Privacy Policy
Introduction
This Privacy Policy explains what we do with your personal data within the scope of providing the services offered on the website www.uPassable.com (the “Platform”), such as the sale and subscription to courses, creating your profile at uPassable.com, the ability to offer and apply for employment, communications, etc. (the “Services”). We also explain our policy in terms of data we may collect when you visit the Platform.
Pursuant to applicable data protection laws, bear in mind that:
If you live in a country that is a member of the European Economic Area, the way your data is processed and the current Privacy Policy shall be governed by the General Data Protection Regulation or Regulation [UE] 2016/679(“GDPR”).
If you live in a country outside the European Economic Area, collection of your personal data shall be governed according to the privacy laws of the state of California.
The company responsible for personal data is uPassable Inc., with registered offices in 2001 Addison St., Suite 300 Berkeley, CA, 94704, United States (uPassable) (“We” or “Data Controller”). To contact the representative from the Data Controller, you may send an email to: info@uPassable.com
If the information indicated as required is not provided, we might be unable to process your user registration or the use of certain Services available in the Platform.
In order to register and navigate the Platform, you need to be older than 16. uPassable may use your personal information to verify your age and ensure the enforcement of this restriction.
Legal basis for processing the personal data
Collection and processing of your personal data is based primarily on the contractual and/or non-contractual relationship you have with us.
When we send you newsletters and Services or when we use the email you have provided us to contact you individually or to recognize you when you return to visit our website, we are doing so under the informed consent.
How we process the information collected by our cookies is based on the informed consent you provide, pursuant to current legislation.
Personal information we collect
In order to register on the Platform and identify yourself, we will request your email and date of birth.
To create your profile on the Platform, you may include personal information such as your country or city of residence, a photograph, first and last names, education, work experience, and any other additional information you might want to share in your profile. The profile information helps you make the most out of our Services, like helping other professionals find you and finding business opportunities or projects you might be interested in. However, if you do not want this information to be published, you may leave the profile information fields blank or delete the information already provided.
To buy or subscribe to our courses, we will request your credit card or debit information, including expiration date and CVV. If you are paying with PayPal, we will request the email associated with it. If you are paying with PayU, we will redirect you to that payment platform. If you request an invoice, we will request your invoicing data, if needed.
When you visit or use our Services, we register data such as the frequency of use, date and time Services were accessed, when you see or click on specific content, your course preferences, projects you are sharing, or content you publish. We use information when you log in, when you read our emails, and Internet protocol (“IP”) addresses to identify you and register your use on the Platform.
We do not make decisions based on profiles, beyond personalization of advertisement and for the purpose of the legitimate prevention of Internet fraud.
We obtain information through other platforms, for example, when you register via Facebook or similar technologies. This might include personal texts or images available on an external website.
Purpose of the processing
uPassable, as the Data Controller, will process your personal data for the following purposes:
Manage your registration as a Platform user, to identify you and give you access to Services available for registered Platform users.
The development, compliance, and execution of the contract for the provision of services such as the sale of or subscription to uPassable PRO courses or any other contract we might have through the Platform. You will need to keep in mind that:
You expressly authorize us to process the data indicated as required for activation and payment processing. The card’s security code (CVV or CVC) will only be used to process the purchase in course and will not be stored or processed afterward as part of your payment information. The consent for the activation of this feature allows your data to autofill in future purchases so you do not need to re-enter payment information every time you make a purchase. The data enter will be assumed valid and current in future purchases. You will be able to modify or delete your credit cards or PayPal account at any time through the payment method in the purchase form or through the payment method setting in your uPassable PRO subscription. We store and release card information in accordance with international confidentiality and security standards for credit and debit cards. For security reasons, the use of this feature might require changing your password. Remember, the safety of the Platform also depends on the correct use and storage of confidential passwords.
Recommending jobs that match your profile.
Contacting you through email regarding updates or information related to features, products, or services contracted, including Platform security updates, as long as they are needed or reasonable.
Respond to any request or inquiry you make through the customer service channels available on our Platform.
We also use your information to generate aggregated non-identifying data. For instance, generate statistics regarding our users, their jobs or areas of expertise, the number of impressions or clicks on a specific course or project, or visitor demographics.
Options
The provision of uPassable’s Service might entail the use of your personal data, with your express consent, to make available to you personalized advertisement related to our products and services, through emails or other electronic communication means from us or third-party collaborators. With the goal of improving our services, please know that personal information regarding your purchases, interests, and preferences might be used by uPassable for the purpose of analysis, user profiling, marketing studies, quality surveys, and improving interaction with our clients.
If you do not want to receive a certain type of email communications, simply access the Notifications section under Edit Profile to manage your preferences.
Likewise, you will be able to cancel your notifications by following the instructions in each notice you receive.
Data retention period
We will retain your personal data for as long as we have a valid contractual relationship, and after that, for the period determined by any obligations arising from the treatment of the data or as established by law.
Data Recipients
To comply with the purposes indicated in this Privacy Policy, it might be necessary to report or release your personal data to third parties for the following reasons:
Business Transfers: in connection with any recomanization, restructuring, merger, or sale, or any other transfer of assets, including personal, provided that the receiving party accepts to process your personal information in accordance with our Privacy Policy.
Service Providers: in order to provide services on our behalf or to help us provide our services. For example, we contract service providers to render marketing, advertising, communication, infrastructure, and IT services, to customize and improve our service, to process credit card transactions or other methods of payment, provide customer service, collect debts, analyze and improve data (such as data regarding user interaction with our services), and process and manage satisfaction surveys. For efficiency purposes, these partners and providers may be based in the US or other countries or territories outside of the European Economic Area and might not provide a data protection level comparable to that of your country or the European Union’s.
When you accept this Privacy Policy, you are specifically authorizing us to process and report your personal data to the partners mentioned and/or release your personal data to the service providers as processors located outside of the European Economic Area for the purposes described herein and to provide you complete service. When we release personal information when exchanging data with countries outside the European Economic Area and other areas with data protection laws, we will ensure the information is being transferred in compliance with this Privacy Policy and pursuant to current data protection laws.
Data Protection Rights
As Data Controller, we are committed to respecting the confidential nature of your personal data and guaranteeing the full exercise of these rights. At all times, you will have the following rights:
Right to access. You have the right to confirm whether we are processing your personal data and, if we are, you have the right to obtain a copy of such data and information regarding the processing.
Right to amend. You have the right to correct errors, modify incomplete or wrong data, and guarantee the authenticity of the information that is being processed.
Right to delete. You have the right to request the deletion of your data without undue delay, if it were being processed wrongfully or if the end to which it was processed or collected has ceased to exist.
Right to limitation of processing. You have the right to request the suspension of the processing of your information if it is illegal or the accuracy of the data has been contested.
Right to oppose. You have the right to oppose the processing of your data when it has been used for purposes of direct marketing or when the processing must be terminated due to a personal situation, except when there is legitimate interest or it is necessary for the exercise or defense of claims.
Right not to be subjected to personalized decisions. You have the right not to be subjected to a decision based solely on the automatic processing of your data, including profiling, with binding legal effects or which affects you, except when necessary for the execution of an agreement, as permitted by the law, or if you have expressly authorized it.
In order to exercise these rights, please send an email to: info@uPassable.com indicating your (i) identity, by sharing your full name and email address used to register or make a purchase at uPassable, an ID to establish your identity, and (ii) the right or rights you’re exercising.
You may also visit the agency overseeing the protection of data in your country to file a claim or request the protection of your rights if deemed necessary.
The exercise of such rights is free, except when requests are deliberately unfounded or excessive, in which case, the individual will be required to bear the processing costs.
uPassable complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. uPassable has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
Information about cookies
We use cookies, small files with information regarding your navigation on this Platform, mainly to enable a better user experience. Please read our Cookies Policy to know more about the cookies we use, their purpose, and other useful information.
Requirements
In compliance with the Privacy Shield Principles, uPassable commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact uPassable at: info@uPassable.com
Modifications to the Privacy Policy
uPassable reserves the right to modify this Privacy Policy at any time. We recommend you to regularly review this Policy to be aware of any changes that may occur. However, significant changes to the Privacy Policy will be notified through our Platform or by other means, so you can review them before you continue using our Services.
If you continue to use the Platform after the modifications have been implemented, it will be understood that you accept the new terms of the Privacy Policy. If you do not agree with the changes, please do not continue using our Platform or Services.
Last update: June 2023
