Information We Collect and Receive
We collect and receive information that relates to identified or identifiable individuals (“personal information“) as follows: Identity Data: Information such as your name; address; email address; telephone number; gender; date of birth, age and/or age range; photo/avatar; account login details (e.g., username and password); and information such as unique IDs and online identifiers.
Contact Data: Identity Data that includes personal and business contact information, such as postal address, email address, telephone number, or other identifiers used for communication.
Content: Unstructured or free-form content that you post on our Site or Platform that may include personal data (e.g., text, images, photographs, messages, comments, feedback and correspondence), such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with our Site, receive customer support or otherwise correspond with us.
Financial Data: Information such as bank account details, payment card information, and information from credit reference agencies, including similar data defined in Cal. Civ. Code § 1798.80(e).
Commercial Data: Information from transactions and purchases you make through the Site, registrations through our Site, and billing details.
Device/Network Data: Information regarding your interaction with a website, application, or advertisement (e.g., IP Address, MAC Address, SSIDs, etc.), online user ID, device characteristics (such as browser/OS version), web server logs, application logs, cookie data, web beacons, clear GIFs, pixel tags, and information about how you use our Site and interact with us.
Audio/Visual Data: Recordings such as audio files and records (e.g., voice mails, call recordings, and the like).
Professional/Biographical Data: Data relating to professional and employment history, qualifications, and similar biographic information.
Government ID Data: Information relating to official government identification, such as driver’s license or passport numbers, social security numbers, etc., including similar Identity Data included in Cal Civ Code § 1798.80(e).
How We Collect Personal Information
Information you give us
You may give us personal information when you apply for a Upekkha program, register for the Platform or otherwise submit information to use through the Services or other communications with us. For example: We may collect Identity Data, Professional/Biographical Data, and Content when you create a profile on our Site (“Profile Data”). We may collect Commercial Data, Identity Data, and Financial Data when you enter into a commercial transaction or register for an event (“Transaction Data”). We may collect Identity Data, Professional/Biographical Data, Content, Government ID, Protected Class Data, or Special Category Data when you submit an application to one of our programs (“Application Data”).
As part of our Services, we host, coordinate, and operate community events, demo days, mentor sessions, and other public or private events (“Events“) where you may engage with Upekkha founders, teams, sponsors, investors, and other community members. We may create audio or visual recordings of these events, take photographs, conduct interviews or surveys, or conduct similar activities at these Events (“Event Recordings“), and we will collect and process Audio/Visual Data incorporated into these Event Recordings.
Information from Angel List
In connection with a rolling fund that we will be operating through Angel List, UP Funds LLC, we may collect certain information regarding investors in UP Funds LLC such as the investor’s name, email ID, committed investment amount, subscription period, and other information related to the investor’s investment in UP Funds LLC.
Information from Social Networking Sites
Information we get from others
We may subscribe to databases or contract with third party data providers from which we collect personal information such as Contact Data, Professional/Biographical Data, Inference Data, and other personal data regarding individuals that may be interested in our Events and programs. We may also collect, and combine with other personal data we maintain, personal data that is publicly available, such as that provided by business networking sites and databases, information related to the organization for which you work and personal interests and skill sets, and other similar information. We also may obtain information from those in the Upekkha network such as our event organizers, contractors, and local representatives who have agreed to a relationship with us in order to deliver our Services. This may include information about potential interest in our programs, company and individual progress, interest in local events, and attendance at other similar events.
Information automatically collected
We may automatically collect personal information such as Device/Network Data when you access and use our Site. For example, we may log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site. We collect this information about you using cookies. Please refer to the Cookies and Similar Technologies section below for more details.
Changes to your personal information
It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us by updating your registration profile or emailing us at firstname.lastname@example.org.
How We Use Your Information
To provide the Services you request
If you use our Site, sign up for, or request to participate in a particular Service, we will process your personal information you give us or that we receive from relevant parties as necessary or appropriate for us to provide that Service. For example, we may process your personal information as follows: (i) we process Device/Network Data to operate, maintain, administer and improve our Site, (e.g., to show the content you request, secure the Site, and understand how users interact with the Site); (ii) we process Profile Data, Transaction Data, and Application Data to create, manage, and communicate with you regarding an account you may have on our Services, including by sending you service announcements, technical notices, updates, security alerts, and support and administrative messages; (iii) we process Profile Data, Transaction Data, and Application Data, Inference Data and other personal information to better understand your needs and interests, and personalize your experience with the Services; and (iv) we process personal information related to support and maintenance for our Services that you may request.
In connection with Marketing Communications
If you request information from us, register on our Site, or participate in our surveys, promotions or events, where allowed by law, we or our third party partners, mentors, and members of the Upekkha network may use your personal information, such as Identity Data and Contact Data, as well as Inference Data or Profile Data, to send you updates, newsletters, surveys, offers, and other promotional materials, including communications that may be targeted to you based on your personal information, as permitted by law. We also may, from time to time, contact you about a particular offering that may be of interest to you based on publicly available information, or information obtained through the Upekkha network, Events you’ve attended, or your participation in Upekkha Services. You will have the ability to opt out of such communications.
To document and promote Upekkha and our events
If we create any Event Recordings, we or our event sponsors or participants may use those Event Recordings (including any Audio/Visual Data therein) as part of our marketing and promotional activities. Further, we may also publish the Event Records, including Audio/Visual Data or related Identity Data therein, in connection with our documentation of or publicity relating to those Events, for example, on the Upekkha website or a relevant Event-specific page. We may seek your consent or a release from you in the event the nature of our processing requires such consent or release. However, in certain circumstances, we may process or publish certain video, images, etc. without your consent, such as when we publish on an Event page certain Event Recordings that include images of groups or crowds in attendance at an Event.
Cookies and Similar Technologies
What are cookies and similar technologies? We may collect personal information using “cookies“. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site. We use two broad categories of cookies: (i) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Site; and (ii) third party cookies, which are served by service providers on our Site, and can be used by such service providers to recognize your computer or mobile device when it visits other websites or online services. Pixel tags- We may also use technologies that function similarly to cookies called pixel tags (which are also known as web beacons and clear GIFs) to track the actions of users on our Site. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags can be used, for example, to measure the success of our marketing campaigns and compile statistics about usage of the Site, so that we can better understand how users interact with our Site.
Our Site may collect personal information using the following types of cookies and similar technologies and process that data for the purposes set out below:
These cookies and similar technologies are essential to provide you with services available through our Site and to enable you to use some of its features (e.g. to keep you logged in as you navigate between web pages). Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services. These cookies and similar technologies collect personal information, such as unique IDs, IP addresses, device information, OS/browser type, and other similar data, that are used to create information about traffic to our Site and how users use our Site. The information gathered may include the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information.
Analytics and Performance Cookies
We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site. For example, we use Google Analytics to improve how our Site works, so that we can understand usage patterns on the Site, and similar purposes. You can find out more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available here. To learn more about other similar technologies we use and how you can opt out, you may contact us at email@example.com.
Social Media Cookies
Retargeting Interest-based Advertising
These cookies and similar technologies are used for “retargeting” and for interest-based advertising. Interest-based advertising includes various parties and services providers, including third party data controllers, engaged in the processing of personal data in connection with personalized advertising. These parties may collect personal information such as unique IDs, IP addresses, device information, OS/browser type, and other similar data, as well as information about the ads you see and view to develop and assess aspects of a profile about you to deliver more relevant advertisements and offers, and determine whether and how ads you see are effective. These third parties may augment your profile with demographic and other preferences data derived from these observations, and may also track whether you view, interact with, or how often you have seen an ad, or whether you complete a purchase for a good or services you were shown in an advertisement. These parties may be able to identify you across sites, devices, and over time. We also use ad “retargeting” so that you can see advertisements from us on other websites. For example, we may share with Google certain personal information (such as unique user ID) in connection with advertising provided through Google’s “Customer Match” service. These technologies and the data they process may be used by advertisers to deliver ads on their services based on content you have viewed on our Sites, or that we believe you would be interested in, for example, based on Events you have attended or products/services you have purchased from us. These tracking technologies may also help prevent you from seeing the same advertisements too many times, and help us understand whether you have interacted with or viewed ads we’ve delivered to you. This collection and ad targeting takes place both on our Sites and on third-party websites (e.g. Google) that participate in the ad network, e.g. any advertisements delivered by that ad network on a third party website. To learn about the specific providers we use for these services, please contact us at firstname.lastname@example.org.
For online advertising
We may use Device/Network Data and Inference Data we collect from cookies and similar technologies in order to market certain products and services to you, such as Events you may be interested in. For example, if you attend an Event, we may use your personal data in connection with online advertising campaigns on Google, Facebook, Instagram and LinkedIn. We, or our third party advertising partners, may combine this information in order to create profiles that are used to make more relevant profiles. You can control how these third parties use your data, and the ads you see on these platforms, using the tools described in the Your Rights and Choices section below. We may use or share your personal information with your consent, such as when you: consent to participate in additional surveys on gender and race/ethnicity (where legally permissible), let us post your testimonials or endorsements on our Sites, instruct us to take a specific action with respect to your personal information, or opt into third party marketing communications. Please note, in certain cases (such as in connection with our Diversity & Inclusion efforts), we may collect and share with parties you authorize, information about race, ethnic origin, religious beliefs, physical/mental health, sexual orientation, or other personal information that is classified as a “special category” of personal data under applicable law. You may revoke your consent to this processing at any time. Additional information regarding these programs, how your personal information will be shared, and the parties that may receive it, are available within program descriptions we provided at the time you agreed to participate in the program.
For compliance, fraud prevention and safety
We use your personal information as we believe necessary or appropriate to (i) enforce the terms and conditions that govern the Service; (ii) protect our rights, privacy, safety or property, and/or that of you or others; and (iii) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
To create aggregated or de-identified information
We may disclose or use aggregated or de-identified information for any purpose, subject to limits under applicable law. For example, we may share aggregated or de-identified information with prospects, partners, or sponsors for business or research purposes, such as when we analyze and report on demographic trends to measure our objective of having healthy diversity ratios across our programs.
Generally, we do not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate in any way your personal information to third parties in exchange for monetary or other valuable consideration. Note, however, we may make any disclosure or otherwise process personal information in connection with our provision of the Services to you or at your request, and we make any of the disclosures described in the Data Sharing section below.
How We Share Your Information
Partners, Mentors and User Groups
We may disclose your personal information to our partners, mentors, and other groups with whom we have contracted to sponsor and deliver industry-focused Accelerator and Startup Programs, and to other users of our Services, for the purpose of providing our products and services, including sharing with other members of the groups for which you are registered (e.g. founders, mentors). For example, when you participate in an accelerator program, your personal information may be shared with the identified accelerator partners to organize and deliver the accelerator services. Also, when you register for an event through our Services, your personal information may be shared with the Event organizers and sponsors in order to communicate with you about the Event. Finally, you may request to join certain programs, initiatives, projects, or promotional opportunities operated by or in connection with third parties where your information will be shared with the parties you choose or that operate the relevant program.
We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
Compliance with Laws and Law Enforcement; Protection and Safety.
Upekkha may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (i) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (ii) enforce the terms and conditions that govern the Services; (iii) protect our rights, privacy, safety or property, and/or that of you or others; and (iv) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
Service Providers & Business Purposes.
We may employ third party companies and individuals to administer and provide the Services on our behalf (such as account creation, quality assurance testing, technical support, hosting, email delivery and database management services). We may also disclose your data in connection with certain other business and operational purposes, such as data security monitoring, service analytics, internal research, quality control, etc.
We generally share your personal data as you request, or in accordance with certain business purposes. When we disclose information for business purposes (e.g., where we disclose information as part of our own internal operations, such as security operations, internal research, etc.), we may disclose the following categories of information: Identity Data, Contact Data, Content, Financial Data, Professional/Biographical Data, Commercial Data, Device/Network Data, Inference Data, Audio/Visual Data, Government ID Data, Protected Class Data, and Special Category Data (each to the extent collected).
Your Rights and Choices.
Access, update, correct or delete your information.
All account holders may review, update, correct or delete the personal information in their registration profile by logging into their account. You may also contact us at email@example.com to accomplish the foregoing or if you have additional requests or questions.
You may opt out of newsletters and marketing-related emails from us by following the unsubscribe instructions on a link at the bottom of each such email, or by contacting us at firstname.lastname@example.org. You may continue to receive service-related and other non-marketing emails.
If you authorized the sharing of your contact information with a third party, contact that third party directly to opt out of receiving any communications they may send.
If you gave us consent to use your personal information, but wish to update or delete it, please contact us at email@example.com.
Choosing not to share your personal information
Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you.
If you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the Services and may need to close your account. We will tell you what information you must provide to receive the Services by designating it as required in the Services or through other appropriate means.
Cookies and similar technologies.
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org. If you do not accept our cookies or similar technologies, you may not be able to use certain features or services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site.
Do Not Track Signals
Retargeting and Behavioral Advertising
When we share your information with third parties for retargeting purposes, or for behavioral advertising, you have a right to revoke your consent (if provided) or otherwise opt-out of such services. Where a third party processes data on our behalf, (e.g. Custom Audiences, or Customer Match) you may contact us to opt-out. However, to the extent the third party processes your information for its own purposes, you should opt out with that third party directly. You can control your Facebook (and Instagram) privacy settings here, Google’s ad settings here, and LinkedIn’s privacy settings here.
The security of your personal information is important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.
Other Sites and Services
Our Site may contain links to other websites and services. These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.
User Generated Content
We may make available on our Site, or link to, features that allow you to share information online (e.g., on message boards, in chat areas, in file uploads, through events, etc.). Please be aware that whenever you voluntarily disclose personal information online, that information becomes public and can be collected and used by others. We have no control over, and take no responsibility for, the use, storage or dissemination of such publicly-disclosed personal information. By posting personal information online in public forums, you may receive unsolicited messages from other parties.
We will only retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances, we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
Our Products and Services are not directed to children under the age of 13, and we do not intentionally gather personal information from visitors who are under the age of 13, without their parental or guardian’s consent. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at the contact information provided below. We will delete such information from our files as soon as reasonably practicable.
Information for California Residents
Your California privacy rights
If you are a California resident, you have the following rights:
Information. To request that we disclose the following information about our collection and use of your personal information during the past 12 months: The categories of personal information that we have collected about you; The categories of sources from which personal information is collected; The business or commercial purpose for collecting or selling personal information; The categories of third parties with whom we share your personal information; Whether we have disclosed your personal information for a business purpose, and if so, the categories of personal information received by each category of recipient; and Whether we have sold your personal information, and, if so, the categories of personal information received by each category of recipients.
To request a copy of the personal information that we have collected about you during the past 12 months. Deletion. To request that we delete personal information about you that we have collected from you. Non-Discrimination. You have the right not to be discriminated against with respect to the quality or level of services we provide as a consequence of your exercise of your rights under CCPA.
You can request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the preceding calendar year. This request is free and may be made once a year. Exercising your California privacy rights. To request access to or deletion of your personal information, or to exercise any other data rights under California law, please contact us using one of the following methods:
Email: firstname.lastname@example.org We will request that you provide information necessary to verify your identity. That information may vary based on the context and scope of your request. For example, we may require you to verify access to an email address, or provide other forms of identification appropriate to the request. We may require agents submitting a request on your behalf to provide proof of agency in order to respond to a request.
Response Timing and Format
We aim to respond to requests for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.