Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

 

How We Collect Information

Depending on the nature of your interaction with the Services, we may collect information as follows:

  • Automatically – we may use Cookies (as elaborated in the Section below) to gather some information automatically.
  • Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as through a registration process, contact us communications, payment process, etc.

 

Cookies

When you access or use the Website, or interact with our Services, we may use "cookies" (or similar technologies), which store certain information on your device (i.e., locally stored) and which will allow us to customize the Service and content as well as enhance your experience of the Services. The use of cookies is a standard industry-wide practice. A "Cookie" is a small piece of information that a website assigns and stores on your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes such as allowing you to navigate between pages efficiently and making the interaction between you and our Services quicker and easier.

We may permit third parties to use cookies or other technology to collect information about your online and application usage activities across our Services, this data may include Online Identifiers therefore we recommend you review our cookie policy carefully:

Cookie

Purpose

Privacy Policy and Opt-Out

Facebook Analytics

Enable use of the Service and analytics purposes

https://www.facebook.com/policies/cookies/

Google Analytics

Analytics purposes

https://www.google.com/policies/privacy/partners

https://tools.google.com/dlpage/gaoptout

Bing

Analytics purposes

https://privacy.microsoft.com/en-us/privacystatement

Flurry (Yahoo) Analytics

Analytics purposes

https://policies.oath.com/us/en/oath/privacy/topics/analytics/index.html

Upclick Cookies

Enable the use of the site and service and analytics purposes

 

For more information about cookies and your controls in this regard, you may review the following links: 

 

Most browsers will allow you to erase cookies from your computer's hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies some features of the Services may not operate properly and your online experience may be limited.

 

Third Parties

Occasionally, Upclick receives information from third parties to compare it to information that you had provided to Upclick for fraud prevention purposes.

Any websites displayed to you by our Website as Internet search results or linked to Internet search results pages provided to you by our Website, including websites owned or operated by our clients, have been developed by third parties over which Upclick exercises no control. Upclick is not responsible for the privacy practices or the content of such websites, including such websites' use of any information collected when you are directed to or click through to such websites. Even though such information might not identify you personally, we strongly encourage you to become familiar with the privacy practices of those websites.


Direct Marketing

We may send our Business Partners and Customers an email or other messages about us or our Services. We may also send our updates or newsletter to individuals who have registered to the newsletter or used our Services. You can remove your Personal Information from our mailing list and stop receiving promotional communications from us by following the unsubscribe link located at the bottom of each communication or by emailing us at compliance@upclick.com

Please note that in the event you are our Business Partner, even if you unsubscribe, we reserve the right to send you service-related communications, including service announcements and administrative messages, relating either to your account or to your transactions the Services, without offering you the opportunity to opt out of receiving them unless you terminate and delete your account. If you wish to delete your Account, please contact us at: compliance@upclick.com .Note that, even if we will delete your account, we will not delete certain information required under applicable law or otherwise, required for the legitimate purposes of our business. For example, we will not delete any invoices sent to you as we need it for the purpose of managing our financials.

 

Children

Our Service are not direct or intended for children, as follows: (i) US residents under 13 years of age; (ii) EU residents under 16 years of age; or (iii) as children are otherwise defined under applicable law. We will not knowingly solicit, collect and store Personal Information directly from children. If you are under 18, please be sure to read the terms of this Privacy Policy with your parents or legal guardians. If we later obtain actual knowledge that a User is considered as a child under applicable law, we will take steps to immediately delete its Personal Information. We request that such individuals do not provide Personal Information through the Services. If you become aware or have any reason to believe that a child has shared any information with us, please contact us at: compliance@upclick.com

 

Policy Changes

We reserve the right to periodically amend or revise this Privacy Policy at our sole discretion; such changes will be effective immediately upon the display of the revised Privacy Policy. The last revision date will be reflected in the "Last Modified" heading. Your continued use of our Services following the amendments constitutes your acknowledgement and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments. In the event of a material change we will make best efforts to display applicable notification in our Website or if applicable, notify you via email or through your Account.

 

Do Not Track Disclosure

The Service does not respond to Do Not Track signals. For more information about Do Not Track signals, please see: http://www.allaboutdnt.com/.

 

Data Transfer Outside of the EEA

We may store or process your Personal Information in the United States or in other countries. If you visit our Websites or use our Services from locations outside of the United States, please note that any information you provide to us through your use of our Websites or Service may be transferred to and processed in countries other than the country from which you accessed our Websites or Service, including the United States where our central database is operated. If you are a resident of the European Economic Area ("EEA") we will take appropriate measures to ensure that your personal data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where transfer of your personal data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your data.

 

Commitment

We are committed to privacy and are actively involved in and support current industry initiatives to preserve individual privacy rights on the Internet. Protecting your privacy online is an evolving area, and Upclick Website is constantly evolving to meet these demands.

If you have any comments or questions regarding our Privacy Policy, please do not hesitate to contact us at compliance@upclick.com.

Upclick Malta Limited

48/4 Triq Amery, Sliema SLM 1701

 

Data Protection Officer

If you have any requests regarding the data collected under this Privacy Policy, including without limitation, requests to remove, delete, amend, modify or transfer the data, please contact our Data Protection Officer at: dpo@upclick.com

Please include your name, address and email address in any correspondence so that we can respond to your inquiry or request.