Privacy Policy for UPP Global
UPP Global and its affiliates greatly value your privacy. This Privacy Policy (“Policy”) describes the data privacy practices of UPP Global and its subsidiaries, divisions, and affiliates (collectively and/or individually, “UPP” "Company", "our", or "we") and your rights regarding your personal information. This Policy provides you with detailed information about how UPP processes personal and personally identifiable information or data, meaning information or data that, subject to certain exceptions, identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or individual (“personal information,” “PII”). Our data collection is designed to improve the purchasing experience of our customers and to provide relevant information about our Products, Services, and promotions.
We reserve the right to make changes to this Privacy Policy at any time and for any reason. Any changes will be reflected in a revised policy posted on our website: UPP Global (“uppglobal.com”) and we will alert you that there has been a change by updating the “Updated” date displayed on the Privacy Policy. If UPP Global determines that such changes materially affect your privacy rights, we will provide additional notice to you.
Except as otherwise provided, the Policy applies to the use of our Services and interactions with our customers and visitors, including, but not limited to:
· Use of our digital Services, including usage of our website(s) (“the Website”), scan to park methods (if applicable) and digital applications;
· Visits to our physical locations, including but not limited to, lots, garages, other private parking facilities, or properties managed/operated by UPP for the purpose of performing valet services (e.g., hotels, street parking);
· Digital communications, including, but not limited to:
o Phone and email communications;
o Social media interactions on our websites and other third-party websites like Meta (Facebook, Instagram), YouTube, Google+, and “X” f/k/a Twitter; or
o Online advertisements or emails.
· Through our authorized service providers.
1. Types of Information We Collect: We primarily collect two types of information about our users. Personally Identifiable Information (“PII”) and Aggregate Information, as well as other information as detailed below.
Personally Identifiable Information:This means information informing us who the user is, and the user specifics. PII may be collected by registering for an account, downloading or purchasing a product or service, engaging with kiosks/physical point-of-sale (“POS”), or sending us feedback. Examples of PII include the following:
a. Personal Identities and Contact Information. Examples include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, license plate number, or other similar identifiers.
b. Aggregate Information: This means information that does not by itself identify a specific individual. We gather certain information about you based upon where you visit our Site from, from where you access our Products/Services, and what other sites may have directed you to us. This information, which is collected in a variety of different ways, is compiled and analyzed on both a personal and an aggregated basis. This information may include the Website’s Uniform Resource Locator (“URL”) that points to the site you just came from, which URL you go to after visiting our Site, what browser you are using, online identifiers, and your Internet Protocol (“IP”) address.
c. Other Elements. Examples include name, signature, characteristics or description, address, telephone number, and potentially education.
d. Commercial Information. We may also collect commercial information which includes services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
e. Education Information. This includes information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, Sec. 1232g; 34 C.F.R. Part 99).
f. Internet and Additional Electronic Activity. Examples include browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement.
g. Geolocation Data. To assist in the performance of our Services to you, we may collect location information while using our Services.
h. Audio, electronic, visual, thermal, olfactory, or similar information. Examples of this category include information collected from voicemail messages, while speaking with one of our service representatives, and/or by video camera.
i. Sensitive Personal Information. Payment card information, bank account number, credit card number, and precise geolocation.
2. How We Collect and Use Information:
We may collect your personal information from the following sources.
You. Examples of when we collect that information include:
During a website visit, when you complete a webform, or when you visit us at one of our locations or events.
When utilizing our “Scan to Park” feature.
In connection with your interactions with us as a registered user of our websites.
We may use tracking tools like browser cookies, flash cookies, and web beacons.
Your Friends and/or Family. For example, if they provide your information in connection with utilizing our Products or Services. You should always be cautious of who you share your personal information with.
News Outlets, Social Media, Surveys, and Third Parties. We or outside parties on our behalf may conduct research and other activities that result in the collection of your personal information.
Related Entities and Affiliates. We may collect information about you from our affiliates and other related parties.
Service Providers and Contractors. We may engage service providers and contractors to collect information about you that is necessary to our business operations and/or provision of services to you. For example, we may the utilize third party property management companies at our locations to manage and enforce our policies.
Information Collected Automatically. As you navigate through and interact with our Website and app, we may compile statistical information concerning your usage of the Website and app through analytics services, such as those provided by Google Analytics.
Automated License Plate Recognition. When you enter lots owned or operated by UPP, UPP may employ the use of automated license plate recognition systems or license plate readers. Our automated license plate recognition systems compile your license plate information to effectuate our services. Please refer to our ALPR Policy for further information.
We will primarily use your PII to provide Products or Services to you. We will also use certain forms of PII to enhance the operation of our Site, improve our internal marketing and promotional efforts, statistically analyze Site use, improve our product and service offerings, and customize our Site’s content, layout, and services. We may use PII to deliver information to you and to contact you regarding administrative notices. Finally, we may use your PII to resolve disputes, troubleshoot problems and enforce our agreements with you, including our Terms of Use, and this Policy. We may also collect certain Aggregate Information. For example, we may use your IP address to diagnose problems with our servers, software, to administer our Site and to gather demographic information. We may use your personal information in the following ways:
· Operate and Improve our Business. We use information to provide our Services to you, to increase the efficiency of our business, and to improve our Products and Services.
· Other Business Purposes. We may also use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
· Analytics. We may monitor and analyze usage and trends to compile statistical information which we may use internally or provide to third parties.
· Process Transactions and Facilitate Customer Service. We use your information to complete purchases, to operate and personalize the Site, to send you confirmations and administrative messages, and to perform our customer service functions.
· Marketing and Advertising. We use your information to market our services to you, and to deliver information to you that we think may be of interest to you, such as articles, news, or information about various promotions and products. Additionally, we may communicate with you through social media concerning our products or services.
· Security and Fraud Prevention. We use your information to perform security and fraud prevention functions for the Site.
· Required by Law. We collect and use your information as required by law, for compliance purposes, or as necessary to investigate or remedy any actual or potential violation of our policies or to protect the rights, property, and safety of UPP Global or others, as appropriate.
3. Cookies, Web Beacons, and Tracking Technologies. Depending on how you use our Site, Content, and or Services, we may store cookies on your computer or device to collect certain Aggregate Information about our users and to customize certain aspects of your specific user experience. A cookie is a small data text file that is stored on your computer that uniquely identifies your browser. Cookies may also include more personalized information, such as the user’s IP address, browser type, server the computer is logged onto, area code and ZIP code associated with the server, and the user’s first name to welcome you back to our Site. We may use cookies to perform tasks such as: monitoring aggregate site usage metrics, storing and remembering your passwords (if you allow us to do so), storing account and advertising preferences that you have set, and personalizing the Services we make available to you. However, we do not store cookies to track your browsing behaviors. Most browsers are initially set up to accept cookies, however you may reset your browser to refuse all cookies or to indicate when a cookie is being sent.
Examples of this information may include: the number of visitors to the Website or to sections or pages within the Website, patterns of traffic flowing through the Website, length of time spent on the Website, or in sections or pages of the Website, the other sites that refer visitors to the Website, the pages of the Website that visitors frequently use as entry and exit points, utilization of the browser and operating systems and versions used by visitors to the Website. We also may use this personal information in our marketing and advertising services.
This Website may also use social media plugins (e.g. Facebook and LinkedIn) to enable you to easily share information with others. When you visit our Website, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our Website. If you are logged into the social media website (e.g. Facebook, Twitter) while browsing our Website, the social plugins allow that social media website to share data about your activities on our Website with other users of their social media website. You should always refer to those social media sites’ privacy and data/information sharing statements/policies.
As a courtesy, we provide links below with instructions on how to alter cookies, and other information collection and sharing with various browsers, and other third-party internet service providers. This list is not exhaustive, and you are solely responsible for finding and using the most up to date link address for each.
Provider/App/Service
Current URL
Chrome; Firefox; Internet Explorer / Edge; Opera; Safari
Flash cookies (not controlled through browser settings – but with a flash media player)
http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
Opt out of Google Tracking Analytics
https://tools.google.com/dlpage/gaoptout
Digital Advertising Alliance tools to opt out of interest-based advertising
https://optout.aboutads.info/ and https://optout.privacyrights.info
If you modify or block cookies and tracking tools or other information collection and tracking, certain features with respect to our Website, Services, and Content may not work, and not all the tracking described in this Policy will stop.
IMPORTANT: BY USING THE SITE, CONTENT, OR SERVICES AVAILABLE THROUGH THIS SITE, YOU GIVE YOUR CONSENT THAT ALL PERSONAL DATA YOU SUBMIT MAY BE PROCESSED BY US IN THE MANNER AND FOR THE PURPOSES DESCRIBED BELOW. IF YOU DO NOT AGREE TO THESE TERMS AND CONDITIONS, DO NOT USE THE SITE, CONTENT, OR SERVICES.
4. Consumer Data Privacy Rights. We are committed to consumer fairness, the following list ensures that you can diligently exercise your data privacy rights under applicable law. Please see section 10 for details on submitting a verifiable consumer request to delete, modify, or correct your PII, or otherwise exercise any of your applicable privacy rights.
Right to Opt-Out. You may exercise certain rights to review information collected about you, deleting any or all of it, correcting it, and opting out of cookie or other information collection, learn about and opt out of financial incentives offered with certain information collection, which are available to residents of California when browsing or using a device with an IP address that places the device within California (see California privacy rights under the CCPA), or similar options and rights legislated in Colorado (see https://coag.gov/resources/colorado-privacy-act/ and https://coag.gov/app/uploads/2023/03/FINAL-CLEAN-2023.03.15-Official-CPA-Rules.pdf), and in Virginia (https://www.oag.state.va.us/consumer-protection/files/tips-and-info/Virginia-Consumer-Data-Protection-Act-Summary-2-2-23.pdf and https://law.lis.virginia.gov/vacode/title59.1/chapter53/).
Other Rights. In addition to the Right to Opt-Out, you may have certain rights related to accessing your collected personal information, subject to certain exceptions, that we value and want you to be knowledgeable of. Please be advised that the following list may be subject to change and may not constitute an exhaustive list of additional rights under applicable law. Specifically, you have the:
· Rights to Deletion of Your PII. You may have the right to request deletion of your personal information from our records, subject to certain exceptions. As required by applicable law, and pursuant to a verifiable request, we will delete and direct any service providers to delete your personal information at your request.
· Right to Correct Your PII. You may have the right, subject to certain limitations, to request that we correct any inaccurate personal information we maintain about you.
· Right to Know What We Do With Your PII. You may have the right to confirm whether or not we process your personal information and, if we do, to request that we disclose the following to you upon receipt of your verifiable request:
o Types of personal information that we may have sold or disclosed for a business purpose
o Types of personal information we may have collected about you;
o The sources from which we may have collected that information from;
o That personal information we collected about you, and upon request, we will provide a copy of that information in a portable and readily usable format;
o Our commercial purposes for collecting, selling, or sharing that information;
o Third parties to whom we may sold or disclosed that information to.
· Right Against Discrimination.You may have the right not to be discriminated against for exercising any of the rights described in this section. Namely, you will not experience disparate treatment as it related to our actions, quality of, or delivery of services if you choose to exercise your data privacy rights.
· Right to Consent to or Limit Use or Disclosure of Sensitive Personal Information. You may have the right, subject to certain exceptions, to consent to or request limitations on the use and disclosure of your sensitive personal information under applicable law. Additionally, it is not our intention to, and we do not use sensitive personal information to, infer characteristics about data subjects, nor for any purpose other than those pursuant to Section 7027(m) of the California Consumer Privacy Act.
Privacy Rights Applicable to California Residents ONLY.
This section applies only to California residents. It supplements and amends the foregoing as well as other information contained in the Policy (as may be applicable) with respect to California residents. The other provisions of the Policy continue to apply, except as modified in this section.
· California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes. Such requests must be submitted to us in accordance with the instructions in the “Consumer Requests” section of this Policy. Please mention when contacting us that you are making a “California Shine the Light” inquiry. Within 30 days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than in accordance with the instructions specified in this paragraph.
· If you are a California resident under the age of 18, and are a registered user of any site where this Policy is posted, California law permits you to request and obtain removal of content or information you have publicly posted. You may submit your request using the contact information in “Consumer Requests” section of this Policy, subject to exceptions wherein applicable law does not require or permit removal, even if upon request of the consumer. Please be aware that your request may not ensure complete or comprehensive removal of the content or information you have posted based on these applicable law exceptions. If you are a California resident, you may opt out of such future sharing of your personal information (as defined under the California Shine the Light Act) and/or request information concerning our compliance by contacting us in accordance with sections 10 and/or 11 below.
Limitations On Requests. Upon receipt of a verifiable consumer request consistent with the terms of this Policy, and as may be required by applicable law, we will take appropriate steps to respond to your request. Additionally, and as may be required by applicable law, you can require us to only process your personal and/or personally identifiable information with your consent. However, we may not be required to comply with deletion requests if we, or our service providers, contractors, or affiliates, require the information that is the subject of the request for the following purposes:
· For software related issues like debugging of errors or issues;
· To detect, protect, or prosecute against security threats and malicious, deceptive, fraudulent, or illegal activity;
· To complete the transaction for which your personal information was collected, to perform a contract between us and you, or in connection with providing you goods or services requested by you (or as reasonably anticipated) in the furtherance of our ongoing business relationship with you;
· For the exercising of free speech or to otherwise ensure the free speech rights of other consumers in accordance with applicable law;
· For compliance with applicable regulations, legal obligations, and criminal laws;
· To use your PII for additional internal and lawful business purposes that are compatible with the context to which your PII are provided and subject to any restrictions that you may have requested.
5. Disclosure/Release of Personal Information. We will not sell, trade, or rent your PII to others. We do provide some of our Products and Services through contractual arrangements made with affiliates, advertisers, other service providers, and other third parties that we work with from time to time (“Service Partners”). A list of our Service Partners can be provided upon request. We and our Service Partners may need to use some of your PII to perform tasks between our respective sites, or to deliver products or services to you. We encourage our Service Partners to adopt and promote strong privacy policies. However, the use of your PII by our Service Partners is governed by their own respective privacy policies and is under their control, not ours. Except as otherwise discussed in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. Other Sites accessible through this Site, including our advertisers, and our other Service Partners, have their own privacy policies and data collection, use, and disclosure practices. Please consult each Site’s privacy policy. We are not responsible for the policies or practices of our Service Partners or other third parties.
· As Required By Law. We also may be required by law enforcement or judicial authorities to provide PII to the appropriate governmental authorities. In such cases, we will disclose PII upon receipt of a court order, subpoena, or for cooperating with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful or as we deem appropriate.
· Analytics. We also may provide Aggregate Information about our customers’ sales, traffic patterns, and related Site information to third-party advertisers, but these statistics do not include any PII.
· Other Purposes. We may disclose your personal information for the same reasons that we may use it, as described in this Policy, which includes disclosing it to our affiliates and non-affiliated third parties, as we deem necessary to carry out those purposes. We endeavor to choose affiliates and non-affiliates with similar standards to ours regarding the protection of data.
6. Information Retention.We shall retain your personal information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), to resolve disputes, enforce our legal agreements and policies, and other legitimate business needs, or for other purposes for which the information was obtained in accordance with applicable law. Our retention period is based on: (1) the nature of our relationship with the data subject, and (2) any legal obligations we are bound to fulfill.
7. Policy for Children. Pursuant to the Children’s Online Privacy Protection Act, we do not knowingly collect, use, or disclose PII about children under thirteen (13) years of age. If the parent or guardian of a child under 13 believes that the child has provided us with any personal information, the parent or guardian of that child should contact us and ask to have this personal information deleted from our files. Personal information about a child under 13 will be subject to deletion. By using this Website, you represent that you have the requisite legal authority to do so. We prohibit children under the age of 13 from using any interactive portion of this website.
8. Security.We work hard to ensure that the data we collect is reliable, accurate, complete, and current. We encrypt all PII, to protect against unauthorized parties viewing such information when it is transmitted to us. The collected information, even if kept indefinitely, is used only for the purposes for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.
We limit access to PII only to specific employees, contractors, and agents who have a reasonable need for that access. For example, we may provide members of our technical support team with limited access to your account to allow them to troubleshoot problems you may be having with the Site.
We also employ numerous physical, electronic, and procedural safeguards to protect your rights in your PII. Our secure servers and our data centers are protected by industry-standard encryption, and our servers reside behind firewalls and employ high-level password protection.
The measures we use are appropriate for the type of information we collect. Unfortunately, there is no way to give a 100% guarantee of security for any data transmission over the Internet or through any other communication channel. As a result, while we strive to protect your PII, you acknowledge that: (a) there are features inherent to the Internet and other communication networks which limit our ability to preserve data security, integrity, and privacy in ways that are beyond our control; and (b) the security, integrity, and privacy of information and other data that you exchange with us through this Site or through other communication channels cannot be guaranteed.We encourage you to use caution when using the Internet.
9. Website Users Located Outside the U.S.We control and operate the Site and our services from within the United States of America (the “U.S.”). Information collected through the Site may be stored and processed in the U.S. or any other country in which our vendors or we maintain facilities. Similarly, the English language version of this Privacy Policy is the controlling version regardless of any translation you may attempt. The data protection laws in U.S. may not provide you with the same protections as those of your jurisdiction. If you are located in the EU or EEA, or elsewhere outside of the United States, please be aware that any information you provide will be transferred to the United States. By using this Website, using any of its services, and/or providing your information, you acknowledge that these laws may provide a different standard of protection, and you consent to the transfer of your personal data to other jurisdictions, including the U.S.
10. Consumer Requests; Updating and Correcting Information.We believe you should have the ability to access and edit the PII that you have provided to us. We also encourage you to promptly update your PII if it changes. You may access correct, or change any of your PII or privacy preferences at any time by submitting a verifiable consumer request by emailing us at support@uppglobal.com or writing to us at: Attn: Privacy Compliance, 496 Congress Street, Suite 3, Portland, Maine 04101.
Please include your name, mailing address, and email address when you contact us as well as detailing your request(s). We reserve the rights to request additional information and to only respond to verifiable requests made by you, and/or an authorized representative or guardian. If we cannot verify your identity or authorization of the consumer request, we may not be able to respond to your request. To verify your identity, we recommend using your personal information previously used by you with us.
In the event you believe we have erroneously denied your request, in full or in part, you may, within sixty (60) days of receipt of that denial, submit an appeal by emailing us at support@uppglobal.com , stating in the subject line of the e-mail “Privacy Request Appeal.” Otherwise, please contact 207-747-4230 with your request as well as any questions or concerns. In your appeal submission, please explain why you believe our decision to deny your request was incorrect and please provide any additional information you believe we should consider in connection with your appeal.
11. Contact Us. If you have additional questions or comments about this Policy, please send us an email at support@uppglobal.com. If you prefer, you may also contact us via physical mail at: 496 Congress Street, Suite 3, Portland, Maine 04101.
Updated 11/12/2024