Privacy Policy

Last modified: September 18, 2018

Your privacy is very important to us. This Privacy Policy explains our information privacy practices and the choices you can make about the way your information is collected and used. When you access and use our website and the Uelco services in any manner, features and information available on our website (collectively, the “Services”), you are consenting that we will collect, use, and share your Personal Data as described in this Privacy Policy. Remember that your use of the Services are at all times subject to the Terms of Service, which incorporates this Privacy Policy.

What does this Privacy Policy cover?

This Privacy Policy covers our treatment of personally identifiable information (“Personal Data”) that we gather when you are accessing or using our Services, but not to the practices of companies we don’t own or control, or people that we don’t manage. We gather various types of Personal Data from our users, as explained in more detail below, and we use this Personal Data internally in connection with our Services, including to personalize, provide, and improve our services, to allow you to set up a user account and profile, to contact you and allow other users to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some Personal Data with third parties, but only as described below.

We do not knowingly collect or solicit personal information from anyone under the age of 16. If you are under 16, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us personal information, please contact us at support@uelco.co.

Personal data

Personal data shall mean any information concerning the personal or material circumstances of an identified or identifiable natural person. This includes, in particular, information which can be traced back to your identity, such as your name, telephone number, mailing address or email address. Statistical data collected when users visit our website and which cannot be directly linked to your identity is, for instance, not considered/classified as personal data.

Controller

The Personal Data is gathered and used by Miropia Inc. (“Uelco”), a legal entity established under the laws of Canada and registered at the address: 10 Church St N, Unit 5, Richmond Hill, ON, L4C 3E7, Canada.

What Information does Uelco Collect?

1. Information you provide to us

We collect Personal Data about you when you provide such information directly to us or when Personal Data about you is automatically collected in connection with your use of the Services.

Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:

Information we receive from third party sources: Some third parties provide us with Personal Data about you, such as the following:

Account information for third party services: If you provide your third-party account credentials to us or otherwise sign in to the Services through a third party site or service (e.g. Slack or Google SSO), you understand some content and/or information in those accounts (“Third Party Account Information”) may be transmitted into your account with us if you authorize such transmissions, and that Third Party Account Information transmitted to our Services is covered by this Privacy Policy. Certain information may be required to register with us or to take advantage of some of our features.

2. Information collected automatically

Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, such as the following:

We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services – for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.

The access data is additionally saved to the logfiles, in order to develop our website further with regard to the usage patterns of our visitors and in order to administer our service in a general way. The information saved in the logfiles allows no direct conclusion to be drawn about you as a person - in particular, we save the IP addresses only in abbreviated, anonymised form. The logfiles are saved for 30 days and archived following subsequent anonymisation.

How do we use your Personal Data?

We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:

Additionally, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our services. If you do not want to receive communications from us, please indicate your preference by changing the notification settings in the Uelco web application or clicking the unsubscribe links in email.

Will Uelco share any of the Personal Data it receives?

We do not rent or sell your Personal Data in personally identifiable form to anyone. We may share your Personal Data with third parties as described in this section:

Information that’s been de-identified. We may de-identify your Personal Data so that you are not identified as an individual, and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual person.

Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. These parties include:

Unless we tell you differently, our agents do not have any right to use the Personal Data we share with them beyond what is necessary to assist us.

User profiles and submissions: Certain information, including your name, location, team and any video or image content that such user has uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address your request for our services. Please remember that any content you upload to your user profile, along with any Personal Data or content that you voluntarily disclose online in a manner other users can view (on discussion boards, in messages and chat areas, etc.) can be collected and used by anyone in your Uelco Org. Your name may also be displayed to other users if and when you send messages or comments or upload images or videos through the Services and other users can contact you through messages and comments.

Your organization: If the email address under which you have registered your User account belongs to or is controlled by an organization (e.g., your employer), we may disclose that email address and other pertinent account information to that organization in order to help it understand who associated with that organization uses Uelco, and to assist the organization with its accounts. In addition, if your User account details are different from the billing contact listed for your account, we may disclose your identity and the account details to the billing contact upon their request.

Business transfers: We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if Uelco (or its assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Data could be one of the assets transferred to or acquired by a third party.

Protection of company and others: We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law or court order; enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of Uelco, our employees, our users, or others (for example, to prevent spam or other unwanted communications and investigate or protect against fraud); or maintain the security of our products and services.

Is Personal Data about me secure?

We do not use or store passwords for your Account. Your account is protected by your email password for your privacy and security. You must prevent unauthorized access to your account and Personal Data by protecting access to your email appropriately and limiting access to your computer or device and browser by signing out after you have finished accessing your account.

All Personal Data transmitted over public networks is encrypted with the latest recommended secure cipher suites, including use of TLS 1.2 (a strong protocol), ECDHE_RSA with P-256 (a strong key exchange), and AES_256_GCM (a strong cipher). This also applies to Personal Data transmitted between you and Uelco and through the Services.

Your Personal Data is hosted in Uelco’s shared infrastructure and segregated logically by user ID. We use industry standard methods for data encryption and key management. Furthermore, we authorize select employees to access Personal Data only as needed to fulfill their job responsibilities.

We endeavor to protect the privacy of your account and other Personal Data we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

What Personal Data can I access?

Through your account settings, you may access, and, in some cases, edit or delete the following information you’ve provided to us:

The information you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on file about you, please contact us at support@uelco.co.

What choices do I have?

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us.

You may be able to add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by removing yourself from the organization in the Settings page of the web application. Some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Data after you update or delete it, but not in a manner that would identify you personally.

What if I have questions about this policy?

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to support@uelco.co and we will try to resolve your concerns.

EU Residents

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Uelco will be the controller of your Personal Data processed in connection with the Services. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of the Services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at support@uelco.co.

Grounds for Processing

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Service with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.

Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.

Examples of these legitimate interests include:

Consent: In some cases, we may process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

Other processing grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

For how long does Uelco retain my Personal Data?

We generally retain data for as long as you have an account with us, or to comply with our legal obligations, resolve disputes or enforce our agreements.

What rights do I have regarding my Personal Data?

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email support@uelco.co.

Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access or change certain of parts your Personal Data by going to your Profile in the Uelco app. You can also delete resources you’ve created, or requests you’ve filed, by going to those sections and searching for those created by you.

Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by going to your Profile in the Uelco app.

Erasure: You can request that we erase some or all of your Personal Data from our systems.

Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.

Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.

Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.

Restriction of Processing: You can ask us to restrict further processing of your Personal Data.

Right to File Complaint: You have the right to lodge a complaint about Uelco’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Transfers of Personal Data: The Services are hosted and operated in the United States (“U.S.”) through Uelco and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Uelco in the U.S. and will be hosted on U.S. servers, and you authorize Uelco to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. pursuant to: (i) a data processing agreement incorporating standard data protection clauses promulgated by the EC, a copy of which can be obtained at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087, (ii) binding corporate rules for data protection that align with the GDPR’s requirements, or (iii) adherence to an industry- or technology-specific approved code of conduct blessed by the EC.

What if I have questions regarding my Personal Data?

If you have any questions about this section or our data practices generally, please contact us at support@uelco.co.

Cookies

When you visit any web site, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience.

Because we respect your right to privacy, you can choose not to allow some types of cookies. However, blocking some types of cookies may impact your experience of the site and the services we are able to offer.

We may use the following types of cookies and tracking technologies:

Strictly Necessary Cookies. These cookies are essential because they enable you to move around our Services and use certain features on our Services. For example, strictly necessary cookies allow you to access secure areas. Without these cookies, some Services cannot be provided.

Performance/Analytics Cookies. These cookies collect information about your use and interaction with our Services. The types of information collected by such cookies include which pages you go to most often, how much time you spend on that page, or if you get error messages from certain pages.

Functionality Cookies. These cookies allow us to remember your preferences and choices so that we can tailor our Services to you and your interests. For example, these cookies will remember which country or language you selected, or will use your display name on parts of the Services.

If you are signed in to your account, we may associate the cookie information with the Personal Information tied to your account.

You can instruct your browser, by changing its options under Settings or Preferences, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you will not be able to use some or all portions or functionalities of the Services.

Google Analytics

This website uses Google Analytics, a web-analysis service of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google Analytics uses cookies and similar technologies to analyse and improve our website on the basis of your usage pattern. The data accrued in this context may be transmitted by Google for analysis to a server in the USA and stored there. Should personal data be transmitted to the USA, Google has acceded to the EU-US Privacy Shield. Your IP address will be abbreviated prior to the analysis of usage statistics, however, so that no conclusions can be drawn about your identity. For this purpose, Google Analytics has been extended on our website to include the code "anonymizeIP", in order to guarantee an anonymised capture of IP addresses.

Google will process the information so gained in order to evaluate your use of the website, to assemble reports on the website activities for the website operators, and to supply further services connected with website use and internet use.

You will find more detailed information on this matter in the Privacy Statement of Google Analytics.

Designated Countries: Pursuant to the Data Protection Laws, we process this Personal Information to satisfy our legitimate interests as described above. As required by law, we will ask for your consent.

Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time. Uelo will try to notify you of these changes by placing a notice on uelco.co/privacy, by sending you an email, and/or by some other means but will not be liable for any failure to do so. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

Questions

If you have questions regarding our Privacy Policy or practices, please contact us at support@uelco.co