upvansa

1. Introduction

upvansa.com is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our website, located at [www.upvansa.com], (“Site”) and Services (as defined in the Terms of Use). Capitalized terms not defined in this Privacy Policy have the meanings given in our Terms of Use.

2. Types of Data We Collect

“Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.

Information You Provide to Us

We may collect Personal Data from you, such as your first and last name, email and password when you log in to our network (“Account”).

When you create an Account on the Site you may provide additional information, for example, a website address or social media URLs.

If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply.

We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, and other requested information if you contact us via email regarding support or further information.

We may also collect Personal Data, such as at other points in our Site that state that Personal Data is being collected.

Typically the main data collected is your name and email address, but other data may be collected by the online platforms used to power these offerings in accordance with their terms and conditions.

Information Collected via Technology

To make our Site and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your device type, browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your device when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.

We also use cookies and URL information to gather information regarding the date and time of your visit and the information for which you searched and which you viewed. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a web site. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. Persistent Cookies can be removed by following Internet browser help file directions.

This Site may use cookies served by a third party service provider to help us analyze how users use the Site through the collection of anonymous user information.

3. Use of Your Personal Data

General Use

In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:

to facilitate the creation of and secure your Account on our network;

identify you as a user in our system;

provide improved administration of our Site and Services;

provide the Services you request;

improve the quality of experience when you interact with our Site and Services;

send you a welcome email to verify ownership of the email address provided when your Account was created;

send you administrative email notifications, such as updates, security or support and maintenance advisories;

respond to your inquiries;

send you newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of upvansa.com.

Creation of Anonymous Data

We may create Anonymous Data records from Personal Data by excluding information (such as your name) that make the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. upvansa.com reserves the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in its sole discretion.

4. Disclosure of Your Personal Data

We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

Third Party Service Providers

We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to upvansa.com. These third party service providers are required not to use your Personal Data other than to provide the services requested by us.

Other Disclosures

Regardless of any choices you make regarding your Personal Data (as described below), upvansa.com may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on upvansa.com; (c) to protect or defend the rights or property of upvansa.com or users of the Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or Terms of Use.

5. Lawful Basis For Processing Personal Data

Our lawful basis for processing Personal Data depends on how the data is collected. For Personal Data collected via activity on the Site related to a request (e.g. making a booking or reservation request) our basis for processing is performance of a contract.

When responding to a direct inquiry via email or other means our basis for processing is legitimate interest.

You have the right to complain to your local data protection authority if you are not satisfied with the way your data is being handled.

6. Social Networking Sites

If you associate your account with your login credentials from a social networking site (e.g. Google, Facebook or Twitter) (“SNS”), we may receive Personal and/or Anonymous Data about you from such SNS, in accordance with the terms and conditions (e.g., terms of use and privacy policy) of the SNS. If you elect to share your information with these SNS, we will share information with them in accordance with your election. The terms and conditions of these SNS will apply to the information we disclose to them. For example, we may offer a feature that allows you to share information from our Site with your SNS.

7. Third Party Websites

When you click on a link to any other website or location, you will leave our Site and go to another site and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites.

8. Your Choices Regarding Your Personal Data

Choices

We offer you choices regarding the collection, use, and sharing of your Personal Data.

We will periodically send you free newsletters and emails that directly promote the use of our Site or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly.

Despite your indicated email preferences, we may send you service related communication, including notices of any updates to our Terms of Use or Privacy Policy.

Changes to Personal Data

You may change any of your Personal Data in your Account [by editing your profile within your Account or by sending an email to us [at the email address set forth below]. You may request deletion of your Personal Data by us, but please note that we may be required to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may retain your information for fraud or similar purposes.

9. Your Rights Under the General Data Protection Regulation (GDPR)

If you are a resident of the European Union or the European Economic Area, you have the following data protection rights under the GDPR:

You can access, correct, update, or request deletion of your Personal Data by emailing hello@sebasma.com

You can object to the processing of your Personal Data, or ask us to restrict the processing of your Personal Data by emailing hello@sebasma.com

You can request an archive of Personal Data by emailing hello@sebasma.com We will provide you with a .csv file or files containing your Personal Data.

You have the right to opt-out of marketing communications. To do so, click on the "unsubscribe" link in the email.

You have the right to complain to a data protection authority about our use of your Personal Data. For more information, please contact your local data protection authority.

We respond to all requests from individuals wishing to exercise their data protection rights within 30 days, and do not charge a fee for fulfilling such requests.

10. Security of Your Personal Data

upvansa.com is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your Account information. Please do not disclose your Account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while upvansa.com uses reasonable efforts to protect your Personal Data, we cannot guarantee its absolute security.

11. Data Retention

We retain Personal Data only as long as we have an ongoing legitimate business need to do so (e.g. to provide you with a service or to comply with legal or tax requirements). At your request, we will delete your Personal Data or anonymize it so that it no longer identifies you, unless otherwise required by law.

12. Children

We do not intentionally gather Personal Data from visitors who are under the age of 13, and children under 13 are prohibited from using our service.

13. International Data Transfers

Your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country.

14. Changes to This Privacy Policy

This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by sending you an email to the last email address you provided to us and/or by prominently posting notice of the changes on our Site. Any changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an email notice to you or thirty (30) calendar days following our posting of notice of the changes on our Site. These changes will be effective immediately for new users of our Service. Please note that at all times you are responsible for updating your Personal Data to provide us with your most current email address. In the event that the last email address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the email containing such notice will nonetheless constitute effective notice of the changes described in the notice. In any event, changes to this Privacy Policy may affect our use of Personal Data that you provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your Personal Data, you must notify us prior to the effective date of the changes that you wish to deactivate your Account with us. Continued use of our Site or Service, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

15. Contact Information

upvansa.com welcomes your comments or questions regarding this Privacy Policy. Please email at hello@sebasma.com

Last Revised: August 30th 2019

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