Last revised: April 29th, 2019
Principles of data protection
Information Submitted by You
Information about you. We collect information about you when you participate in our research process and use the Services in a variety of ways:
Information about others. You may provide information about others (e.g. clients), including their names, emails, phone numbers and companies to support our reference check and review process. You should obtain the consent of other individuals prior to providing UpFirms with their information. The information you provide about others is only used in the reference check and review process.
Information from Third Parties
We may also obtain information about you if it is contained in user-generated content that other users post to or on our Services. For example, a user could include information about you in a review they post.
Automatically Collected Information
Cookies are files that websites and online services create and access on your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device to help us recognize you, improve your experience, increase security, and measure use of our Services. Our Services may use HTTP cookies, HTML5 cookies, Flash cookies and other types of local storage (such as browser-based or plugin-based local storage). Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. You also may be able to delete your Flash cookies or adjust your Flash cookie settings by visiting the Adobe Flash Website Storage Settings Manager by following Adobe’s instructions here (link is external) (instructions vary depending on your operating system and version of Flash). Please note, however, that without cookies or local storage you may not be able to use all of the features of our Services.
We may also collect different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), and may use that information to customize the Services with location-based information, advertising, and features. For example, if you provide a zip code that indicates that you live in New York, the Services may be customized with New York-specific information and advertisements. In order to do this, your location information may be passed along to our agents, vendors or advertisers. If you access the Services through a mobile device and you do not want your device to provide us with GPS location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.
What legal basis do we rely on to process your Personal data?
Information about you may be shared for the following purposes:
Online Analytics Providers
To help us better understand your use of the Services, we may use third-party analytics. These third parties use the sorts of technologies described in the “Automatically Collected Information” section above. The information collected by this technology will be disclosed to or collected directly by these service providers.
Advertising Technology Providers
Data about your activities on our Services may be collected by us or by advertising technology providers for use in delivering online advertising tailored to your individual characteristics, activities, interests and other factors. These ad services may track your online activities over time by collecting information through automated means, including through the use of the various technologies described above, and they may use this information, and other information they receive from us or other sources, to deliver advertisements to you on our website, our emails, and other websites. We and third-party vendors may use first-party cookies and third-party cookies together, and other automated technologies, and in some cases additional information, (i) to inform, optimize, and serve ads based on past visits to our Services or other factors and (ii) to report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our Services or other factors.
You may visit the Network Advertising Initiative’s Consumer Opt-Out page (link is external) or the Digital Advertising Alliance’s Consumer Opt-Out page (link is external) to opt out of receiving tailored advertising based on your Internet browsing activities from companies that participate in those programs. Some of our advertising-related activities may involve the services of companies that do not participate in those programs. For example, we use the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our Website. You can set preferences for how Google advertises to you using the Google Ad Preferences page (link is external). The opt-outs apply only to the browser in which you set them. For example, if you set the opt-out while using Firefox, but then use Chrome, the opt-out will not be active in Chrome. To opt out in Chrome, you will need to repeat the opt-out process.
Do Not Track Disclosure
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. However, we do not recognize or respond to browser-initiated DNT signals, as the internet industry is still working to determine what DNT means, how to comply with DNT, and how to create a common approach to responding to DNT.
You have a right to (1) access, modify, correct, or delete certain aspects of your information regarding your user profile, and (2) close your user account. You can also contact us regarding any account information which is not on your profile or readily accessible to you. If you close your account, your information may be removed or unpublished from the Services within a reasonable amount of time.
Once you submit a review and the review has been approved for posting, it cannot be edited or removed. You will have the ability to submit a revision to appear below your original posting and to revise your star ratings.
Note that information that others have copied may remain visible and you may not be able to access, correct, or eliminate any information about you that others copied or exported out of UpFirms, because this information may not be in our control. Your information may be displayed in search engine results until the search engine refreshes its cache.
We retain your information as long as your account is active or as needed to provide you services or because we have an ongoing legitimate business need to do so. We also retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. We store your information as long as is necessary for the purpose for which we have collected it. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if it is possible (e.g. your personal information is stored for backup archives) then will securely store your personal information and isolate if from any further processing until the deletion/erasure is possible.
We have implemented various technical, administrative, and physical safeguards to protect your information. These safeguards vary depending on the sensitivity of the information at issue.
The Services are not intended for use by children under the age of 13. We do not knowingly collect (or knowingly allow any third party to collect) personal information from persons under the age of 13. If we become aware that personal information has been collected from a person under the age of 13, we will delete this information and terminate the person’s account as quickly as possible.
Whenever you use our services from within the EU the following rights apply to your user account:
The right to be informed, The right of access, The right to rectification, The right to erasure, The right to restrict processing, The right to data portability, The right to object and rights in relation to automated decision making and profiling.
If you wish to exercise any of the above rights, please contact us using the contact details set out below. For the protection of your privacy and security, our Data protection team shall take every reasonable step to ensure that your identity is verified before granting access, or rectification, or deletion.