We — meaning Uyolo S.r.l., (also "we," "our," or "us") — prepared this Privacy Policy to help you understand our practices with respect to the collection, use, and disclosure of personal information (hereinafter, “Personal Information” or “PI”) we collect from you through the application owned by us (“UyoloApp”).

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1. What PI We Collect from You and How

We collect information from you when you:

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(i) Create or register an account

(ii) Submit requests, or other communications to us 

(iii) Contact us for customer support or technical support

(iv) Use our UyoloApp and services thereof

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We may also collect information about you from our providers, insofar as they help us to provide or promote our product. 

We may also obtain publicly-available business contact information.

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a. Customer Information

“Customer Information” consists of information related to your access or use of our UyoloApp, the creation of accounts, or that otherwise identifies you as an end user. 

Customer Information includes:

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Identifiers. This includes your name, surname, email address, and other similar identifiers.

Customer Records. This includes username and password, job title, company name, field of expertise.

Internet/Network Activity Information. This includes your browsing history, Ip address, log and analytics data, information about the device(s) used to access the UyoloApp, domain server, search history and information regarding your interaction with our UyoloApp, and other usage data.

Other Personal Information. This includes personal information you provide to us in relation to a survey, comment, question, request, or inquiry.

Inferences. This includes inferring your location using your IP address, or using data from your use of our Service to make predictions about your preferences, characteristics, predispositions, behavior, etc.

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b. Automatically-Collected Information

We collect information about how you use the UyoloApp and your actions on it, including your IP addresses, browser types, operating systems, ISPs, platform types, device types, and mobile device identifiers such as make and model, and mobile carrier. We may also use tools, including third-party tools, to collect analytics data. Some of this information is collected through the use of cookies and other tracking technologies, such as web beacons, pixels, session replay scripts, and similar technologies. 

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c. Aggregated or De-Identified Data

This includes aggregated or de-identified information for a wide variety of statistical, analytical, and UyoloApp improvement purposes. The aggregation or de-identification process prevents the information from being reassociated or identified with any one customer account, user, or individual.

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2. How We Use the Information We Collect

We use your PI to:

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• Fulfil our Contract with You and Provide the Services to You. This includes use for the purpose of: (i) responding to your requests or inquiries; (ii) providing you with  support or technical assistance; (iii) contacting you to provide product updates or information about products you have requested or purchased; (iv) facilitating transactions and processing payments, where applicable; (v) ensuring the proper functioning of our services and delivering personalized user experiences; (vi) creating, managing, or administering your information and account, including identifying you with your account.

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• Allow You to interact with other Users and allow transactions from within the UyoloApp. This includes: (i) enabling communication and content sharing between users within the UyoloApp; (ii) providing access to features or additional functionalities that require payment; and (iii) ensuring compliance with community guidelines and terms of use.

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• Analyze and Improve our services pursuant to our Legitimate Interest. This includes use for the purpose of: (i) deriving market insights and performing other business analysis or research at aggregate level; (ii) securing the UyoloApp and our systems, and protecting your information and data; (iv) detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; (v) measuring interest in and engagement with our UyoloApp and short-term, transient use; (vi) improving our algorithms, user experience, and overall platform functionality; and (vii) conducting quality assurance, troubleshooting, and performance monitoring.

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• Marketing Our Products and Services. This includes use for the purpose of: (i) monitoring the performance of our advertisements and marketing efforts, and (ii) communicating with you about your engagement with our UyoloApp.

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• Fulfil Legal Obligations and Rights. This includes use for the purpose of: (i) establishing, exercising, investigating, prosecuting, or defending against legal claims; (ii) complying with laws or responding to lawful requests and legal process; (iii) protecting our rights and property, our agents, customers, and others, including to enforce our agreements and policies; (iv) detecting, suppressing, or preventing fraud; (v) reducing credit risk and collecting debts owed to us; (vi) protecting the health and safety of our customers, or any person, including ourselves; or (vii) fulfilling other requirements under applicable law.

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• Other Purposes. This includes use for our other, legitimate business purposes, or as permitted by applicable law.

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3. How We Disclose Information

We disclose information we collect for specific purposes, including:

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• With affiliates and partners to provide you with our services and product;

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• With third-party suppliers that help us provide you with aspects of the UyoloApp, such as data storage, hosting, etc., or that help us with marketing and email campaigns, to advertise, gain insights, and perform analytics into how the Service is used and how it might be improved;

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• With third-party providers of marketing services;

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• With other users, as you choose to interact with them from within the UyoloApp;

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• As necessary to comply with applicable law, including governmental requests and law enforcement requests, and otherwise to protect the rights, privacy, safety, or property of you, us, or others;

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• As necessary in the event of a proposed or actual re-organization, merger, sale, joint venture, assignment, transfer, financing, or other disposition of all or any portion of our business, assets, or stock;

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• With others for any legitimate business purpose that does not conflict with the statements made in this Privacy Policy.

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4. Onward Transfers of Information

We may transfer to and process your personal information in countries outside of the jurisdiction where you are located for the purposes described above. When required by law, we will ensure that we rely on an appropriate legal mechanism for the transfer, such as your consent, standard contractual clauses (or their equivalent), or adequacy decisions. You may ask us, using the contact information in this policy, for more information about the specific basis we use for transferring your data.

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5. Retention of Information

We store your personal information for no longer than necessary for the purposes for which it was collected, including for the purposes of satisfying any legal or reporting requirements, and in accordance with our legal obligations and legitimate business interests. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data; the potential risk of harm from unauthorized use or disclosure of your personal data; the purposes for which we process your personal data; and the applicable legal requirements.

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6. Information from Children

The UyoloApp is not intended for use by children under the age of 13 (or other age as required by local law) and we do not knowingly collect personal information from children. If we learn that we have collected personal information from a child, we will take reasonable steps to delete such information from our files as soon as is practicable. If you learn that your child has provided us with personal information without your consent, you may contact us at support@uyolo.io.

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7. Changes to Privacy Policy

Any information that we collect is subject to the Privacy Policy in effect at the time such information is collected. We may, however, revise the Privacy Policy from time to time. If a revision is material, as determined solely by us, we will notify you, for example via email. The current version will always be posted to our Privacy Policy page.

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8. Contact Us

If you have any questions about our privacy practices, including this policy, you may contact us by email at support@uyolo.io.

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9. EEA, UK, Swiss-Specific Disclosures

The disclosures in this section apply solely to residents of the European Economic Area ("EEA"), Switzerland, and the United Kingdom ("UK"), and describe how we collect, use, disclose, and otherwise process personal data about you. Unless otherwise expressly stated, all terms in this section have the same meaning as defined in the General Data Protection Regulation ("GDPR"). We are the controller of the personal data we hold about you in connection with your use of the UyoloApp.

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a. Lawful Basis of Processing

We collect and process your personal data for purposes set forth in this Privacy Policy. Where required by law, we obtain your consent to use and process your personal data for these purposes. Otherwise, we rely on another authorized legal basis (including but not limited to the performance of a contract or legitimate interest) to collect and process your Personal Data.

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b. Marketing and Advertising

From time to time we may contact you with information about our products and services, including sending you marketing or advertising messages and asking for your feedback on our products and services. You can unsubscribe at any time from our marketing or advertising emails by clicking on the unsubscribe link at the bottom of the email or by contacting us at support@uyolo.io.

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c. Your Privacy Rights

You have the following rights in respect of your personal data that we hold: 

(i) right of access; 

(ii) right of portability; 

(iii) right to rectification; 

(iv) right to erasure (right to be forgotten); 

(v) right to restriction; 

(vi) right to withdraw consent; and 

(vii) right to object.

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You also have the right to lodge a complaint to your local data protection authority. Information about how to contact your local data protection authority is available here.

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If you wish to exercise one of these rights, please submit a request by:

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Emailing support@uyolo.io with the subject line "European Rights Request".

Due to the confidential nature of data processing we may ask you to provide proof of identity when exercising the above rights.

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10. California-Specific Disclosures

The disclosures in this section apply solely to individual residents of the State of California and provide additional information about how we collect, use, disclose, and otherwise process personal information within the scope of the California Consumer Privacy Act of 2018, as amended, including its implementing regulations ("CCPA"). Unless otherwise expressly stated, all terms in this section have the same meaning as defined in the CCPA.

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a. Sensitive Personal Information

Certain data elements we collect and use about you may be deemed "sensitive personal information" under CCPA. These include your username and password to access your account and contents of any messages you send through our email integration feature. We do not use or disclose such sensitive personal information to “infer” characteristics as defined under the CCPA, or for any purpose other than that which is necessary to provide the Service as specified in the CCPA.

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b. Sales and Sharing of Personal Information (Targeted Advertising)

We use cookies and similar tracking technologies that enable certain advertising campaigns, analytics services, and other third-party businesses to collect and disclose your personal information directly from your browser or device when you visit or interact with our Service or otherwise engage with us online. In some cases, we may upload personal information to certain of these partners for advertising or analytics purposes.

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To opt out of these “sales” or “sharing” of personal information (as these terms are defined under the CCPA or other applicable US state privacy laws), you must:

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Toggle cookies off in our or enable Global Privacy Control (“GPC”) on your browser; and

Submit a request using this form or email support@uyolo.io.

Note that the above opt-out right does not apply where we have appropriately limited our partners to be our “service providers” or “processors” (as these terms are defined under the CCPA or other applicable US state privacy laws).

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To learn more about GPC, please visit http://globalprivacycontrol.org.

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c. California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):

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- The Right to Know any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:

• The specific pieces of personal information we have collected about you;
• The categories of personal information we have collected about you;
• The categories of sources of the personal information;
• The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
• The categories of personal information we have sold or shared and the categories of third parties to whom the information was sold or shared; and
• The business or commercial purposes for collecting, selling, or sharing the personal information.

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- The Right to Request Deletion of personal information we have collected from you, subject to certain exceptions.

- The Right to Request Correction of inaccurate personal information.

- The Right to Opt Out of Personal Information Sales or Sharing to third parties now or in the future.

- You also have the right to be free of discrimination for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our Service or engage with you in the same manner.

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d. How to Exercise Your California Privacy Rights

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To exercise your rights to know, correct, or delete, please submit a request by:

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support@uyolo.io  with the subject line "California Rights Request".

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We will need to verify your identity before processing your request. In order to verify your identity, we will generally require either the successful login to your account (if applicable) and/or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to know, correct, or delete, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know, correct, or delete, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.

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e. Minors Under Age 13

We do not sell or share the personal information of consumers we know to be less than 13 years of age. 

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f. California’s "Shine the Light" Law

In addition to the rights described above, California's "Shine the Light" law (Civil Code Section §1798.83) permits California residents that have an established business relationship with us to request certain information regarding our disclosure of certain types of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year.

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To make such a request, please send an email to the contact email provided in the paragraph above.

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11. Disclosures to residents of Colorado, Connecticut, Virginia, and Utah

The disclosures in this section apply solely to individual residents of the States of Colorado, Connecticut, Virginia, and Utah. Privacy laws in these states give residents certain rights with respect to their personal data, when they take effect over the course of 2023. Those rights include:

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• Right to Access Information. You have the right to access and obtain a copy of your personal data.
• Right to Request Deletion. You have the right to request that we delete personal data provided by or obtained about you.
• Right to Correct. You have the right to correct inaccuracies in your personal data.
• Right to Opt-Out of Targeted Advertising. You may ask us not to use or disclose your information for the purposes of targeting advertising to you based on your personal data obtained from your activity across different businesses, services, UyoloApps, etc.
• Right to Opt Out of Personal Information Sales to third parties.

To submit a request to exercise your access, deletion, or correction privacy rights, please email us at support@uyolo.io with the subject line “Privacy Rights Request - State name*”. 

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Residents of Colorado, Connecticut, and Virginia may appeal a refusal to take action on a request by contacting us by email at the email address provided above.