This Privacy Policy (“Policy”) is acceptable by Users and Publishers while accepting or requesting Services provided by Upgini under separate Terms of Service available at the Website (“Agreements”) and becomes part thereto. All definitions used in this Policy has the same meaning as given in the Agreements.

This Policy explains how Upgini collects, stores, uses and otherwise processes information about End Users, Publishers and Users when providing Services. This Policy does not apply to Publisher Data.

1. Collected Information

Upgini may collect the following information related to Users, Publishers, and their End Users (“User Information”):

(1) Certain data provided by End Users while registering at Website and requesting for Upgini Services: name, email, postal address, phone number, credit card information and other information.

(2) Certain data that in not directly provided by End Users, but becomes available to Upgini due to provision of Services through the Website:

data obtained by End Users from the Platform, APIs, log files generated during such use;
data and metadata about the End Users (user ID, email, IP address, other data about the user’s computer or other device, browser and connecting software (e.g., OS and software versions);
data and metadata about End Users’ activities on Website and Platform in course of Services use.

2.Use of User Information

2.1. Upgini may use collected User Information in order to:

Maintain and improve the Services, Platform and Website;
Provide Services to Clients and Publishers (including provision of access to Services, payments and billing, Services technical support etc.);
Identify Clients and Publishers, and provide the security of the Accounts, monitor and verify authorized Services access and payments thereto;
Prevent fraud, spam, malware or other network and security risks;
Detect and exclude Platform bugs and Services errors;
Conduct research, development and marketing activities;
Maintain legal and regulatory compliance.

2.2. Upgini may store and process User Information worldwide, transfer and process it in countries other than the country in which the End User, Publishers or Clients are residents.
2.3. When Upgini ceases provision of Services or possession of a legitimate business to process User Information, Upgini will either delete or anonymize it.
2.4. Upgini will not share User Information with the third parties unless:

Such User Information has been aggregated or anonymized;
Client or Publisher gives instruction or consent to sharing their User Information with the third parties;
It is required to comply with laws or to respond to lawful requests and legal processes.

3. Security of User Information

3.1 Upgini acknowledges that some User Information may qualify individuals’ personal information (like name and contact details).
3.2. Upgini undertakes to take all reasonable technical and organisational measures to protect Client Information from unauthorised access, disclosure, alteration and destruction, including: access controls, encryption, internet firewalls, intrusion detection and network monitoring.

4. Changes to this Notice

Upgini may update this Policy by publishing the new version on the Website.

5. How to Contact Us

All issues or questions related to or raised out of this Policy and other privacy-related issues shall be sent at legal@upgini.com.