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.

• Microsoft Windows Explorer
• Google Chrome
• Mozilla Firefox
• Apple Safari

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
220 S. Helberta Ave. #D
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
220 S. Helberta Ave. #D
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
220 S. Helberta Ave. #D
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. California Privacy Rights
This section is provided pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”) and other applicable California privacy laws. This section applies solely to our users who are California residents as defined under applicable California privacy laws.

Information We Collect
Within the last twelve (12) months, we have or may have collected the following categories of information from our users and/or consumers:

1. identifiers, such as a name, alias, unique personal identifier, online identifier, IP address, email address, or other similar identifiers;
2. personal information listed under Cal. Civ. Code § 1798.80(e);
3. characteristics of protected classifications under California or federal law;
4. commercial information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
5. biometric information;
6. internet or other similar network activity, such as browsing history, search history, information regarding your interaction with a website, application, or advertisement;
7. geolocation data;
8. professional or employment-related information; and
9. inferences drawn from any of the information identified in this section to create a profile about users reflecting user preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Categories of Sources from Which Information is Collected
We obtain the categories of personal information listed above from the following categories of sources:

10. directly from users, such as you, as described above under “Personal Information that You Provide to Us”;
11. indirectly from other users of our sites and services;
12. indirectly from third-parties that interact with us in connection with the services that we perform; and
13. directly and indirectly through cookies and other technologies, as described above under “Other Information We Automatically Collect through Cookies and Other Technologies.”

Using and Sharing of Personal Information
The personal information described in the categories above may be used for the business purposes listed above under “How We Use Personal Information.”

We disclose your personal information for a business purpose to the following categories of third parties: (a) service providers and (b) third parties to whom you authorize or direct us to disclose your personal information in connection with our sites and services. In the preceding twelve (12) months, we have disclosed the personal information described in the categories above for the business purposes listed above under “Sharing Personal and Non-Personal Information.” We also may share personal information about you for any other purpose(s) disclosed to you at the time we collect your information or with your consent.

Personal Information “Sold” to Third Parties
We may share information that we have about you, such as a cookie ID or IP address, with third-party marketing partners who may use this information, on our behalf, to help us deliver advertising on our sites as well as on third-party websites.

In the preceding twelve (12) months, we have made available personal information included in the categories described above to third-parties, including our third-party marketing partners to deliver advertising.

We do not sell the personal information of consumers that we know are minors under 16 years of age without affirmative authorization as required under the CCPA.

Your Access and Deletion Rights under the CCPA
As of January 1, 2020, California residents, as defined under applicable California privacy laws, may take advantage of the following rights:

14. You may request, up to two (2) times each year, that we disclose to you, once we receive and confirm your verifiable consumer request, the: (i) categories and specific pieces of personal information that we have collected about you; (ii) categories of sources from which your personal information is collected; (iii) business or commercial purpose for collecting your personal information; (iv) categories of personal information that we disclosed for a business purpose; (v) categories of personal information that we sold about you; (vi) categories of third-parties with whom we have shared your personal information; and (vii) business or commercial purpose for selling your personal information.
15. Subject to certain exceptions and up to two (2) times each year, you may request that we delete any of your personal information that we collected from you. Once we receive and confirmed your verifiable consumer request for deletion, we will delete (and direct our service providers to delete) such personal information from our records, unless an exception applies.

Exercising Your Access and Deletion Rights under the CCPA
To exercise the access and deletion rights described above, please submit a request to us by either:

16. sending an email to privacy@uptmedia.com; or
17. clicking here

You will be asked to provide certain identifying information, such as your name, email, and residency. You will also be asked to validate your request by clicking a validation link in an email that will be sent to the email address you provided. While processing your request, we may ask you to provide further verifying documentation, such as proof of residency and identity. We will only use personal information provided in a request to verify the requestor’s identity or authority to make the request.

Your request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or that you have authority to make the request; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide proof of written authorization to do so, and you must verify your identity directly with us, unless such authorized agent provides proof of a power of attorney pursuant to Probate Code sections 4000 to 4465.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Opting-out of the Sales of your Personal Information
Subject to certain exclusions under the CCPA, you have the right to opt-out of the sale of your personal information. Once we receive your request, we will not sell your personal information, unless an exclusion applies.

To opt-out of the sale of your personal information that we collect through cookies and other technologies.

To opt-out of the sale of your personal information that we collected directly from you or other third-parties, please submit a request to us by either:

18. sending an email to privacy@uptmedia.com; or
19. clicking here.

We may deny your request to opt-out if we have a good-faith, reasonable, and documented belief that the request is fraudulent.

Non-Discrimination
We will not discriminate against you for exercising any of your rights under the CCPA. Accordingly, and unless permitted by the CCPA, we will not:

20. deny you goods or services;
21. charge you different prices or rates for goods or services, including through the use of discounts or by imposing penalties;
22. provide you a different level or quality of goods or services; or
23. suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

We may charge a different price or rate or provide a different level of service if the difference is reasonably related to the value provided by your personal information.

Other Applicable California Privacy Laws
Section 1798.83 of the California Civil Code requires select businesses to disclose policies relating to the sharing of certain categories of your personal information with third parties. If you reside in California and you have provided us with your personal information, you may request information about our disclosures of certain categories of your personal information to third parties for direct marketing purposes. To make such a request, please fill out our Privacy Contact Form with “California Privacy Rights” in the subject line and allow 30 days for a response. We will not accept requests via the telephone, mail, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

In accordance with Section 22581 of the California Business and Professions Code if you are a California resident under the age of 18, you may request and obtain the removal of content or information you have publicly posted. To make such a request, please fill out our Privacy Contact Form with “California Privacy Rights” in the subject line. Please specify the site(s) or service(s) to which your removal request relates, including any URLs where the content or information is posted, and the specific content or information you posted for which you are requesting removal. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

VI. Nevada Privacy Rights
FOR RESIDENTS OF NEVADA ONLY. In accordance with SB 220, Nevada consumers may opt-out of the sale of their personal information to third parties. If you reside in Nevada and you have provided us with your personal information, you may choose to opt-out of the sale of such personal information by filling out our Privacy Contact Form or by emailing us at privacy@uptmedia.com with “Nevada Privacy Right” in the subject line. We may request for additional information from you in order to verify your identity and/or the authenticity of your request.

VII. EU Privacy Rights
FOR RESIDENTS OF THE EUROPEAN UNION ONLY. Under European data protection law, in certain circumstances, you have the right to:

24. request access to your personal information;
25. request correction of your personal information;
26. request erasure of your personal information;
27. object to processing of your personal information;
28. request restriction of processing your personal information;
29. request transfer of your personal information; and
30. withdraw your consent.

In addition, you have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting your personal information) if we intend to use your personal information for such purposes or if we intend to disclose your information to any third party for such purposes.

You can exercise any of these rights by filling out our Privacy Contact Form or sending an email to privacy@uptmedia.com with “EU Privacy Rights” in the subject line. If you believe that we have not complied with its obligations under this Privacy Policy or European law, you have the right to make a complaint to an EU Data Protection Authority.

VII.  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: February 20, 2020.