Privacy Policy

At Upflo (https://www.upflostrategy.com), we value your privacy. To put this into practice, we take reasonable measures to protect your privacy and manage your information.

This Privacy Policy describes the information we collect, where it comes from, how it is used, and how it is stored.

This Privacy Policy also includes information to help you understand how the choices you have can influence the collection and use of certain information, as well as how you can contact us if you have questions or concerns.

By using this website, contacting us, or providing personal information, you signify your consent to this Privacy Policy, agree to comply with its terms, and consent to the collection and use of your personal information as described in this Privacy Policy, subject to applicable law.

Scope

This Privacy Policy on https://www.upflostrategy.com/en/privacy-policy applies only to our website at https://www.upflostrategy.com/en (the "Website") and to visitors and users of our Website. It does not apply to information we collect through channels, online or offline, other than this Website, such as telephone, email, or mail operations concerning our activities, products, or services, as well as off-site marketing contacts with you.

For your convenience, this Website may contain links to other websites. This Privacy Policy does not apply to third-party websites or services, and you should review the privacy policies of those sites before using them, as other websites may not handle information collected online in the same way we do. These privacy policies may include information on how to view, modify, download, or delete information or opt out of certain practices. We are not responsible for the privacy practices, advertising, products, or content of these sites.

Updates and Changes

If we decide to modify our Privacy Policy, we will post these changes on this page at https://www.upflostrategy.com/en/privacy-policy.

If you are concerned about how your personal information is used, please frequently visit our website to review other announcements and important updates.

Issues/Questions

If you have any questions or concerns regarding our Privacy Policy, you can contact us at info@upflostrategy.com

Information We Collect

This section includes a general description of the type of information we may collect about you. Those who wish to contact us but do not wish to provide personally identifiable information via the Website can contact us through the address or phone numbers provided on our website.

Information You Provide to Us

• We may collect personal information at various times during your relationship with Upflo, including:
• When you provide your personal information during the inquiry, activation, or purchase of a product or service.
• When we provide you with a service, such as technical support or assistance requests.
• When you use our products or services, visit our websites (information being collected via cookies or similar technologies), use any of our applications, or call a call center.
• When we communicate with third parties, such as revenue agencies or credit evaluation agencies or other third parties with whom you have had a relationship.

Information We Collect About You

Even if you do not submit personal information via the website, we collect browsing information about where visitors go on the website, as well as information about the technical performance of our website and services (such as website connection times or page load times). This information allows us to see which parts of our website are most visited and helps us better understand the user experience. This data helps us improve the quality of the website by recognizing and providing more of the features, areas, and services that our visitors prefer.

In the process of collecting information, we may collect personally identifiable information and non-personally identifiable information (such as domain type, browser type and version, service provider and IP address, referral/exit pages, operating system, date/time, and clickstream data). We collect this information to fulfill any contract you may have with us, and as part of our legitimate business interests.

We may also create and use electronic records to compile statistics on how our visitors collectively interact with our website by collecting, aggregating, and using information about you, such as data on browser type and operating system used, web pages you view, the time and duration of your visits to our website, search queries you use on the website, whether you clicked on items or links on the website, whether you clicked on links in emails sent by us or third parties on our behalf, whether you opted out of certain services or shared information, and whether you viewed or ordered certain products or services, in order to improve our products and services. We collect this information to fulfill any contract you may have with us and as part of our legitimate business interests.

We may obtain information about you from external sources. For example, we may obtain commercially available information about you from third parties, such as credit information to prevent fraud, or purchase email lists from third parties for advertising and marketing purposes. We collect this information to fulfill any contract you may have with us and as part of our legitimate business interests.

If you access the website using a device, we may collect the following device-related data:

• Device type
• Operating system
• Unique device identifiers
• Device settings
• Geolocation data
• IP addresses
• Browser type
• Browser identifier
• Clickstream data
• User workflow progress

We collect this information to fulfill any contract you may have with us and as part of our legitimate business interests.

Widgets

A widget is a small application embedded in a web page. Widgets are typically dynamic, not static: they can provide updates of information on a web page, or users can interact with them. Appointment calendars and chat tools are common examples of widgets. Most widgets come from third-party companies that provide these services to us. Widgets may share data with their provider as well as with us.

We collect this information with your consent and as part of our legitimate business interests.

Ads, Analytics, and Other Google Services

Google provides several different technologies to our website as part of delivering services to our users. These services may include the use of cookies, which we have described elsewhere in this Privacy Policy. You may want to review Google's privacy and terms page on advertising (https://policies.google.com/technologies/ads) to determine what options you have for controlling the collection and use of your information.

Similarly, Google Analytics uses cookies and device identifiers as part of providing its analytics. This, and other analytics software, track website usage (pages, forms, and files) and traffic (referral pages, pages visited, and exit pages) to help us understand how users use the website. You may want to review details on how Google Analytics collects and processes data in "How Google Uses Data When You Use Our Partners' Sites or Apps" (https://www.google.com/policies/privacy/partners/).

We collect this information to fulfill any contract you may have with us and as part of our legitimate business interests.

How We Use Personal Information

We collect personal information in order to:

• Operate and improve our website
• Operate our business
• Improve our products and services
• Communicate with you
• Ensure legal compliance

Operate and Improve Our Website

Here are some examples of what we mean by operating and improving our website:

• Maintain the operation of the website
• Personalize your experience on the website
• Provide support and respond to user and visitor inquiries
• Maintain the security of information and data
• Address operational, engineering, and network troubleshooting issues
• Prevent fraud
• Improve our website
• Enhance, personalize, and develop our website
• Personalize experiences
• Understand and analyze your use of our website
• Understand user needs
• Track traffic and usage trends on the website
• Personalize our recommendations and promotions for you

Operate Our Business

Here are some examples of what we mean by operating our business:

• Maintain the operation of Upflo
• Provide our offerings
• Comply with legal requirements
• Fulfill orders and deliveries
• Recruit team members
• Manage our business and keep appropriate records
• Engage in the sale of all or part of our business

Improve Our Products and Services

Here are some examples of what we mean by improving our products and services:

- Develop new products, services, or features
- Measure, support, and enhance our offerings
- Analyze trends and conduct research to improve our products and services

Communicate with You

Here are some examples of what we mean by communicating with you:

• Provide customer service
• Send you emails, mail, or contact you in the manner you approve, such as by phone or SMS
• Provide you with updates and other information related to the website
• Send you marketing messages
• Send you surveys
• Launch and operate promotions
• Suggest products or services that may interest you
• Contact you for research or informational purposes
• Facilitate online registration and provide customer service related to registration
• Send email newsletters

How We Share Personal Information

We do not share your personal information outside of the company unless required by law or as stated elsewhere in this Privacy Policy.

Location of Personal Information

We must, of course, store and process your data somewhere.

We store and process your data in the following countries: Canada.

How We Secure Information

We believe in providing a safe and secure experience for all our online visitors. To this end, we have implemented reasonable security measures to protect the information we collect from you. We maintain reasonable physical and electronic security measures designed to limit unauthorized access to your personal information and to protect against criminal misuse of that information.

Although we use these security measures to protect your information, please remember that no data transmitted over the Internet or stored and used for commercial purposes can be completely secure. No security measure is perfect or impenetrable. We cannot guarantee:

• That your information will be seen only by authorized individuals.
• That the information you share will remain private.
• That the information you share will not become public.

You can reduce the likelihood of these events occurring by using a strong password, not reusing passwords, and protecting your devices from viruses and other malware.

Business Transactions

If we sell our assets or merge with another company, or if our company ceases operations, the user information used by the business will be one of our assets that may be transferred to our successor. You consent to the use of your information by this successor, in accordance with the terms of this Privacy Policy.

Access and Choices

You have choices regarding the information we collect.

If you do not wish to accept the ways we have mentioned that we may use your personal information, the first and best step is not to provide us with that personal information.

If you do not wish to receive the emails we send, including those containing information or promotions, you can unsubscribe from these emails by clicking the unsubscribe link, replying with "unsubscribe," or contacting the "support" email address below.

If you do not wish to receive other marketing materials from us or if you do not want us to share your personal information with other entities as described in this Privacy Policy, please send us your name, address, and email address, along with a statement indicating that you wish to unsubscribe from information dissemination or receiving materials (or both).

Please send your information and request to:

info@upflostrategy.com

or

send your information and request to:

[Company Address]

Children's Personal Information

This website is not intended for use by children under 13 years old. Children under 13 should not use or submit information on the website, and their guardians should not allow them to do so. The company does not knowingly seek to collect personal information from children under 13. If such a child or their guardian alerts us, we will take reasonable steps to delete that information as quickly as possible.

GDPR Privacy Rights

If you are a resident of one of the EU countries or other covered nations and the processing of your personal information by the website is subject to the GDPR, you have certain rights regarding that information, subject to applicable law. Some issues regarding the applicability of GDPR to non-EU businesses are relatively new, and therefore the correct interpretation of these laws is not yet settled in some cases. In such cases, we will make a good faith effort to comply with applicable law.

You have the following rights:

1. Right to Information - You can request that we confirm whether or not we are processing your personal data.
2. Right to Access - You can request access to your personal data that we process; you can request to receive a copy of the personal data you have previously provided to us in a portable and machine-readable format.
3. Right to Rectification - You can correct inaccurate, incorrect, or incomplete personal data.
4. Right to Erasure - You can request that we delete personal data that is no longer necessary or if its processing is unlawful.
5. Right to Object - You can object to the processing of personal data for marketing purposes or other reasons related to your particular situation.
6. Right to Restriction - You can request the restriction of the processing of your personal data in specific cases.
7. Right to Human Review - You have the right to human review of automated processing or automated decision-making, including the right to participate and the right to appeal.

Please make all your requests under EU law, if applicable, using one of the following methods:

info@upflostrategy.com

[Company Address]

We have the following obligations, subject to applicable law:

1. Timely Response to Requests - We must respond to your requests without undue delay and in any case within one month of receiving the request. We may extend this period by up to two additional months if necessary, taking into account the complexity and number of requests. We must inform you of any such extension within one month of receiving your request, as well as the reasons for the delay. Generally, we will provide information in response to your requests free of charge, unless the requests are unfounded, excessive, or repetitive. In such cases, we may choose to refuse your request in the absence of payment of a reasonable fee.

2. Our Obligations - We must process data lawfully, fairly, and transparently. We must process data for a limited purpose for which it was provided. We must minimize the data collected in relation to the purpose of processing. We must maintain data accuracy and keep it up-to-date. We must limit data retention when it is no longer necessary. We must protect data against unauthorized or unlawful processing and against accidental loss, destruction, or damage.

3. Data Breach Notifications - In case of a data breach, we must notify users "as soon as possible." We have 72 hours to notify the competent supervisory authority. Note that if we are not established or operating in the EU, there is no applicable supervisory authority.

4. Data Protection Officer - If we are required to appoint a Data Protection Officer, we must also inform you of the identity and contact details of the Data Protection Officer.

Data Protection Officer: Samantha Chahine

DPO Contact Details: info@upflostrategy.com

[Company Address]

Updated: August 13, 2024