At UPT Media, or our traffic subsidiaries, including ClickToRing, SquareVid, TheTrafficBoss or UptownTraction, (“UPT Media,” “we,” “us,” or “our”), we provide online advertising services. We conduct ourselves in a manner that protects user privacy and personalizes web experiences to provide significant benefits to Internet end users. In accordance with these beliefs, UPT Media creates results for advertisers and publishers in revolutionary ways without compromising individual privacy.  We have created this Privacy Policy in order to demonstrate our commitment to privacy as it pertains to SERVICES, COMPANY WEBSITE, ADVERTISERS and PUBLISHERS.

I.  SERVICES
This The purpose of this Privacy Policy (this “Policy”) is to inform you of regarding the use of data within UPT Media’s network as well as those affiliated with us, including data processors, sub-processors and third-party partners. This Policy shall also provide you information regarding how to manage certain data collected about you.

Definitions:

• Company – UPT Media, a Registered Company
• Platform – The services we provide to Clients
• Clients – Our primary clients are Advertisers and Publisher who utilize the Platform to create, edit and maintain advertising campaigns or to sell advertising placements.
• User – An individual who receives or otherwise interacts with an advertisement
• Data Subject – The person about whom personal data relates. This could be Clients or a User.
• Processor – Are the technology providers or sub processors who maintain a data processing agreement with the Company.

Personally Identifiable Information
Personally Identifiable Information (“PII”) is information about you that can be used to contact you or identify you as an individual. PII may include: your name, username, phone number, email address, and physical address. To the extent we obtain PII about you, such information shall be held for no more than one (1) year before it is deleted.

Personal Data
Personal Data is information that is associated with an individual and enables that individual User to be singled out. Through the use of ad tags and cookies we collect information about you. Typically, the information obtained does not identify you directly (i.e. by name or email address), however, the information may indirectly identify your device or geolocate you for purposes of delivering targeted advertisements. Under European privacy law, some information transmitted by Cookies and Tags including Log Data are considered personal information. To the extent we obtain Personal Data about you, such information shall be held for no more than one (1) year before it is deleted.

What Information We Collect for Client’s Accounts:

• Registration information – Your first and last name, mailing address, phone number, email address, Skype contact and other similar contact details.
• Technical / Access information – Details including your IP (Internet Protocol) Address, User-Agent and activity including pages accessed, information entered are stored for fraud prevention and security auditing.

The information we collect and log, as outlined above, is necessary for secure account access and for securing the data systems of the platform. This information will not be sold or otherwise transmitted for commercial usage.

Information Collected Relating to Users and Advertising:

• Device and Connection Information – Details including your IP (Internet Protocol) Address, User-Agent and activity including URLs of websites or names of applications accessed. The details of a User’s device and the context of where it is seen, as it related to URLs and applications is important for general ad targeting. These elements of a User’s browser or device are available for targeting, but are not made available to target a User individually.

Where ads may be targeted directly to a user – commonly called “retargeting”, in service of an advertiser or merchant whose website or app a User may have interacted with previously, clear and informed consent will be collected before such retargeting techniques will be activated.

Your Rights as a Resident of the European Economic Area
If you are located in the European Economic Area (“EEA”), you have certain rights with respect to your personal data, including the right to request access to, correct, amend, delete, port to another service provider, or object to certain uses of your personal data.

Your data may be obtained to pursue the following legitimate interests, either for ourselves, our Clients, or other third parties.

• To provide Clients with services related to our Platform;
• To prevent risk and fraud on our Platform;
• To provide communications, marketing, and advertising via the Client’s Platform;
• To provide reporting and analytics;
• To help Clients integrate with third party publishers and advertiser platforms via our Platform;
• To provide troubleshooting, support services, or to answer questions;
• To test out features or additional services; and
• To improve our services, applications, and websites.

When we process personal information to pursue these legitimate interests, we do so where we believe the nature of the processing, the information being processed, and the technical and organizational measures employed to protect that information can help mitigate the risks to the data subject.

Consent, Data Subject Requests, Opting-Out and Right of Access
If you are a Client, at any time, you may revoke our permission by visiting Settings inside your account, or request logs based on your personal access.

If you are a User and a resident of the EEA who believes they may have PII recorded, please use the Contact section, at the bottom of the document, to direct your inquiries or requests based on your rights outlined above.

Children’s’ Online Privacy Protection Act Compliance (COPPA)
The Platform and services are intended for general audiences and are not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If you become aware that a child has provided us with personal information without parental consent, please contact us here: info@uptmedia.com.

If we become aware that a child under 13 has provided us with personal information without parental consent, we take steps to remove such information and terminate any account linked to such underage minor.

Data Policies

Data Retention
If you are using the Platform as an advertiser or publisher, we will maintain your registration information for our records unless and until you ask the Client Platform to delete this information, or otherwise update said information.

Data Related to Advertisements
We may retain other data within our databases, related to your connection, advertisements served or other related information that we process on behalf of our Clients for a period of up to six (6) months unless otherwise required specific legal obligations, dispute settlements or contract enforcement.

After this period, The Company and its Processor may maintain and use such data in an aggregated format, as necessary for internal analytical purposes, to comply with its legal obligations, settle disputes and enforce contracts.

How do we protect your information?
The Company and its Processor(s) uses both physical and technical security measures to maintain an accepted industry security standard to protect all data on the Platform from misuse and/or unauthorized access.

Physical Measures of Data Security
The Company and its Processor maintains a private, physical “cloud” infrastructure of hardware to provide the Platform services.

Access to this hardware is secured by twenty-four (24) hour, seven (7) days a week on site guards. Building access is secured by keycard entry into the rooms that store the infrastructure.

Access to logs and other sensitive data is controlled and monitored to ensure employees of the Client and The Company and its Processor have a legitimate basis for accessing the data.

Technical Measures
The Company and its Processor encrypts the data sent to and from Client Platforms using the HTTPs protocol.

Access to this hardware is secured by twenty-four (24) hour, seven (7) days a week on site guards. Building access is secured by keycard entry into the rooms that store the infrastructure.

Data Breach
While we cannot guarantee misuse of data and or unauthorized access will not occur; we make good faith efforts to prevent such occurrences. We do not warrant or represent that your account or any of your information will be protected against, any misuse, by third parties.

In the case of a breach which we determine may have involved your personal information, there will be timely efforts to contact you and also alerts to the relevant local authorities.

Do we disclose any information to third parties?
We may also share your information in the following circumstances:

• To prevent, investigate, or take action regarding illegal activities, suspected fraud, violations of Client Terms of Service or any other agreement related to the Platform, or as otherwise required by law.
• To conform to legal requirements, or to respond to lawful court orders, subpoenas, warrants, or other requests by public authorities (including to meet national security or law enforcement requirements).
• Personal information may also be shared with a company that acquires our business, whether through merger, acquisition, bankruptcy, dissolution, reorganization, or other similar transaction or proceeding. If this happens, we will post a notice on our home page.

Cookies
We, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, advertising identifiers (including mobile identifiers such as Apple’s IDFA or Google’s Advertising ID) and similar technology (“Cookies”) in connection with your use of the Platform, third party websites, and mobile applications. Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit information about you and your use of the Platform, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session.

The purposes for which we use Cookies in the Service include:

Purpose	Explanation
Processes	Intended to make the service work in the way you expect. For example, we use a Cookie that tells us whether you have already signed up for an account.
Authentication, Security, and Compliance	Intended to prevent fraud, protect your data from unauthorized parties, and comply with legal requirements. For example, we use Cookies to determine if you are logged in.
Preferences	Intended to remember information about how you prefer the service over our Platform to behave and look. For example, we use a Cookie that tells us whether you have declined to allow us to send push notifications.
Advertising	Intended to make advertising more relevant to users and more valuable to advertisers. For example, we may use Cookies to serve you interest-based ads, such as ads that are displayed to you based on your visits to other websites, or to tell us if you have recently clicked on an ad.
Analytics	Intended to help us understand how visitors use the Platform. For example, we use a Cookie that tells us how our search suggestions correlate to your interactions with the search page.

You can set some Cookie preferences through your device or browser settings, but doing so may affect the functionality of the service over the Platform. The method for disabling Cookies may vary by device and browser, but can usually be found in your device or browser preferences or security settings. For example, iOS and Android devices each have settings which are designed to limit forms of ad tracking. Please note that changing any of these settings does not prevent the display of certain advertisements to you.

Click on any of the browser links below for specific instructions on deleting cookies.

• Microsoft Windows Explorer
• Google Chrome
• Mozilla Firefox
• Apple Safari

Changes to the Privacy Policy
We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. The most current version of our privacy policy shall govern how we collect, use and disclose information about you. By continuing to use our services after changes to the privacy policy become effective, you acknowledge any such revised privacy policy.

How to Contact Us
If you have any questions about this Privacy Policy, the practices of the UPT Media or your dealings with the UPT Media, you can contact us by e-mail at info [at] uptmedia.com.

Or as follows:
UPT Media/ ClickToRing
ATTN: DPO
220 S. Helberta Ave. #D
Redondo Beach, CA 90277

California Privacy Rights
This section is provided pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”) and other applicable California privacy laws. This section applies solely to our users who are California residents as defined under applicable California privacy laws.

Information We Collect
Within the last twelve (12) months, we have or may have collected the following categories of information from our users and/or consumers:

1. identifiers, such as a name, alias, unique personal identifier, online identifier, IP address, email address, or other similar identifiers;
2. personal information listed under Cal. Civ. Code § 1798.80(e);
3. characteristics of protected classifications under California or federal law;
4. commercial information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
5. biometric information;
6. internet or other similar network activity, such as browsing history, search history, information regarding your interaction with a website, application, or advertisement;
7. geolocation data;
8. professional or employment-related information; and
9. inferences drawn from any of the information identified in this section to create a profile about users reflecting user preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Categories of Sources from Which Information is Collected
We obtain the categories of personal information listed above from the following categories of sources:

10. directly from users, such as you, as described above under “Personal Information that You Provide to Us”;
11. indirectly from other users of our sites and services;
12. indirectly from third-parties that interact with us in connection with the services that we perform; and
13. directly and indirectly through cookies and other technologies, as described above under “Other Information We Automatically Collect through Cookies and Other Technologies.”

Using and Sharing of Personal Information
The personal information described in the categories above may be used for the business purposes listed above under “How We Use Personal Information.”

We disclose your personal information for a business purpose to the following categories of third parties: (a) service providers and (b) third parties to whom you authorize or direct us to disclose your personal information in connection with our sites and services. In the preceding twelve (12) months, we have disclosed the personal information described in the categories above for the business purposes listed above under “Sharing Personal and Non-Personal Information.” We also may share personal information about you for any other purpose(s) disclosed to you at the time we collect your information or with your consent.

Personal Information “Sold” to Third Parties
We may share information that we have about you, such as a cookie ID or IP address, with third-party marketing partners who may use this information, on our behalf, to help us deliver advertising on our sites as well as on third-party websites.

In the preceding twelve (12) months, we have made available personal information included in the categories described above to third-parties, including our third-party marketing partners to deliver advertising.

We do not sell the personal information of consumers that we know are minors under 16 years of age without affirmative authorization as required under the CCPA.

Your Access and Deletion Rights under the CCPA
As of January 1, 2020, California residents, as defined under applicable California privacy laws, may take advantage of the following rights:

14. You may request, up to two (2) times each year, that we disclose to you, once we receive and confirm your verifiable consumer request, the: (i) categories and specific pieces of personal information that we have collected about you; (ii) categories of sources from which your personal information is collected; (iii) business or commercial purpose for collecting your personal information; (iv) categories of personal information that we disclosed for a business purpose; (v) categories of personal information that we sold about you; (vi) categories of third-parties with whom we have shared your personal information; and (vii) business or commercial purpose for selling your personal information.
15. Subject to certain exceptions and up to two (2) times each year, you may request that we delete any of your personal information that we collected from you. Once we receive and confirmed your verifiable consumer request for deletion, we will delete (and direct our service providers to delete) such personal information from our records, unless an exception applies.

Exercising Your Access and Deletion Rights under the CCPA
To exercise the access and deletion rights described above, please submit a request to us by either:

16. sending an email to privacy@uptmedia.com; or
17. clicking here

You will be asked to provide certain identifying information, such as your name, email, and residency. You will also be asked to validate your request by clicking a validation link in an email that will be sent to the email address you provided. While processing your request, we may ask you to provide further verifying documentation, such as proof of residency and identity. We will only use personal information provided in a request to verify the requestor’s identity or authority to make the request.

Your request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or that you have authority to make the request; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide proof of written authorization to do so, and you must verify your identity directly with us, unless such authorized agent provides proof of a power of attorney pursuant to Probate Code sections 4000 to 4465.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Opting-out of the Sales of your Personal Information
Subject to certain exclusions under the CCPA, you have the right to opt-out of the sale of your personal information. Once we receive your request, we will not sell your personal information, unless an exclusion applies.

To opt-out of the sale of your personal information that we collect through cookies and other technologies.

To opt-out of the sale of your personal information that we collected directly from you or other third-parties, please submit a request to us by either:

18. sending an email to privacy@uptmedia.com; or
19. clicking here.

We may deny your request to opt-out if we have a good-faith, reasonable, and documented belief that the request is fraudulent.

Non-Discrimination
We will not discriminate against you for exercising any of your rights under the CCPA. Accordingly, and unless permitted by the CCPA, we will not:

20. deny you goods or services;
21. charge you different prices or rates for goods or services, including through the use of discounts or by imposing penalties;
22. provide you a different level or quality of goods or services; or
23. suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

We may charge a different price or rate or provide a different level of service if the difference is reasonably related to the value provided by your personal information.

Other Applicable California Privacy Laws
Section 1798.83 of the California Civil Code requires select businesses to disclose policies relating to the sharing of certain categories of your personal information with third parties. If you reside in California and you have provided us with your personal information, you may request information about our disclosures of certain categories of your personal information to third parties for direct marketing purposes. To make such a request, please fill out our Privacy Contact Form with “California Privacy Rights” in the subject line and allow 30 days for a response. We will not accept requests via the telephone, mail, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

In accordance with Section 22581 of the California Business and Professions Code if you are a California resident under the age of 18, you may request and obtain the removal of content or information you have publicly posted. To make such a request, please fill out our Privacy Contact Form with “California Privacy Rights” in the subject line. Please specify the site(s) or service(s) to which your removal request relates, including any URLs where the content or information is posted, and the specific content or information you posted for which you are requesting removal. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Nevada Privacy Rights
FOR RESIDENTS OF NEVADA ONLY. In accordance with SB 220, Nevada consumers may opt-out of the sale of their personal information to third parties. If you reside in Nevada and you have provided us with your personal information, you may choose to opt-out of the sale of such personal information by filling out our Privacy Contact Form or by emailing us at privacy@uptmedia.com with “Nevada Privacy Right” in the subject line. We may request for additional information from you in order to verify your identity and/or the authenticity of your request.

EU Privacy Rights
FOR RESIDENTS OF THE EUROPEAN UNION ONLY. Under European data protection law, in certain circumstances, you have the right to:

24. request access to your personal information;
25. request correction of your personal information;
26. request erasure of your personal information;
27. object to processing of your personal information;
28. request restriction of processing your personal information;
29. request transfer of your personal information; and
30. withdraw your consent.

In addition, you have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting your personal information) if we intend to use your personal information for such purposes or if we intend to disclose your information to any third party for such purposes.

You can exercise any of these rights by filling out our Privacy Contact Form or sending an email to privacy@uptmedia.com with “EU Privacy Rights” in the subject line. If you believe that we have not complied with its obligations under this Privacy Policy or European law, you have the right to make a complaint to an EU Data Protection Authority.

SUMMARY
The Company may update this Privacy Policy from time to time. We may notify you about significant changes in the way we treat your information by sending a notice to you, although we are not required to do so.

Notwithstanding the foregoing, we reserve the right to change this Privacy Policy without any notice whatsoever to you and for whatever reason we deem appropriate under the circumstances. We encourage you to periodically check back and review this Privacy Policy so that you always will know what information we collect, how we use it, and to whom we disclose it.

This Privacy Policy was last updated on: February 20, 2020.