Effective Date: March 1, 2018 

This “Privacy Policy” discloses the privacy practices for UP Institute, Inc. (“UP Institute”, “we”, or “us”). This Privacy Policy applies solely to information collected by UP Institute (as the data controller) through the website located at http://up.institute and its associated webpages (the “Website”), and will notify you of the following:

• What information, including personally identifiable information, is collected from you through the Website, how it is collected, how it may be used, and with whom it may be shared.
• What choices are available to you regarding the use of your information.
• The security procedures in place to protect the misuse of your information.
• How you can correct any inaccuracies in the information.

By checking the appropriate box(es) and clicking “I Accept”, you agree that you have read and understand this Privacy Policy and that you accept and consent to the privacy practices (including the uses, disclosures, processing, and transfers of your information by UP Institute) that are described in this Privacy Policy. Kindly note that any consent you provide will be entirely voluntary. HOWEVER, IF YOU DO NOT ACCEPT THIS PRIVACY POLICY, THEN YOU SHOULD NOT USE, AND ARE NOT AUTHORIZED TO USE, THE WEBSITE.

Information Collection

We collect a variety of types of information including:

• Contact information, such as your name and email address;
• Account information, which may include your contact information, as well as your account password and other information about your account;
• Preference information, such as your contact and marketing preferences;
• Demographic information, which may include age or birthdate, gender, ZIP code, geographic location, and other information about you;
• Experience information, including information that you share through the Website regarding any experience that you have had; and
• Correspondence information, including information about your email or other written communications with us, and information that you share in your emails and other written communications with us.

We collect information that you voluntarily give us through your use of the Website, via email, or through other contact or communication with you. We also collect information from social media platforms and networks that you use in connection with the Website, or that share or allow you to share information with us, such as Facebook, Twitter, LinkedIn, and Google+. For example, if you use functionalities, plugins, widgets, or tools from social media platforms or networks in connection with the Website (for example, to share content from the Website with your friends and followers on social media), we will collect the information that you share with us, or that those social media platforms or networks share with us.

Information Use

We use information that we collect and obtain to conduct our business and to provide you with access to the Website and Website content. We may combine any or all of the information that we collect or obtain with other information that we collect or obtain, including, but not limited to, information obtained from third parties with which we choose to work. We use information:

• To provide you with access to the Website and Website content, and to maintain and service your account;
• To contact or respond to you, when you correspond with us by email or otherwise communicate with us, make a request or inquiry, or share a comment or concern;
• To provide social media features;
• For our business purposes, to operate and improve upon our business and lawful business activities, to maintain our accounts and records, for research, to determine your satisfaction with the Website, to detect and prevent fraud or misuse of the Website, to enforce, apply, or comply with any of our terms or policies, including but not limited to this Privacy Policy, and for any other business purpose that is permitted by law; and
• For legal, contractual, and safety purposes, to defend or protect us, you, or other Website users or third parties, from harm or in legal proceedings, to protect our rights, to protect our security and the security of our Website users, employees, and property, to respond to court orders, lawsuits, subpoenas, and government requests, to address legal and regulatory compliance, to verify your identity or communications from you, to comply with contracts and other agreements to which we are a party, and to notify you of changes to our terms, policies and practices

We do not use profiling or make any decisions based solely on the automated processing of your personal information.

Information Use

We may share personal information with:

• The UP Institute family of companies, including our affiliates;
• Third parties and service providers that provide services to us. We may use third parties or service providers to perform any of the actions or activities allowed under this Privacy Policy;
• Social media platforms and networks, such as Facebook, Twitter, LinkedIN, and Google+, that offer functionalities, plugins, widgets, or tools in connection with the Website (for example, to share content from the Website with your friends and followers on social media). If you choose to use these functionalities, plugins, widgets, or tools, certain information will be shared with or collected by those social media companies;
• Parties to business transactions, such as those we deal with in mergers, acquisitions, joint ventures, licenses, media agreements, sales of assets, reorganizations, divestitures, dissolutions, bankruptcies, liquidations, or other types of business or commercial transactions. In these types of transactions, information, including personal information, may be shared, sold, or transferred, and it may be used subsequently by a third party; and
• Additional third parties, such as law enforcement, government entities, courts, our legal advisors, or other third parties as required or allowed by applicable law.

We also may share personal information with third parties upon your request or with your consent, although we may not be able to accommodate all requests.

Your Access to and Control Over Information

You may opt out of any future emails from us at any time. If you have registered for an online account on the Website, we allow you to access and update certain information that you have provided to us by logging into your account and using the features and functionalities available there. In addition, You can do the following at any time by contacting us via the “Contact Us” feature on the Website, or by sending us an email.

• See what information we have about you, if any.
• Change/correct any information we have about you.
• Have us delete any information we have about you.
• Express any concern you have about our use of your information.

We are not able to grant all access requests, and we may request additional information from you in order to verify your identify before accommodating an access request.

In addition, if you are a resident of the European Union, you have certain additional rights under European data protection law, including the right to limit the use of your personal information, to withdraw your consent for the processing of your personal information, and the right to receive a copy of your personal information in a commonly used an machine-readable format for transmission to another data controller. Please remember that if you delete or limit the processing of your personal information, you may not be able to access or use the services provided through the Website.

Your Access to and Control Over Information

We take precautions to help protect the security of information you share with us through the Website, but information transmitted through the Internet may not be perfectly secure. We do not guarantee the security of your information. We will keep your information, including your personal information, only for as long as necessary for the purposes for which it was collected, to provide you and other users with access to the Website and Website content, to carry out legitimate business interests, and where otherwise required or permitted by law. Links to Other Websites and Services.

The Website may provide links to other Internet sites, content, or videos (embedded or direct links) maintained by third parties. We are not responsible for the sites, content, or videos accessed via the links, and we have not reviewed the privacy practices of those third parties. We encourage you to review the privacy practices of those third parties.

Your California Privacy Rights

Once per calendar year, California Civil Code Section 1798.83 provides California residents with the right to receive: information identifying (names and addresses) any third party(ies) to whom we may have disclosed, within the preceding calendar year, certain of your personal information for that third party’s direct marketing purposes; and (b) a description of the categories of personal information disclosed, as required under this law. To request such information, please email us, or write to us at:

UP Institute / Startling, Inc.
San Juan, Puerto Rico.

If you are a California resident under the age of 18, and have a registered account on the Website, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information. 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.

Children’s Privacy

The Website is not directed to or intended to be used by individuals under the age of 16. We do not knowingly request or collect personal information from any person under 16 years of age without prior verifiable parental consent. If you believe that your child under the age of 16 has submitted personal information to us in connection with the Website, and without prior verifiable parental consent, please email us so that we can take steps to delete the personal information that she or he has provided as required in accordance with applicable law.

International Users

Those who access or use the Website from jurisdictions outside the United States of America do so at their own choice and risk and are solely responsible for compliance with local law. If you provide personal information through the Website, you agree that the personal information will be transferred to and processed in the United States of America and any other country or jurisdiction at our sole discretion. The laws that apply to the use and protection of personal information in the United States or other countries or jurisdictions in which we transfer or process personal information may be different than the laws and protections in your country.

In addition, if you are a resident of the European Union, please note that the United States of America has NOT been deemed by the European Commission to ensure an adequate level of protection for personal information. Accordingly, the level of safeguards and legal protections provided in the United States or other non-European countries from which you may access the Website may not be as stringent as that under European Union privacy standards or the privacy laws of some other countries, possibly including your home jurisdiction. BY CHECKING THE APPROPRIATE BOX(ES) AND CLICKING “I ACCEPT”, YOU AGREE THAT YOU ACCEPT AND FULLY UNDERSTAND THE RISKS OF, AND EXPRESSLY CONSENT TO, THE TRANSFER, STORAGE, AND PROCESSING OF YOUR PERSONAL INFORMATION IN THE UNITED STATES AND OTHER COUNTRIES OUTSIDE OF THE EUROPEAN UNION BY UP INSTITUTE IN ACCORDANCE WITH THIS PRIVACY POLICY.

Updates to this Privacy Policy

We may make changes to this Privacy Policy, and may apply any changes to information previously collected, as permitted by law. When we make material changes to this Privacy Policy, we will notify you by posting the updated Policy on the Website, and we will update the effective date at the top of this Privacy Policy. By continuing to use the Website after being notified of material changes to this Privacy Policy, you agree that the terms of this Privacy Policy as of the effective date will apply to information previously collected or collected in the future.

Additional Information and Contacting Us

If you have questions about this Privacy Policy or our privacy practices, please contact us using the “Contact Us” feature on the Website, or by email, or write to us at:

UP Institute / Startling, Inc.
San Juan, Puerto Rico.