Privacy Policy

We are committed to protecting your privacy. We only gather personal information from you if you provide it voluntarily, and we use it only to send you communications you have requested. We maintain the privacy of your information using security technologies and adhere to policies that prevent unauthorized use of your personal information.

Last Updated: [1/26/2022]

This Privacy Policy (“Privacy Policy” and “Policy”) applies to the collection and use of Personal Information by Upwardly Global (“Company”, or “we,” or “us,” or “our”). It describes the Company’s practices regarding the collection, use, and disclosure of Personal Information when you visit our websites, use our mobile applications, our Learning Management System (the “Sites”) and when you engage with us offline. It also describes the rights residents of California may have regarding their Personal Information.
This Policy does not apply to information we collect about employees, job applicants, and independent contractors.
For purposes of this Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include de-identified or aggregate information, or public information lawfully available from governmental records.

Personal Information We Collect and Have Collected– Sources and Categories
We may have collected your Personal Information when you visited our Sites, requested information about our products or services, provided us with your information at a conference or other event, clicked through links on our Sites to watch or listen to archived events or presentations, or when you voluntarily provided information to us through our web portal, email or phone number. We will continue to collect Personal Information from the same sources.
The categories of Personal Information we may have collected from these sources include the following:

  • Personal identifiers: Name, address, email address, telephone numbers, IP address or other unique identifier, account name , and other similar information.
  • Financial and insurance information: Bank account information, W9, Employer Identification Number (EIN), insurance information, and payment information.
  • Protected class information: Age, military or veteran status.
  • Commercial information: Records of products purchased or considered, consuming histories or tendencies.
  • Internet or other electronic activity information: Device and browser type, your browsing and search history on our Sites, and information regarding your interaction with our Sites and our advertisements.
  • Educational information: Information about your educational history, degrees and credentials.
  • Professional information: Name and location of current or past employers, health care provider professional qualifications, information on your resume or CV, position(s) you hold.
  • Geolocation information
  • Audio and visual information: Recordings from video of telephone conference calls.
  • Inferences drawn from any of the Personal Information identified above.

Purposes for Collection of Personal Information
We use your Personal Information to provide you with information you request and our products and services. We also use Personal Information to contact you from time to time, respond to your inquiries, and to provide you with news about the Company and for marketing purposes. We may share Personal Information with our educational partners from time to time to provide our services.
Additionally, we use Personal Information, including about your use of our Sites, to monitor or improve our Sites; for internal business analysis; to prevent fraud, activities that violate our Terms of Service or that are illegal; and to protect our rights and the rights and safety of our users or others.

Disclosure of Personal Information
The following chart describes the categories of Personal Information that we disclosed to third parties:

Categories of Consumers’ Personal Information Categories of Third Parties With Which We Shared Personal Information
Personal identifiers: Name, address, email address, telephone numbers, IP address or other unique identifier, and other similar information. Service providers that provide services; assist us in operating, analyzing, and displaying content on our website; provide analytics information; advertise or market our services; provide website hosting, webcast and teleconference services; provide legal and accounting services. 

The U.S. government

Financial information: Bank account information, W9, Employer Identification Number (EIN), insurance information, and payment information. Bank, IRS, Sage (general ledger).
Internet or other electronic network activity information: Device and browser type, browsing and search history on our Sites, and information regarding interaction with our Sites and our advertisements. Service providers that provide data security services and cloud-based data storage; host our Sites and assist with other IT-related functions; provide website hosting, webcast and teleconference services; advertise and market our services; and provide analytics information.
Educational information: Information about your educational history, degrees and credentials. The U.S. government, private funders, and educational institutions.
Professional information: Name and location of current or past employers, information on your resume or CV, areas of specialization. The U.S. government and private funders.
Audio or visual information: Social media platforms and subscribers to our newsletter.

Additional Information About How We May Share Personal Information
We may also share your Personal Information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also share your Personal Information with third parties to help detect and protect against fraud or data security vulnerabilities. And we may transfer your Personal Information to a third party in the event of a reorganization of our entity or other restructuring.
Like most websites, our Sites use small data files stored on your computer or mobile device called cookies. Cookies consist of two different types; session and persistent. Session cookies enable us to recognize your actions during the browsing session. Persistent cookies remain stored on your device after you close your browser until they expire or when you delete them.

Cookies and Other Tracking Technologies
Cookies and web beacons, typically a one-pixel image, used to pass information from your computer or mobile device to our Sites, enable us to provide you with great customer service, improvements to our website design, product assortments and special promotions by:

  • keeping track of what you have in your shopping cart;
  • remembering you when you return to visit the Sites;
  • identifying the pages you click on during your visit to the Sites;
  • the name of the website you visited immediately before clicking onto our Sites; and
  • helping track whether our communications are reaching you, measuring their effectiveness and allowing us to better design future communications.

We use this information to improve our site design, product assortments, customer service, and special promotions. Certain of these cookies are strictly necessary to the access and operation of the website and other cookies used are non-essential to the access and operation of the website.

We may contract with third parties who may use cookies and web beacons and collect information on our behalf or provide services such as data management, or website troubleshooting and analytics. These third parties are prohibited by our contract with them from sharing that information with anyone other than us or our other vendors who provide similar services.

We use also Google Analytics to evaluate the use of our Sites. Google Analytics uses cookies and other identifiers to collect information, such as how often users visit a website, what pages they visit when they do so, and what other websites they visited prior to visiting a website. To learn more about how Google Analytics collects personal information, review Google’s Privacy Policy.

California Privacy Rights
If you are a California resident, you may have separate rights regarding your Personal Information, in accordance with California law.

California Shine the Light
California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits California residents to annually request, free of charge, information about certain categories of Personal Information a business has disclosed to third parties for direct marketing purposes in the preceding calendar year. For information, please contact us at 415-834-9901 or info@upwardlyglobal.org.

California Do Not Track
Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, our Sites do not respond to browsers’ do not track signals.

Personal Information of Minors
Our products and services are not directed to minors under the age of 13.

Third Party Websites
Our Sites may contain links to other third-party websites, which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on these websites. Accordingly, we recommend that you review the privacy policies posted on any website that you may access through our Sites.

How We Keep Your Personal Information Secure
We implement and maintain reasonable security measures appropriate to the nature of the Personal Information that we collect, use, retain, transfer or otherwise process. Those measures include administrative, physical and technical safeguards to protect the security, confidentiality and integrity of Personal Information. However, data security incidents and breaches can occur due to a variety of factors that cannot reasonably be prevented; therefore, our safeguards may not always be adequate to prevent all breaches of security.

International Residents
Personal Information collected from you, including via our Sites, will be transferred to the United States where the Sites are hosted. You hereby consent to the transfer of your Personal Information to the United States as described in this Privacy Policy. Please do not use the Sites if you do not agree to the transfer and processing of your Personal Information in the United States, which may not provide the same level of protection for your data as your home country.
Changes to This Policy

We will review and update this Policy periodically. We will notify you of material changes to it by posting on our Sites notification that the Policy has been revised and by updating the effective date of the Policy.

Contact Us
If there are any questions regarding this Policy or to request a copy of this Policy in another format you may contact us at: info@upwardlyglobal.org.

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