Privacy Policy
EFFECTIVE DATE: September 10, 2020

In this Privacy Policy (“Policy”), we describe how Upful, Inc. (“Upful”) collects, uses, and discloses information that we obtain about visitors to our website upful.ai (the “Site”) and the services available through our Site (collectively, the “Services”).

By visiting the Site, or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Site or Services, and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. The Upful Terms of Service are incorporated by reference into this Policy.

The Information We Collect About You
Information We Collect Directly From You
Information We Collect Automatically
How We Use Your Information
How We Share Your Information
Our Use of Cookies and Other Tracking Mechanisms
Third-Party Analytics
User-Generated Content
Third-Party Links
Security of Your Personal Information
Access to Your Personal Information
What Choices Do You Have Regarding Use of Your Personal Information?
Children Under 13
Contact Us
Changes to this Policy

The Information We Collect About You
We collect information about you directly from you and automatically through your use of our Site or Services.

Information We Collect Directly From You
The information we collect from you depends on how you use our Services. To create an account, you must provide your work email address, first name, last name, and invite code. We also may collect additional information from you, including gender, ethnicity/race, religion, sexual orientation, disability, year of birth, department, title, manager’s work email address, salary, date you started working at your company, date you started working for your manager, date of last promotion, date of last raise, and LinkedIn profile URL.

Information We Collect Automatically
We automatically collect the information below about your use of our Site through cookies and other technologies. To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information. The information we collect includes:
Domain name
Browser type and operating system
Web pages you view on the Site; links you click on the Site
Your IP address
The length of time you visit our Site and use our Services
The referring URL, or the webpage that led you to our Site

Information We Collect From Third Parties
In connection with the Services, we collect personal information about you from your employer, managers, colleagues, clients, and any other third parties you invite to respond. This information may include employee evaluations and other feedback on your job performance.

How We Use Your Information
We use your information, including your personal information, for the following purposes:To provide our Site and Services to you, and to process customer orders.To improve the accuracy, helpfulness, and relevancy of employee coaching.To provide statistical analyses, generate reports, and otherwise provide feedback on evaluations to customers’ admin users.To better understand how users access and use our Site and Services, both on an aggregated and individualized basis, to improve our Site and Services, to respond to user desires and preferences, and for other research, development, and analytical purposes.To communicate with you about your use of our Site and Services, to respond to your inquiries, and for other customer service purposes.To assist us in advertising on third-party websites, mobile apps, and other online services, and to evaluate the success of our adverting campaigns through third-party channels (including our online targeted advertising and offline promotional campaigns).For marketing and promotional purposes. For example, we may use your information, such as your email address, to send you news and newsletters or to otherwise contact you for promotional purposes. We also use the information that we learn about you to assist us in advertising on third-party websites and to assist us in evaluating the success of our advertising campaigns in various platforms.To comply with legal and regulatory obligations, as part of our general business operations, and for other business administration purposes. For example, we may use your personal information to safeguard our business interests and to manage or transfer our assets or liabilities, such as in the case of an acquisition, disposition, or merger, as described below.Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of our Terms of Service or this Privacy Policy.

How We Share Your Information
We may share your information, including personal information, as follows:

Service Providers
We disclose the information we collect from you to service providers, contractors or agents who perform functions on our behalf. These service providers include databases and cloud storage platforms.

Upful Platform Users
Your name, work email address, and any information that you post within our platform, including, without limitation, reviews, comments, and text will be available to, and searchable by, your manager, HR users, and those users of the Site and Services you have tagged. This does not include feedback or messages sent to us privately. We also disclose information in the following circumstances: Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third-party advisors, including attorneys and consultants. In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena. To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which we are involved.

Our Use of Cookies and Other Tracking Mechanisms
We and our service providers use cookies and other tracking mechanisms to track information about your use of our Site or Services. We may combine this information with other personal information we collect from you (and our service providers may do so on our behalf).

Cookies
Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.

Session Cookies
Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site and Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site and Services.

Persistent Cookies
Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function.

Third-Party Analytics
We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site and Services. We also may use other analytic means to evaluate our Site. We use these tools to help us improve our Site’s and Apps’ performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Do-Not-Track
Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).

User-Generated Content
We invite you to post content on our Site and Services, including your comments, pictures, and any other information that you would like to be available on our Site or Services. If you post content to our Site or Services, all of the information that you post will be viewable by your manager, HR users, and those users of the Site and Services you have tagged. Upful cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy.

Third-Party Links
Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

Security of Your Personal Information
We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Access to Your Personal Information
You may modify personal information that you have submitted by logging into your account and updating your profile information, or by contacting us at https://upful.ai/contactUs. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site for a period of time.

What Choices Do You Have Regarding Use of Your Personal Information?
We may send periodic promotional emails to you. You may opt out of promotional emails by following the opt-out instructions contained in the email or by contacting us at https://upful.ai/contactUs. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.

Children Under 13
Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.

Contact Us
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at privacy@upful.ai.

Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site and Application. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site and Application.