Upright Data, Inc.

Privacy Policy

(last updated June 1, 2022)

Upright Data, Inc. (“Upright Data”, “we”, or “us”) respects your privacy and is committed to communicating transparently regarding our privacy practices. This Privacy Policy describes the types of information we may collect from you when you visit our couponing platform, known as “Giving Assistant”, through our website at https://givingassistant.org/ and its subdomains, or when you visit or use any of our related mobile or desktop applications, including any content or functionality offered on or through any of the foregoing (collectively, the “Site”), or when you access or use the online services we make available on the Site (collectively, the “Service”). This Privacy Policy also describes our practices for collecting, using, maintaining, protecting, and disclosing such information.

This Privacy Policy applies to information we collect on the Site, in email, text, or other electronic messages between you and the Site, and through your access to or use of the Service through the Site. Except as otherwise expressly set forth herein, it does not apply to information collected by us offline or through any other means, including on any other website operated by us or any third party, nor to information collected by any other third party, including through any application or content (including advertising) that may link to or be accessible from or on the Site or the Service.

Please read this Privacy Policy carefully before you start to use the Site or the Service to understand our policies and practices regarding how we treat your information. By accessing or using the Site or the Service in any manner, you accept and agree to be bound by this Privacy Policy. If you do not agree with any terms of this Privacy Policy, you may not access or use the Site or the Service for any purpose.

This Privacy Policy may change from time to time (see Updates to Our Privacy Policy, below). Your continued use of the Site or the Service after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Privacy of Children

The Site and the Service are not intended for or directed to children. No one under age 16 may provide any information to or on the Site or the Service. We do not knowingly collect or solicit personal information from children under age 16. If you are younger than 16 years of age, do not use or provide any information on the Site or through the Service or any of its features, register on, make any purchases through, or use any interactive, messaging, or public comment features of the Site or the Service, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under age 16, we will delete that information. If you believe we might have any information from a child younger than 16 years of age, please contact us at [email protected].

Information We Collect

When you access the Site or use the Service, we collect certain information about you. This may include information by which you may be personally identified, such as name, geographic location, and e-mail address, as well as information that is about you but may not specifically identify you, such as information about your internet connection, the equipment you use to access the Site or the Service, and usage details, IP addresses, and certain other information collected through cookies and other tracking technologies (collectively " personal information").

Information You Provide Us

We collect personal information from various sources, such as directly from you when you access or use the Site or the Service. This may include:

• where you elect to provide it in connection with the Data Participation Network (as defined below), Opt-in Data (as defined below) that you submit to Upright Data, including, without limitation, your email address and your responses to marketing questions posed to you by Upright Data.
• information that you provide when you enter a contest or promotion sponsored by us, or when you report a problem with the Site or the Service.
• records and copies of your correspondence (including email addresses), if you contact us.
• your responses to surveys that we might ask you to complete for research purposes.
• your search queries on the Site.

Information We Collect by Automatic Means

When you navigate through and interact with the Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing, actions, and patterns, including:

• information about the devices you use to access the Site (such as the IP address and the type of the device, operating system, and web browser);
• dates, times, and duration of use of the Site (including whether you are a repeat or first time visitor);
• information on actions taken when using the Service (such as page views and website navigation patterns, including coupons and/or retailer pages you may access or link to through the Site or the Service);
• certain geolocational information.

In addition, we use third-party web analytics services to help us understand your use of the Site and the popularity of certain content so we can improve your experience. For more information on our use of third-party analytics services, see Third Party Providers below.

Information we collect automatically may be statistical data that does not include personal information. We may maintain or associate any such statistical data with personal information we collect in other ways or receive from third parties. It helps us to estimate our audience size and usage patterns, speed up user experience, and to improve and personalize the Service, including enabling us to identify and authenticate users. To the extent that we associate any of this non-personal information with your personal information, we will treat it as personal information under the terms of this Privacy Policy.

Technologies we use for automatic data collection may include cookies. A cookie is a small file placed on the hard drive of your computer. Pages of our Site and our emails may also contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Information We Collect Through Service Participants

In connection with the Service, Upright Data may link or otherwise display on the Site coupons or other deals offered by participating retailers (“ Brands”). When you use these coupons or other deals (“Coupons”) to make a purchase from a Brand, we collect certain information from the applicable Brand with respect to that purchase transaction (“Transaction Information”). This Transaction Information is necessary to allow us to track and collect amounts owed to us by the applicable Brands in connection with our operation of the Site and the Service. By using any Coupon linked or posted to the Site to make a purchase from any Brand, you consent to Upright Data’s collection and use of all related Transaction Information for the purposes set forth in this paragraph. If you do not want us to collect this Transaction Information, please do not use any Coupons linked or posted to the Site. For more information, see Your Choices, below.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Site are served by third-parties, including content and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about any targeted content, you should contact the responsible provider directly.

How We Use the Information We Collect

We may use information we obtain about you, or that you provide to us:

• to provide you with our services;
• to send you information or materials you request;
• to track and maintain a record of your Transaction Information for purposes of tracking and collecting amounts owed to us by applicable Brands;
• to respond to your questions and comments and to provide customer support;
• to communicate with you about the Service or our offers and promotions;
• to operate, evaluate, and improve our business and the products and services we offer;
• to analyze trends and statistics regarding use of the Service and transactions conducted using the Service;
• to protect against and prevent fraud, unauthorized transactions, claims, and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users;
• to enforce our Terms of Service and other agreements;
• to comply with applicable legal requirements and industry standards; and
• for any other purpose for which you provide your consent. 

We may also use certain of your information in connection with our Data Participation Network, including to display targeted advertisements to you on behalf of our data and advertising service users. Where you have opted-in in the manner more specifically detailed in our Terms of Service, we may also contact you via email regarding the goods and services of our data and marketing service users in which you may be interested. For more information, see Data Participation Network, below.

How We Share Your Personal Information

We may disclose aggregated information about our users, and information that does not identify any individual user, without restriction. 

We may disclose personal information that we collect or you provide (as described in this Privacy Policy):

• to our subsidiaries and affiliates;
• to contractors, service providers, and other third parties we use to support our business (see Third Party Providers, below);
• to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• to enforce or apply our Terms of Service and other agreements;
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Upright Data, users of the Site or the Service, and/or others;
• for any other purpose which is incidental to the normal use of the Service; and
• for any other purpose for which you provide your consent.

We also reserve the right to transfer your personal and other information to a buyer or other transferee in the event of a merger, divestiture, restructuring, reorganization, dissolution, sale, or other transfer of some or all of our assets.  Should such a sale, merger, or transfer occur, we will use reasonable efforts to direct the transferee to use your information in a manner that is consistent with our Privacy Policy.

Data Participation Network

In connection with Upright Data’s operation of its various websites and online services, including, without limitation, the Site and Service (collectively, the “Upright Network Sites”), Upright Data has developed a data sharing program that allows visitors to Upright Network Sites to leverage their data to increase the relevance and applicability of content made available to them by Upright Data, both on its own behalf and on behalf of third party users of Upright Data’s data and marketing service (collectively, the “Data Participation Network”), as detailed more specifically in our Terms of Service. By accessing or using the Site or the Service, you consent to your participation in the Data Participation Network, including your provision of Participant Data (as defined below).

Data used in the Data Participation Network

As discussed above, we collect Transaction Information any time you use a Coupon to make a purchase from a Brand. We may combine this Transaction Information with other information we collect with respect to your use of the Site and Service, such as which coupons you view or access through the Site (collectively, with Transaction Information, “Service Data”). Service Data is collected any time you access or use the Site or the Service, and by accessing or using the Site or the Service, you expressly consent to our collection and use of your Service Data, as detailed herein. If you do not want us to collect this Service Data, please do not access or use the Site or Service in any manner (including, without limitation, by using any Coupons linked or posted to the Site).

Additionally, you may elect to provide additional personal information to Upright Data in exchange for enhanced discounts (as detailed more specifically in our Terms of Service), which information may include: (i) your email address; (ii) your responses to marketing questions posed to you by Upright Data; and/or (iii) such other information as Upright Data may specifically request from you at the time you are offered the enhanced discount (collectively, “Opt-in Data” and, together with Service Data, “Participant Data”). Any submission of Opt-in Data by you is voluntary and is made at your discretion. If you choose not to provide Opt-in Data, you will still be able to access the Site and the Service, and use Coupons posted or linked to the Site, however you will not be entitled to receive, and will not have access to, any enhanced discounts.

Use of Participant Data

Participant Data may be combined with other of your personal information collected through other Upright Network Sites (where you have consented to collection of your personal information by those websites), and may be used and transmitted by Upright Data across and in support of the Data Participation Network, including in connection with our operation of our external data and marketing service. More specifically, we may collect, examine, manipulate, aggregate, analyze, create analysis using, reproduce and otherwise use your Participant Data to identify trends and insights with respect to your purchasing behaviors and preferences, which we may use to display targeted advertisements to you on behalf of those data and marketing service users and to otherwise help tailor our Coupon offerings and advertisements to your needs and preferences and to those of our other Service users. If you have elected to provide Opt-in Data to us, we may also use your Participant Data and the trends and insights identified through our analysis thereof to contact you via email regarding the goods and services of our data and marketing service users in which you may be interested. **Please note that Upright Data does not sell any personal information, even under the broad CCPA definition of a “sale.” **We do not distribute your Participant Data directly to users of our data and marketing services; rather, Participant Data (and any trends and insights we identify from your Participant Data) will only be available to users of our data and marketing services on an aggregated basis that does not identify any particular data subject, and only for purposes of allowing such users to select and utilize our data and marketing services.

If you have previously elected to provide Upright Data with Opt-in Data but no longer wish to permit Upright Data to contact you via email regarding the goods and services of our data and marketing service users, please see **Your Choices, **below, for more information on how to opt out of receiving further emails.

Third Party Providers

In addition to the permitted disclosures of personal information set forth in the foregoing Sections, we may also disclose your personal information to third party companies and individuals employed by us to facilitate our Site and to process data, perform Site-related services, or to assist us in providing the Service or analyzing how the Service is used (collectively, “Third Party Providers”). These Third Party Providers may have access to your personal information for purposes of performing these tasks on our behalf, and may have the right to retain and use personal information or other information obtained through performance of these tasks on an aggregated and de-identified basis in accordance with the terms of the applicable Third Party Provider’s privacy policy. We advise you to review the privacy policies of the Third Party Providers, but note that we have no control over and assume no responsibility for the content, privacy policies or practices of any Third Party Providers, their sites or services.

Third Party Providers may include, but are not limited to, the following:

• Google Analytics. Google Analytics is an independent web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Site. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can learn about Google’s privacy practices at https://www.google.com/intl/en/policies/privacy. You may opt out of the aggregation and analysis of data collected about you on our Site by Google Analytics by downloading the Google Analytics opt-out browser add-on, available athttps://tools.google.com/dlpage/. Please note that if you opt out, analytics companies other than Google Analytics may continue to aggregate and analyze data collected about you on the Site.
• Hotjar. Hotjar may be used to track, capture, and analyze how users interact with the Site. You can learn about Hotjar’s privacy practices at https://www.hotjar.com/legal/policies/privacy/.
• Segment. We may use Segment to collect and manage data relating to platform users. You can learn more about Segment’s privacy practices at https://segment.com/legal/privacy/.
• Kevel. We may use Kevel to develop and maintain functions of the Site and Service. You can learn more about Kevel’s privacy practices at https://dev.kevel.co/docs/privacy-policy-customers.

Security

Upright Data takes protecting your information seriously, and implements reasonable measures to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.  However, the safety and security of your information also depends on you.

Please note that the electronic transmission of information is not completely secure. We cannot guarantee that the security measures we have in place to safeguard information will never be defeated or fail, or that such measures will always be sufficient or effective. Any transmission of information is at your own risk.

Information and Data Transfers

The Service is administered by Upright Data in the United States. When we obtain information about you through your access to or use of the Site or the Service or when you input or import information to the Service (including, without limitation, to the Data Participation Network) from somewhere other than the United States, we may transfer, process, and store such information in the United States. If you access the Site and/or the Service from outside the United States, you do so on your own initiative, at your sole risk, and you are responsible for compliance with all applicable laws. If you are a non-United States resident and provide us with your personal information, or if you use the Service, you consent to the transfer to and processing of such information in the United States, which may have data protection laws less stringent than those in the country in which you reside.

Your Choices

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Cookies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Site and the Service may then be inaccessible or not function properly.

_Transaction Information. _As noted above, Upright Data’s collection and use of Transaction Information is necessary for Upright Data’s operation of the Service (see Information We Collect Through Service Participants). Accordingly, if you do not want us to collect and use Transaction Information in the manner described in this Privacy Policy, please do not use any Coupons linked or posted to the Site.

Service Data. Similarly, and as discussed more specifically in our Terms of Service, our collection and use of Service Data is critical to our operation of the Service and allows us to provide value to our users—namely by enabling us to determine the popularity of Service content and to more accurately tailor our Coupon offerings and advertisements to the needs of our user base. Accordingly, if you do not want us to collect and use Service Data in the manner described in this Privacy Policy, please do not access or use the Site or Service in any manner (including, without limitation, by using any Coupons linked or posted to the Site).

Opt-in Data. If you have previously elected to provide Upright Data with Opt-in Data but no longer wish to permit Upright Data to contact you via email regarding the goods and services of our data and marketing service users, you may opt-out from receiving further emails by contacting us at [email protected].

Emails. In addition to emails that may be sent to you if you elect to provide Opt-in Data, Upright Data may send Service updates, Service notifications, promotional information and other communications to you via email. Promotional email communications will contain instructions describing how you can opt out of receiving future promotional emails from us. If you opt out of promotional emails, you may continue to receive non-promotional, transactional emails from us.

Limiting Provided Information. You can choose not to provide us with certain information. If you decline to provide certain information, however, please note that some features of the Site and/or Service may then be inaccessible.

Please note that, when you submit any opt-out request to Upright Data pursuant to this Section, it will take Upright Data a reasonable period of time to process and implement your request.

“Do Not Track” Request

We adhere to the standards set out in this Privacy Policy and do not monitor or respond to Do Not Track browser requests.

Third Party Applications and Websites

The Site and/or Service may contain links enabling the electronic transfer of data from third-party applications to the Site or the Service, as well as links to third-party websites (including, without limitation, those of participating Brands). Upright Data is not responsible for the privacy practices or content of these applications or websites, and linking to an application or website does not constitute endorsement by us of that application or website. You should review the privacy policy and terms and conditions of any such third-party application or website prior to using or providing information to the same.

Accessing and Correcting Your Information

You may send us an email at [email protected] to request access to, correct, or delete any personal information that you have provided to us, including, without limitation, Opt-in Data. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Your California Privacy Rights

California law grants additional privacy rights to California residents. In particular, the California Consumer Privacy Act (CCPA) requires businesses to disclose, for the past 12 months, (i) the categories of personal information collected, (ii) the sources of the collected personal information, (iii) the purposes for which the collected personal information is used, (iv) the categories of personal information disclosed for a business purpose, and (v) the categories of any personal information sold. Upright Data provides these disclosures in the following table. (Note that Upright Data does not sell any personal information, even under the broad CCPA definition of a “sale.”)

California residents also have the rights described below. We will not discriminate against any California resident who exercises these rights.

Right to access/know your information. You may request from us a list of (i) the personal information that we have collected about you, and (ii) the categories of third parties to whom we have disclosed your personal information. You have the right to up to two (2) access requests each twelve (12) months.

Right to delete your information. You may request, at any time, that we delete your information and direct our service providers to delete your information from their records.

You may contact us to exercise these rights at [email protected]. To ensure the privacy and protection of individuals, we are required to verify your identity (or that of your authorized agent) or otherwise authenticate your request(s), which we will do in accordance with the CCPA regulations. Please note that, under the CCPA, we are not required to grant a request to access/know or a request to delete with respect to personal information obtained from you in your role as an employee, owner, director, officer or contractor of a company and within the context of Upright Data providing its services to such company.

Your European and UK Privacy Rights

If you are a resident of the European Union or the UK, you are entitled to certain information and have certain rights under the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”) or the UK GDPR adopted post Brexit (also referred to herein for convenience as simply the “GDPR”). Those rights include:

• the right of access to your information.
• the right to rectify your information if it is incorrect or incomplete.
• the right to have your information erased (“right to be forgotten”) if certain grounds are met.
• the right to withdraw your consent to our processing of your information at any time (if our processing is based on consent).
• the right to object to our processing of your information (if processing is based on legitimate interests).
• the right to object to our processing of your information for direct marketing purposes.
• the right to receive your information from us in a structured, commonly used and machine-readable format, and the right to transmit your information to another controller without hindrance from us (data portability).

If you are located in the European Union or the UK and you are or have been a user of our services (including the Service), we may send you marketing communications based on our legitimate interests, subject always to your right to opt out of such communications. Further, if you are located in the European Union, we will never share your information with a third party for such third party’s marketing purposes, unless you have specifically consented to us doing so.

You may contact us at [email protected] to exercise any of the above rights. We may request specific information from you to confirm your identity, and in some circumstances, we may charge a reasonable fee for access to your information.

Furthermore, if you believe that our processing of your information is inconsistent with your data protection rights under the GDPR and we have not adequately addressed your concerns, you have the right to lodge a complaint with the data protection supervisory authority of your country.

For purposes of the GDPR, we are a “controller” and you are a “data subject.”

Updates to Our Privacy Policy

Upright Data reserves the right to change this Privacy Policy at any time. If we make a material change to this Privacy Policy, we will make an effort to communicate these changes to you via email or by posting a notification on the Site. The date this Privacy Policy was last revised is at the top of this page. We encourage you to review this Privacy Policy periodically to check for any updates or changes.

Contact Us

If you have any questions about this Privacy Policy or our information practices, please email us at [email protected] or write to us at:

Upright Data, Inc.
1240 Rosecrans Ave #120
Manhattan Beach, CA 90266