Privacy Policy

At UPT Media, or our traffic subsidiaries, including ClickToRing, SquareVid, TheTrafficBoss or UptownTraction, (“UPT Media,” “we,” “us,” or “our”), we provide online advertising services. We conduct ourselves in a manner that protects user privacy and personalizes web experiences to provide significant benefits to Internet end users. In accordance with these beliefs, UPT Media creates results for advertisers and publishers in revolutionary ways without compromising individual privacy.  We have created this Privacy Policy in order to demonstrate our commitment to privacy as it pertains to SERVICES, COMPANY WEBSITE, ADVERTISERS and PUBLISHERS.

I.  SERVICES
This Privacy Policy describes how UPT Media collects, uses, shares and secures personal information through our services.  This Privacy Policy describes UPT Media’s data practices associated with our services (“Services”) and explains how UPT Media may collect, use, and disclose information when you access any our websites, apps or services.

A.  OUR SERVICES
Services include our bidding system, which is a web-based marketplace that enables publishers, advertisers, and ad networks to efficiently market, buy and sell digital and mobile advertising and ad inventory.  Publishers and other clients that utilize the bidding system may also have their own policies that govern how they collect, use and share data. These policies may differ from UPT Media policies described in this Privacy Policy. Please consult the privacy policies of the websites and apps that you visit to become familiar with their privacy practices and to learn about any choices that these companies may offer with respect to their information practices.

B.  DATA COLLECTION AND USE
UPT Media DOES NOT COLLECT ANY IDENTIFYING INFORMATION such as your name or address.

Instead we collect the following information:

  • Browser information (e.g. URL, browser type, ‘click through’ data)
  • Ad reporting or delivery data (e.g. size/type of ad, ad impressions, location/format of ad, data about interactions with the ad)
  • Device-type information (e.g. screen dimensions, device brand and model)
  • Unique identification numbers (e.g. IP address and mobile/cell phone device ID)
  • Location data (as derived from IP address or GPS (for mobile))
  • Interest segments (i.e. inferred information on the behavior or likely interests associated with a device or your search query)
  • Information about your activities on our website and services

With respect to data collected, we may combine information that does not directly identify an individual with data collected from other sources and disclose the combined information to participating publishers, advertisers and ad networks so that they can determine whether to bid on ad inventory and in order to improve the relevance of the advertising presented to users. We also use the information we collect to host, operate, maintain, secure, and further develop and improve our Services, such as to keep track of advertising delivery and to measure the effectiveness of advertising delivered through our services, and investigate compliance with our policies and terms and conditions.

1. Cookies and Other Similar Technologies
UPT Media uses cookies (a small file containing a string of characters that uniquely identifies your web browser), web beacons (an electronic file placed within a website that monitors usage), pixels, etags, and similar technologies to operate and improve our services.

We use the following categories of cookies for our Services.

  • Necessary Cookies
    These cookies are essential in order to enable you to navigate our Services and use its features.
  • Performance Cookies
    These cookies collect anonymous information on how people use our Service. We use these cookies to help us highlight areas where we can improve marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established.
  • Functionality Cookies
    These cookies remember choices you make such as the country from which you visit our website, language and search parameters such as size, color or product line. These cookies can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and relevant. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.
  • Marketing or Advertising Cookies
    These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The cookies remember the websites you visit and that information is shared with other parties such as advertisers.
  • Third Party Cookies
    Publishers, advertisers and ad networks that use the Services may also utilize cookies or similar technologies to deliver ads and monitor the performance of such ads. The collection of information through cookies or similar technologies by such third parties will be governed by their own privacy policies and principles, which UPT Media does not control.
  • Disabling/Enabling cookies via your browser
    There are a number of ways for you to manage cookies and other tracking technologies. Through your browser settings, you can accept or decline cookies or set your browser to prompt you before accepting a cookie from the websites you visit. You should be aware that you may not be able to use all our interactive features if you set your browser to disable cookies entirely.  If you use different computers in different locations you will need to ensure that each browser is adjusted to suit your preferences.

You can delete any cookies that have been installed in the cookie folder of your browser. The various browsers provide different procedures to manage your settings.

Click on any of the browser links below for specific instructions on deleting cookies.

If you are not using any of the above-listed browsers, then you should select “cookies” in the “Help” function for information on where to find your cookie folder. It may not be possible for you to selectively opt out of all third-party advertising cookies placed on our website. You should also be aware that disabling cookies does not disable other types of analytics products which we may use to collect generic information about how you and other visitors use our website.

2. Do Not Track Signals
We do not respond to the “Do Not Track” signal that may be activated on your browser. There is no uniform or consistent standard or definition for responding to, processing or communicating Do Not Track signals.

3. Information Sharing
We will disclose the information we collect to third parties as follows:

  • with your express permission;
  • with our affiliates, which include entities controlling, controlled by, or under common control with UPT Media;
  • where we contract with 3rd parties to provide certain services, such as advertising, analytics, data management services, web hosting and web development. We ask these providers to confirm that their privacy and security practices are consistent with ours, we provide these providers with only the information necessary for them to perform the services we request and Service Providers are prohibited from using such information for purposes other than as specified;
  • in the event that UPT Media is merged, sold, or in the event of a transfer of some or all of our assets (including in bankruptcy), or in the event of another corporate change, we may disclose or transfer information in connection with such transaction; and
  • where we believe it is necessary to protect UPT Media or our users; to enforce our terms or the legal rights of UPT Media or others; or to comply with a request from governmental authorities, legal process, or other legal obligations.

We may also share and disclose other information that we collect, including aggregate information, as we consider necessary to develop and provide our Services.  UPT Media may also be required to disclose information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

4. Security Measures
We have reasonable security measures in place and technologies to protect the loss, misuse and alteration of your information under our control but we cannot assure that your personally identifiable information or non-personally identifiable information will never be disclosed in a manner that is inconsistent with this Privacy Policy.

5. Reviewing and Updating Information
UPT Media takes reasonable steps to ensure that information is accurate, complete, current, and reliable for its intended use. For contact or billing information submitted through our website, you may review, correct, update, or change your information, request that we deactivate your account, or remove your information from our direct marketing efforts, at any time by emailing us at tobin [at] uptmedia.com.

C.  RETENTION
We retain the technical data that we collect for up to 18 months from the date of collection.

D.  CONTACT
If you have any questions about this Privacy Policy, the practices of the UPT Media or your dealings with the UPT Media, you can contact us by e-mail at tobin [at] uptmedia.com.

Or as follows:
UPT Media
ATTN: DPO
PO Box 3774
Redondo Beach, CA 90277

UPT Media does not engage in activities that require parental notice or consent under the Children’s Online Privacy Protection Act (COPPA). If you believe that UPT Media has inadvertently collected information from a child under 13 that is subject to parental notice and consent under COPPA, please contact UPT Media using the contact information above to request deletion of the information.

II.  COMPANY WEBSITE
As the owners (“Company” or “we”) of www.UPTmedia.com (the “Web Site”), we have created this Privacy Policy in order to demonstrate our commitment to the privacy of our customers and users. This Privacy Policy is only applicable to the Web Site, and not any other websites that are accessible from the Web Site, each of which may have data collection, storage, and use practices and policies that differ materially from this Privacy Policy. We are not responsible for the privacy practices of such web sites.

1.  The Information We Collect
In order for you to access certain services that we offer via the Web Site, we require you to provide us with certain information that personally identifies you which includes contact information such as your name, mailing address, telephone number and email address and financial data such as your credit card number and social security number and/or tax identification number. We may also collect certain non-personally identifiable information from you when you visit the Web Site such as your IP address; web request; domain server; type of web browser you used to access the Web Site; and your approximate geographic location.

2.  How We Use the Information
We use your contact information that you provide to contact you when necessary. We use the financial data that you provide to verify your qualifications for certain services and to bill you for services. We do not rent, sell or share any personal information about you with other people or nonaffiliated companies except to provide the services you’ve requested. We sometimes use the non-personally identifiable information that we collect to enable us to personalize your experience with our Web Site. We also may use this information in the aggregate to analyze our Web Site usage and/or provide this information to third parties for the same purpose, as well as to offer you products or services. On occasion we may share your non-personally identifiable information that we collect and personal information that you provide to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Company’s Terms and Conditions, in order to diagnose a problem with our server, to administer our Web Site or as we otherwise deem necessary in our sole and absolute discretion. We will transfer information about you if the Company is acquired by or merged with another company and this may occur with or without notice to you. Also, we will provide your personal information to respond to subpoenas, court orders, or legal process or to establish or exercise our legal rights or defend against legal claims.

We provide our customers with unique usernames and passwords for use with our services. We use this information for security purposes and to prevent unauthorized use, access, alteration or misuse of your accounts and services.

4.  Security Measures
We have reasonable security measures in place and technologies to protect the loss, misuse and alteration of your information under our control but we cannot assure that your personally identifiable information or non-personally identifiable information will never be disclosed in a manner that is inconsistent with this Privacy Policy.

To Change and/or Modify Information.  We allow our customers to change and modify personal information previously provided by e-mailing us at tobin [at] uptmedia.com.
Or as follows:
UPT Media
Attn: DPO
PO Box 3774
Redondo Beach, CA 90277

UPTmedia.com does not engage in activities that require parental notice or consent under the Children’s Online Privacy Protection Act (COPPA). If you believe that UPTmedia.com has inadvertently collected information from a child under 13 that is subject to parental notice and consent under COPPA, please contact UPTmedia.com using the contact information above to request deletion of the information.

5.  Cookies
To enhance the performance of certain services within our Web Site we use cookies. Cookies, by themselves, do not tell us your personally identifiable information. However, once you choose to furnish the Web Site with personally identifiable information, this information may be linked to the data stored in the cookie. We use cookies to understand site usage and to improve the offerings on our Web Site. Cookies placed on your computer by third parties by or through the Web Site, if any, are not the responsibility of the Company and are not subject to this Privacy Policy. Please contact the third party placing these cookies to find out what information is collected and how it is used. You can usually edit your browser not to accept cookies, but the features of our Web Site may not function properly if you do accept cookies.

6.  Contact
If you have any questions about this Privacy Policy, the practices of the Web Site or your dealings with the Web Site, you can contact us by e-mail at tobin [at] UPTmedia.com.
Or as follows:
UPT Media
Attn: DPO
PO Box 3774
Redondo Beach, CA 90277

The Company may update this Privacy Policy from time to time. We may notify you about significant changes in the way we treat your information by sending a notice to you, although we are not required to do so, or we may simply place a notice on the Web Site. Notwithstanding the foregoing, we reserve the right to change this Privacy Policy without any notice whatsoever to you and for whatever reason we deem appropriate under the circumstances. We encourage you to periodically check back and review this Privacy Policy so that you always will know what information we collect, how we use it, and to whom we disclose it.

III. ADVERTISERS
This Privacy Notice relates to data held by UPT Media about Advertiser, and includes:
1.  What data is collected and processed and how is it collected
2.  The purpose for collecting the data and the lawful basis
3.  How long we keep the data
4.  How to review and update information

1. Data that’s collected and processed and how its collected:
We collect the following data about Advertiser:
-Company name
-Company contact details
-Contact details of individual contacts within the Company
-Finance details necessary for transacting with the Company
-Details about inventory
-History of interactions between the Company and UPT Media
-This data is given by Advertiser when the Parties enter into a contract and may also be given prior to entering into an agreement.

2. The purpose for collecting the data and the lawful basis:
This data is collected to enable UPT Media to execute the contract between the Parties and to maintain accounting records as required by law.  As per Article 6 of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the lawful basis “legal” and “contract” apply.

UPT Media will use your contact details for service announcements and these communications are covered by the legal basis “contract”.

3. How long we keep the data:
Your data will be kept for the duration of the Agreement, and as required by law for accounting and legal record keeping purposes.

4. How to review and update information:
To review or update the information held, please use the contact details in the UPT Media Privacy Policy on the UPT Media website.

IV. PUBLISHERS
This Privacy Notice relates to data held by UPT Media about Company, and includes:
1.  What data is collected and processed and how is it collected
2.  The purpose for collecting the data and the lawful basis
3.  How long we keep the data
4.  How to review and update information

1.  Data collected and processed and how its collected:
We collect the following data about Company:
-Company name
-Company contact details
-Contact details of individual contacts within the Company
-Finance details necessary for transacting with the Company
-Details about inventory
-History of interactions between the Company and UPT Media

This data is given by Company when the Parties enter into a contract and may also be given prior to entering into an agreement.

2. The purpose for collecting the data and the lawful basis:
This data is collected to enable UPT Media to execute the contract between the Parties and to maintain accounting records as required by law.  As per Article 6 of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the lawful basis “legal” and “contract” apply.

UPT Media will use your contact details for service announcements and these communications are covered by the legal basis “contract”.

3. How long we keep the data:
Your data will be kept for the duration of the Agreement, and as required by law for accounting and legal record keeping purposes.

4. How to review and update information:
To review or update the information held, please use the contact details in the UPT Media Privacy Policy on the UPT Media website.

V.  SUMMARY
The Company may update this Privacy Policy from time to time. We may notify you about significant changes in the way we treat your information by sending a notice to you, although we are not required to do so.

Notwithstanding the foregoing, we reserve the right to change this Privacy Policy without any notice whatsoever to you and for whatever reason we deem appropriate under the circumstances. We encourage you to periodically check back and review this Privacy Policy so that you always will know what information we collect, how we use it, and to whom we disclose it.

This Privacy Policy was last updated on: May 25, 2018.