Privacy Policy

Effective as of June 29, 2019

INTRODUCTION

Please read the following privacy notice carefully to understand our practices regarding the processing of your personal data. We are Renewed Edge Limited, a private limited company incorporated in Hong Kong (hereinafter the “Company” or “we”). We may change the Privacy Policy from time to time and we will inform you of the changes to the Privacy Policy via the available means of communication. The Company recommends you to check our application (hereinafter the “App”) or our website at https://upnow.com (hereinafter the “Site”) frequently to see the actual version of the Privacy Policy and its previous versions.

1. PURPOSE, SCOPE, AND USERS

We have adopted this Privacy Policy and will make sure it is maintained and followed. We make efforts to comply with applicable laws and regulations related to personal data protection in countries where we operate. This Privacy Policy sets forth the basic principles and rules by which we process, collect and store your personal data, and the Privacy Policy indicates our duties and responsibilities while processing, collecting and storing your personal data.

We do not knowingly attempt to solicit or receive information from children or disabled people. The particular age of the children are defined differently in many countries, so any case involving a child will be reviewed individually.

We understand that you are aware of and care about your own personal privacy rights and interests, and we take that fact seriously. This Privacy Policy describes the policies and practices regarding the collection and use of your personal data, and sets forth your privacy rights. We recognize that privacy is an ongoing responsibility, and so we will follow and, from time to time, improve this Privacy Policy as we undertake new personal data practices or adopt new privacy and security rules. Our business model may also change and it may require changes to the current version of the Privacy Policy.

All countries have different privacy and data protection laws and we will do our best to follow such rules when they apply to a particular case.

Any data collected or processed via the App or Site is covered by the Privacy Policy in effect at the time such data is collected. We may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of those changes by posting them on the App or Site or by sending you an email or other notification as required by applicable law, and we’ll update the “Effective as of” above to indicate when those changes will become effective. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the App or Site after the updated Privacy Policy is posted on the App or Site. If at any point you do not agree to any portion of the Privacy Policy then in effect, you shall immediately stop using the App or Site.

2. TERMS WE USE AS LEGAL GUIDELINES OF THE PROCESSING

There are some legal bases for the processing of your personal data and we count on them to process your personal data. We use three main bases to process your personal data such as consent, contract, and legitimate interest.

Consent means your clear agreement to the processing of personal data for a specific purpose. We developed our services in the way that they collect your consent as freely given, specific, informed and unambiguously indicated.

Contract is a ground why the processing is necessary based on a contract you have with us, its performance, or because we have asked you to take specific steps before entering into that contract.

Legitimate Interests mean why the processing of personal data is necessary and based on our legitimate interests or the legitimate interests of a third party, provided that those interests are not outweighed by your rights and interests.

There are also other legal grounds for the processing and when they apply we will count on such grounds.

3. CONSENT RULE AND INTERRELATION WITH OTHER LEGAL GROUNDS

If you have given consent to the processing of your data you can freely withdraw such consent at any time by emailing us or contacting via the contact form.

If you do withdraw your consent, and if we do not have another legal basis for the processing of your data, then we will stop the processing of such personal data.

If we have another legal basis for the processing of your data, then we may continue to do so subject to your legal interests, rights and objection.

4. OUR RESPONSIBILITIES

If you are a registered user or a visitor to our App or Site who is a data subject, we may act both as “data controller” or “data processor” of personal data. This means we may determine how and why your or someone’s data are processed or we process some personal data on your or third party’s behalf.

In some cases, we may not be involved into the processing activity with your personal data at all. This may happen when you use third parties to process your personal data.

5.YOUR RESPONSIBILITIES

Privacy and data protection are a two way street which means that you also have to take some steps to protect your privacy.

So you should:

– read this Privacy Policy carefully;

– make sure you understand all your rights;

– treat your personal data secure and confidential.

If you provide us with personal data about other individuals, we will only employ that data for the special reason for which it was provided to us. By sending the data, you confirm that you have the right to process the data on your behalf in accordance with this Privacy Policy.

In case if you submit third party’s personal data, be sure that you have legal basis for the processing of such data.

6. COLLECTED DATA AND RECIPIENTS

We collect data when you interact with our App or Site, especially when:

– you fill out our contact form and send data;

– you fill out our signup form and send data;

– you purchase something;

– you browse or use pages;

– you use the App or Site;

– you receive emails from us;

– we measure App or Site traffic;

– in cases we have a legal basis to collect some part of personal data.

We process the following types of data:

– contact details such as your name, address and other information you provide to us;

– data connected to your use of the services we provide;

– purchasing history and payment details;

– data that identifies you such as your IP address, login information, browser type and version, time zone setting, browser plug-in types, geolocation information about where you might be, operating system and version;

– data on how you use the App or Site such as your URL clickstreams (the path you take through App or Site), goods/services viewed, page response times, download errors, how long you stay on webpages, what you do on those pages, how often, and other actions.

The recipients of the collected data is the highest management level and employees of the Company. We have appropriate security and organizational arrangements with employees and freelancers when applicable, especially we have security policy, a standard data processing agreement, non-disclosure agreements, and internal privacy instructions. For example, we educate employees to always lock the screen of their devices when leaving it unattended. We have set two-factor verification for our accounts when applicable.

7. PURPOSES AND LEGAL BASIS FOR THE PROCESSING

We process the data for:

– Providing services and registering you as a user:
Details: we need to provide services accessible via App or Site.
Legal basis: Consent; Legitimate Interests.

– Keeping the App and Site running:
Details: managing your requests, login and authentication, remembering your settings, hosting and back-end infrastructure.
Legal basis: Legitimate Interests.

– Providing newsletters/offers/updates which may be interesting to you.
Legal basis: mainly, it is Consent but in rare situations, we may count on Legitimate Interests.

– Processing payment information and purchase history:
Details: processing payments to identify what you purchased.
Legal basis: Legitimate Interests.

– Improving the App or Site:
Details: testing features, interacting with feedback platforms, managing landing pages, browsing history and use of the App or Site, traffic optimization and data analysis and research, including profiling and the use of machine learning and other techniques over your data and in some cases using third parties to do this.
Legal basis: Contract; Legitimate Interests.

– Customer support:
Details: notifying you of any changes to the service, solving issues, any bug fixing.
Legal basis: Contract; Legitimate Interests.

– Preventing frauds, illegal activity or any violation of the terms or Privacy Policy:
Details: we may disable access to the App or Site in cases when such access is restricted or prohibited by the applicable law or in case of your inappropriate behavior.
Legal basis: Legitimate Interests.

8. DATA SUBJECT’S RIGHTS

You may choose not to provide us with personal data. If you choose to do so, you can restrictively continue to visit App or Site and browse its pages, but we may not be able to provide you the full range of services without some parts of your personal data.

You may turn off cookies in your browser via settings. You can block cookies on your browser refusing cookies. You may delete cookies. If you turn off cookies, you can continue to use App or Site and browse its pages, but App or Site and certain services will not work properly.

You may ask us to refrain from using your data for marketing (when applicable). You can opt out from marketing by emailing us or contacting via the contact form.

You can exercise the following rights by sending us an email or contacting via the contact form.

You have the right to access information about you, especially, the categories of data; the purposes of data processing; third parties to whom the data disclosed; how long the data will be retained and the criteria used to determine that period; other rights regarding the use of your data.

You have the right to make us correct any inaccurate personal data about you.

You may object to using your personal data for profiling you or making automated decisions about you. We may use your data to determine whether we should let you know information that might be relevant to you (for example, tailoring emails to you based on your behavior).

You have the right to the data portability of your data to another service or website/application. We will give you a copy of your data in readable format so that you can provide it to another service. If you ask us and it is technically possible, we will directly transfer the data to the other service for you.

You have the right to be “forgotten”. You may ask erasing any personal data about you, if it is no longer necessary for us to store the data for purposes of your use of App or Site.

You have the right to lodge a complaint regarding the use of your data by us. You can address any complaint to your national regulator.

In the context of the right to access information we shall provide you with the information within one month of your request unless there is a justified requirement to provide such information faster or later.

9. SECURITY

We have security and organizational measures and procedures to secure the data collected and stored.

Connections to App or Site are encrypted. We use SSL transfer protocol (https).

We use servers that comply with strict international data security standards, including ISO 27001.

You acknowledge that no data transmission is guaranteed to be 100% secure and there may be risks.

You are responsible for your login information and password. You shall keep them confidential.

In case if your privacy has been breached, please contact us immediately at privacy@upnow.com.

10. LOCATION OF THE PROCESSING OF PERSONAL DATA AND THIRD PARTY SERVICE PROVIDERS

The personal data collected by us is processed in our headquarter in Hong Kong.

We work with some third parties, businesses and organizations, in a variety of ways to effectively provide our services and maintain the functionality of the Site and Apps. They process personal data on our behalf, to support our services, based on our instructions and in compliance with our Privacy Policy, their policies, and other appropriate confidentiality and security measures. List of the third parties is available on a separate page.

The Site and App may offer various tools and functionalities. Our referral services may allow you to invite a friend by email to use our Site. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content related to Site and/or App or link you request, but will not be collected or otherwise used by us or any other third parties for any other purpose.

There is also a list of social media websites where we have our pages. The use of such social media websites is regulated by their terms and privacy policies. You may share the information about our App and Site using special tools available on the Site.

We may use in-app push notifications to inform you about something new, to receive your approval or for other aims which we will indicate in our notification.

We may turn off some of the third parties mentioned above. In case if we do so, we will make changes to this Privacy Policy when applicable.

11. RETENTION PERIOD

Our retention practice depends on the type of data we collect, regulatory burden, and how we use the personal data. The retention period may also be based on criteria that include legally mandated retention periods, pending or potential litigation, intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving.

Please contact us to receive a detailed information regarding the retention period of your personal data.

12. COOKIE POLICY

We collect certain types of information when you access or use App or Site, including cookies and similar tracking technologies.

Cookies are small data files that are placed on your computer or mobile device when you visit this App or Site. Cookies are used by App or Site in order to make App or Site work, or to work more efficiently, as well as to provide reporting information.

You may always turn off some of the cookies through your browser or device. If you turn off the cookies, this may influence the functionality of App or Site.

The list of cookies we use is listed in your browser or device.

We use social media widgets such as the Facebook “Like” button and LinkedIn (that might include widgets such as the share this button or other interactive mini programs) may be on our Site or App. These features may collect your IP address, which page you are visiting on the Site or App, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on the Site or App. Your interactions with these features are governed by the privacy policy of the company providing such widgets.

13. TRANSFER OF YOUR PERSONAL DATA

Personal data we collect from you will be processed in our headquarter in Hong Kong.

Hong Kong has not received a finding of “adequacy” from the European Union. Therefore, in case when we transfer personal data from the European Union, we rely on derogations for specific situations. In particular, we collect and transfer to Hong Kong personal data only: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms. We endeavor to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with us and the practices described in this Privacy Policy. We also enter into data processing agreements and model clauses with our vendors whenever appropriate.

14. CONTACT INFORMATION

If you have any questions or need to make an enquiry, please contact us at privacy@upnow.com

Privacy Preferences
When you visit our website, it may store information through your browser from specific services, usually in form of cookies. Here you can change your privacy preferences. Please note that blocking some types of cookies may impact your experience on our website and the services we offer.