UpFrom PRIVACY POLICY

UpFrom, Inc. (“UpFrom,” “we,” or “us”) wants you to be familiar with how we collect, use, and disclose information. This Privacy Policy describes our practices in connection with information that we collect.

DATA COLLECTION PRINCIPLES AND PRACTICES

The privacy, safety and trust of our users is top priority for UpFrom, and we take seriously the responsibility to safeguard and steward our users’ data. This Policy aims to ensure compliance with the

European General Data Protection Regulation as the current highest standard of data protection and privacy in the world. This Regulation sets out the principles with which any party handling personal data must comply in Europe and provides equal or higher standards of privacy and protection than are required in other parts of the world. As global data protection and privacy standards evolve, UpFrom will continue to strive to the highest standards and to implement those standards internationally to the best of our ability. At minimum, we will always meet local standards of data and privacy protection to ensure compliance.

UpFrom adheres to the following principles of data protection:

• Data processing must be fair to the data subject;
• Data must only be processed for specific and legitimate purposes as outlined in this Privacy Policy;
• Our applications don’t collect more data than is needed to provide specific value to our users;
• We make commercially reasonable effort to ensure that the data collected through our technologies is accurate;
• We don’t store personal data longer than needed for the specified purpose;
• We process data in a way that ensures security, integrity, and confidentiality; and
• We can demonstrate compliance with these principles.

Our practices ensure, in compliance with GDPR, that all personal data will be:

• Processed lawfully, fairly and in a transparent manner in relation to individuals;
• Collected for specified, eUpFromplicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be incompatible with the initial purposes;
• Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
• Accurate and, where necessary, kept up to date; every commercially reasonable step is taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased, or rectified without delay;
• Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;