PARTNER UTOPIA LLC

 

PRIVACY POLICY

 

Last Updated July 30, 2024

 

           Partner Utopia LLC,together with its parents, subsidiaries, and affiliates (the “Company”,“we”,“us”or “our”),is committed to protecting your (“your”, “your” or“user”) privacy and empowering you with this privacy policy (this“Privacy Policy”). This Privacy Policy explains how we collect,use, disclose, and apply the information collected when you access, use, or interact with ourproducts and/or services, including our website (https://www.partnerutopia.com/) (our “Website”),our software platform and applications (our “Platform”), andintegrated and related services (collectively, the “Services”). Our Terms of Service, located on our Website (the “Terms”)are expressly incorporated herein, by reference, and are an integral parthereof.

 

           ThisPrivacy Policy sets forth our policy with respect to information that wecollect from you, on or through the Services, that identifies, relates to,describes, is reasonably capable of being associated with, or could reasonablybe linked, directly or indirectly, with you (“Personal Data” or “PersonalInformation”). We take the privacy of your Personal Data seriously.Because of that, we have created and abide by this Privacy Policy. By using theServices or interacting with us, you are agreeing to the application of thisPrivacy Policy. Please read the following carefully to understand how wecollect, use, disclose, and maintain information that can be used to identifyyou. In addition, this Privacy Policy describes your choices for use, access,and correction of your Personal Data. If you do not agree to be bound by this Privacy Policy, please stopaccessing or using the Services.

1. Changes to this Privacy Policy.

We may change this Privacy Policy, at anytime and from time to time. In the event that we make changes, we will notifyyou by revising the “Last Updated” date at the top of this Privacy Policy. Ifthere are significant changes to this Privacy Policy, we will attempt to notifyyou directly by e-mail, or provide information via our Services homepageprior to any such changes becoming effective. We encourage you to review ourPrivacy Policy whenever you use the Services to stay informed of ways that youcan protect your privacy.

You may choose to submit information to us when you use ourServices, create an account via the Services, in connection with an actual orpotential business relationship with us, or when interacting with us. More information about the categories andsources of Personal Data is provided below. 

2. Information We Collect andReceive.

2.1 Information You Provided to Us.

We collect Personal Data that youdecide to share with us. At times, we may require you to provide certaininformation in order to use certain parts of our Services, fulfill yourrequests, or provide you with certain services.

2.1.1    Account Information.

If you establish an account withus, we may require you to provide your name, address, e-mail, and a password.

2.1.2    Payment Information.

If you purchase any of our Services, wewill collect your credit card information (e.g., your credit card numberand expiration date, billing address, etc.). All credit card information isstored by athird-party payment processor selected by us, from time to time, and suchpayment services are governed by such third-party payment processor’s terms ofservice and privacy policy. For the avoidance of doubt, your credit cardinformation isnever stored by the Company or on the Company’s servers.

2.1.3 User Content

Certain features and functionalities ofthe Services may allow you to upload, deliver, store, transmit, make available,or share certain user generated information, content, materials, documents, andmessages, including various text, images, and files, and which may includecertain Personal Data.

2.1.4 Social Media Data

We have pageson social media services like Facebook, Twitter, Instagram, and LinkedIn (“SocialMedia Pages”). When you interact with our Social Media Pages, we willcollect Personal Data that you elect to provide to us, such as your contactdetails and messages sent. In addition, the companies that host our SocialMedia Pages may provide us with aggregate information and analytics regardingthe use of our Social Media Pages.

2.1.5 Contacting Us

You may interact with us through ourServices, including through any interactive feature, online contact form, by email,or any other communication mechanism. When using these channels, you typicallyprovide your account information and any other information that you choose toprovide at your option.

2.1.6 Surveys

We may contact you to participate in surveys. If youdecide to participate, you may be asked to provide certain information whichmay include Personal Data.

2.2 InformationWe Obtain from Others.

We may obtain Personal Data about you from third parties who help usprovide our Services. We may also obtain some information from our marketingpartners in order to inform you about products or services that we think youmight be interested in. Finally, we may obtain information that does notidentify you directly, but which is later used in a way that may directlyidentify you. We may combine that general information with your Personal Datato provide related services to you.

2.3 Information We Automatically Collect

We automatically collect certaininformation from you when you use the Services, including internet or othernetwork activity information (as described below), unique device identifiers,browsing and search history (including content you have viewed in the Services),and cookies and other technologies (as described below). Information collectedautomatically includes:

2.3.1 Log information

We retain information about you when you access and use the Services.This information can include, e.g., the following:  Internet Protocol (“IP”)address, timestamps, browser information, internet service provider, webpagesvisited, and the URL of the webpage you visited before navigating to our Services.

2.3.2 Usage Information

We monitor user activity in connection with the Services and maycollect information about the features you use within the Services as well as thetypes and amount of the Services you use.

2.3.3 Crash and Error Information

If the Services crash or return an error, we may collect data todetermine the cause of the error using first or third-party services. The crashor error information collected may include, e.g., the following:  device IP address, device name, operatingsystem version, application configurations(s), the time and date, and otherstatistics.

3.  Cookiesand Other Technologies

3.1  Generally

Our Services may use cookies and othertechnologies (such as “pixel tags”, “web beacons”, “clear GIFs”, links in e-mails,JavaScript, device IDs assigned by Google or Apple, or similar technologies) tocollect information and support certain features of our Services. Cookies and othertechnologies allow us and third parties to obtain information about your visitsto our Website and use of our Services, including analyzing your visitingpatterns. Although you are not required to accept cookies when you visit our Services,you may be unable to use all of the functionality of our Services if yourbrowser restricts our cookies. We use this information to process your requestsand to deliver online and mobile advertisements, messages, and content for usand others that are specific to your interests. The information we collect fromcookies and other technologies does not identify you personally but in somecases, we may link it to your Personal Data.

3.2 Cookies

Below, we explain the different types of cookiesthat may be used on the Services.

3.2.1 Necessary Cookies

These cookiesare essential for you to browse our Website and to access and use our Services,as well as for us to identify and prevent security risks, and containinformation about a user’s authentication status on the Website and the Services.Without these cookies, certain Services, like logging into secure areas withinthe Services, cannot be provided.

3.2.2 Performance Cookies

Thesecookies collect information about how you use our Website and the Services,such as which pages you visit most often. This information is used to improvehow our Website and the Service work.  

3.2.3 Functionality Cookies

Thesecookies allow our Website and the Services to remember choices you make (suchas your username, language, or the region you are in) and to provide you with enhanced,more personalized features.

3.3 OtherTechnologies

In addition to cookies, we mayuse other technologies to, among other things, track the actions of the usersof the Services, measure the success of our marketing campaigns, and compilestatistics of the Services.

4. How We Use Your Information

4.1 For Our Legitimate Business Interests

We may use the Personal Data that we collect for our legitimateinterests and the limited purpose of providing the Services and as permitted byapplicable law. These purposes include circumstances where it is necessary toprovide or fulfill the Services requested by or for you or where you have givenus your express consent. As such, we may use your Personal Data to:

(i)         Provide the information, products, and services you request;

(ii)        Service your account and provide you, if you are a registereduser, with effective customer service;

(iii)       Better understand your needs and interests, and provide youwith a personalized experience when you use our Services;

(iv)       Contact you with special offers and other information webelieve will be of interest to you (in accordance with any privacy preferencesyou have expressed to us);

(v)        Contact you with information that you have requested, andnotices related to your use of our Services;

(vi)       Sendyou commercial or marketing/advertising messages, including, withoutlimitation, messages, including via newsletters and e-mail communications aboutour offerings or Services;

(vii)      Invite you to participate in surveys and provide feedback to us(in accordance with any privacy preferences you have expressed to us);

(viii)     Improve our products and services, developnew products and services, improve our marketing and promotional efforts, and improvethe content, functionality, and usability of the Services;

(ix)       Enforce our other policies, such as our Terms;

(x)        Promote security and protect against and prevent fraud,claims, and other liabilities;

(xi)       Verify the information that you provide to us as well as therepresentations and warranties that you make to us in the Terms or on the Services;

(xii)      Meet our internal and external audit obligations; and

(xiii)     To comply with legal obligations and legalprocess and to protect our rights, privacy, safety, or property, and/or that ofour affiliates, you, or other third parties.

4.2 With Your Consent

In some cases, we will ask you forconsent to use your Personal Data for specific purposes. If we do, we will makesure that you can revoke your consent in accordance with the “Your Choices”section below.

4.3  Other Purposes.

If we intend touse any Personal Data in any manner that is not consistent with this PrivacyPolicy, you will be informed of such anticipated use prior to, or at the timethat, the Personal Data is collected, or we will obtain your consent subsequentto such collection, but prior to such use.

4.4 Aggregated Personal Data.

We mayaggregate and/or de-identify information collected through the Services andfrom other sources so that such information can no longer be linked to you oryour device (“Aggregate/De-Identified Information”). We may useAggregate/De-Identified Information for any purpose, including, withoutlimitation, for research and marketing purposes.

5.  How We Share and Disclose Information.

5.1 We Do Not Sell Personal Data.

Wedo not sell or otherwise disclose Personal Data we collect about you, except asdescribed herein or otherwise disclosed to you at the time such Personal Datais collected.

5.2 Service Providers; Business Partners. 

Weprovide access to or share your Personal Data with select third parties whoperform services on our behalf. Pursuant to our instructions, these thirdparties will access, process, or store Personal Data in the course ofperforming their duties to us. We take commercially reasonable steps to ensure thatour service providers adhere to the security standards we apply to yourPersonal Data. Our service providers provide a variety of services to us,including, for example, billing, accounting, sales, marketing, advertising,analytics, research, customer relationship management, customer service, datastorage, security, payment processing, and legal services. We also provideaccess to or share your Personal Data with our business partners to facilitate theprovision of the Services.

5.3 Your Consent.

You consent to: (i)our sharing of your Personal Data with actual and potential partners of yours whouse the Services; and (ii) to receiving communications from such actual andpotential partners in conjunction with your use of the Services. We may ask foryour consent to share your Personal Data with certain other third parties andyour ability to use the Services may be impacted by your denial of anyrequested consent. We may share your information for other purposes pursuant toyour consent or with your further direction.

5.4 Settings.

We may share informationconsistent with your setting selections within the Services.

5.5 Aggregate/De-Identified Data.

From time to time, we may share Aggregate/De-IdentifiedInformation about use of the Services, such as by publishing a report on usagetrends. The sharing of such data is unrestricted.

5.6 LegalReasons.

We may also disclose your PersonalData when we, in good faith, believe disclosure is appropriate to comply withthe law, a court order, or a subpoena. We may also disclose your Personal Data,e.g., to prevent or investigate a possible crime, such as fraud oridentity theft; to protect the security of our Services; to enforce or applyour policies or other agreements; or to protect our own rights or property orthe rights, property or safety of our users or others. We will attempt tonotify our users about legal demands for their Personal Data when appropriatein our judgment, unless prohibited by law or court order or when the request isan emergency. We may dispute such demands when we believe, in our discretion,that the requests are overbroad, vague, or lack proper authority.

5.7  Sale,Merger, or Other Business Transfer.

As wecontinue to develop our business, we may buy, merge, or partner with othercompanies. In such transactions (including in contemplation of suchtransactions), Personal Data may be among the transferred assets. If a portionor all of our assets are sold or transferred to a third-party, your PersonalData would likely be one of the transferred business assets. If such transferis subject to additional mandatory restrictions under applicable laws, we willcomply with such restrictions.

6. Your Choices.

(a)        Youcan manage cookies through your web browser. Most browsers will tell you how tostop accepting new cookies, how to be notified when you receive a new cookie,and how to disable existing cookies. You can find out how to do this for your particularbrowser by clicking “help” on your browser’s menu or by visiting www.allaboutcookies.org.Please note, however, that without cookies you may not be able to take fulladvantage of all our website features. In addition to the browser-based controls,you can manage third-party cookies by visiting www.aboutads.info/choices/.Alternatively, for some devices, you may use your device’s platform controls inyour settings to exercise choice. Please note you must separately opt-out ineach browser and on each device. Advertisements on third-party websites mayhave been directed to you based on information collected by advertisingpartners over time and across websites. These advertisements provide amechanism to opt out of the advertising partners’ use of this information forinterest-based advertising purposes.

(b)       You have a choice, at any time, to stopus from sending you e-mails for marketing purposes by following the“unsubscribe” link included in these messages. Please note that despite anyindicated e-mail marketing preferences, we may continue to send youadministrative e-mails regarding the Company and the Services, including, forexample, notices of updates to our policies or this Privacy Policy if we chooseto provide such notices to you in this manner.

(c)        If you do not provide the informationthat we need to provide the Services, we may not be able to provide with the Servicesor certain functionalities. We will tell you what Personal Data that you mustprovide in order to use the Services and related functionalities or services.

(d)       Some browsers offer a “do not track” (“DNT”)option. Since no common industry or legal standard for DNT has been adopted byindustry groups, technology companies, or regulators, we do not respond to DNTsignals. We will make reasonable efforts to continue to monitor developmentsaround DNT browser technology and the implementation of a standard.

7. Additional Information for Residents of Certain US States.

7.1 Additional Information for California Residents (EffectiveJanuary 1, 2023).

7.1.1    Ifyou are a resident of the State of California, you may have certain rightsafforded to you under the California Consumer Privacy Act or the “CCPA”,as amended by the California Privacy Rights Act.

7.1.2    We collect Personal Informationfor the business and commercial purposes described in the section above titled“How We Use Your Information”, and we share Personal Information with thecategories of third parties described in the section above titled “How We Shareand Disclose Information”. We do not ‘sell’ (as such term is defined in theCCPA) the Personal Information we collect (and will not sell it withoutproviding you a right to opt-out). Please note that we do use third-partyCookies for our advertising purposes as further described in the section abovetitled “Information We Automatically Collect”.

7.1.3    California law, if applicableto us, provides some California residents with the rights listed below:

 (i)         You may have theright to request that we disclose to you the Personal Information we collect,use, or disclose, and information about our data practices.

 (ii)        You may have theright to request that we delete your Personal Information that we havecollected from you.

 (iii)       You may have theright to request that we correct your inaccurate Personal Information.

(iv)       You may have theright to exercise control over our collection and processing of certainsensitive Personal Information.

 (v)        You have the rightnot to receive retaliatory or discriminatory treatment for exercising theserights.

7.1.4    Torequest access to or deletion of your Personal Information, or to exercise anyother privacy rights under California law, please contact us at info@partnerutopia.com,or via any other method which may be specified in the “Contact Us” section below. In order to verify your request, we may require you toprovide us with certain information to be used solely for the purpose ofverifying your identity.

7.1.5    Underthe CCPA, you may exercise these rights yourself or you may designate anauthorized agent to make these requests on your behalf. We may request thatyour authorized agent have written permission from you to make requests on yourbehalf and may need to verify your authorized agent’s identity.

7.2 Additional Information for Colorado Residents (Effective July1, 2023).

7.2.1  TheColorado Privacy Act, if applicable to us, provides some Colorado residentswith the rights listed below:

(i)         You may have theright to know and see what Personal Data we have collected about you in aportable format.

(ii)        You may have theright to request that we correct your inaccurate Personal Data.

(iii)       You may have theright to request that we delete the Personal Data we have collected about you.

(iv)       You may have theright to opt out of targeted advertising (as defined under Colorado law).

7.2.2    Torequest access to or deletion of your Personal Data, or to exercise any otherprivacy rights under Colorado law, please contact us at info@partnerutopia.com,or via any other method which may be specified in the “Contact Us” section below.

7.2.3    Pleasenote that to respond to some rights we may need to verify your request eitherby asking you to log in and authenticate your account or otherwise verify youridentity by providing information about yourself or your account. You maydesignate another person to serve as your authorized agent and to exercise youropt-out right on your behalf; however, we may request certaininformation in order to verify your identity and the authorized agent’sauthority to act on your behalf.

7.3 Additional Information for Connecticut Residents (EffectiveJuly 1, 2023).

7.3.1 TheConnecticut Data Privacy Act, if applicable to us, provides some Connecticutresidents with the rights listed below:

(i)         You may have theright to know and see what Personal Data we have collected about you in aportable format.

(ii)        You may have theright to request that we correct your inaccurate Personal Data.

(iii)       You may have theright to request that we delete the Personal Data we have collected about you.

(iv)       You may have theright to opt out of targeted advertising (as defined under Connecticut law).

7.3.2    Torequest access to or deletion of your Personal Data, or to exercise any otherprivacy rights under Connecticut law, please contact us at info@partnerutopia.com,or via any other method which may be specified in the “Contact Us” section below.

7.4 Addition Information for Nevada Residents (EffectiveOctober 1, 2019).

7.4.1  Ifyou are a Nevada resident, under Privacy and Security of Personal InformationChapter of the Nevada Revised Statutes Section 603A, we are required to provideyou with the following:

(i)         We may collect certain covered information (as defined underNevada Law) when you use or visit our Services, including, but not limited tofirst and last name, home or other physical address, e-mail address, andtelephone number;

(ii)        We may share your covered information to third parties asdescribed in the section above titled “How We Share and Disclose Information”;and

(iii)       Third parties may collect covered information about youronline activities over time and across different internet websites or onlinewebsites when you use our Services.

7.4.2    UnderNevada law, certain Nevada consumers may opt-out of the sale of “personallyidentifiable information” for monetary consideration (as such terms are definedunder Nevada law) to a person for that person to license or sell suchinformation to additional persons. We do not engage in such activity; however,if you are a Nevada resident who has provided “personally identifiableinformation” to us via the Services, you may submit a request to opt-outof any potential future sales under Nevada law by contacting us at info@partnerutopia.com,or via any other method which may be specified in the “Contact Us” section below. Please note we will take reasonable steps to verify youridentity and the authenticity of the request. Once verified, we will maintainyour request in the event our practices change.

7.5 Additional Information for Oregon Residents (Effective July 1,2024).

7.5.1  Ifyou are an Oregon resident, pursuant to the Oregon Consumer Privacy Act, wemust share with you that:

(i)         We collect andprocess the categories of Personal Data described in the section above titled“Information We Collect and Receive”;

(ii)        We processPersonal Data for the business and commercial purposes described in the sectionabove titled “How We Use Your Information”; and

(iii)       We may share thecategories of Personal Data described in the section above titled “InformationWe Collect and Receive” with the categories of third parties set forth in thesection above titled “How We Share and Disclose Information”.

7.5.2    OregonLaw, if applicable to us, provides some Oregon residents with the rights listedbelow:

(i)         You may have theright to receive confirmation as to whether we are processing or have processedyour Personal Data and the categories of Personal Data that we are processingor have processed.  

(ii)        You may have theright to receive, at our option and in our sole discretion, a list of specific third-parties, otherthan natural persons, to which the we have disclosed your specific PersonalData to or any Personal Data to, generally.

(iii)       You may have the rightto receive a copy of all of your Personal Data that we have processed or areprocessing in a portable formation.

(iv)       You may have theright to request that we correct inaccurate Personal Data; however, in decidingwhether to comply with such request, we may take into account the nature of the Personal Data and thepurpose(s) for processing the Personal Data.

(v)        You may have theright to request that we delete your Personal Data, including your Personal Data which you have provided tous, your Personal Data which we have obtained from another source, and deriveddata.

(vi)       You may have theright to opt-out from ourprocessing of your Personal Data for any of the following purposes:  (a) targeted advertising, (b) selling yourPersonal Data, or (c) profiling in furtherance of decisions that produce legaleffects or effects of similar significance; however, please note that wedo not, at this time, process your Personal Data for any of the above-mentionedpurposes.

7.5.3    To request access to ordeletion of your Personal Data, or to exercise any other privacy rights underOregon law, please contact us at info@partnerutopia.com, or viaany other method which may be specified in the “Contact Us” section below.If you would like to appeal our refusal to take action on a prior submittedrequest, you may do so by submitting an appeal to us at info@partnerutopia.com.

7.5.4    Pleasenote that to respond to some rights we may need to verify your request eitherby asking you to log in and authenticate your account or otherwise verify youridentity by providing information about yourself or your account. You maydesignate another person to serve as your authorized agent and to act on yourbehalf to opt-out of the processing of your Personal Data under specifically Section7.5.2(vi); however, we may request certain information in order toverify your identity and the authorized agent’s authority to act on yourbehalf.

7.6  Additionalinformation for Texas Residents (Effective July 1, 2024).

7.6.1    Ifyou are a Texas resident, pursuant to the Texas Data and Privacy Security Act,we must share with you that:

(i)         We collect andprocess the categories of Personal Data described in the section above titled“Information We Collect and Receive”;

 (ii)        We processPersonal Data for the business and commercial purposes described in the sectionabove titled “How We Use Your Information”; and

 (iii)       We may share thecategories of Personal Data described in the section above titled “InformationWe Collect and Receive” with the categories of third parties set forth in thesection above titled “How We Share and Disclose Information”.

7.6.2    Texaslaw, if applicable to us, provides some Texas residents with the rights listedbelow:

 

(i)         You may have theright to receive confirmation as to whether we are processing your PersonalData and the right to access such Personal Data.  

(ii)        You may have theright to request that we correct inaccuracies with respect to your PersonalData; however, in deciding whether to comply with such request, we may takeinto account the nature of thePersonal Data and the purpose(s) for processing the Personal Data.

(iii)       You may have theright to request that we delete your Personal Data which you provided or whichwe have obtained about you.

(iv)       If the such datais available in a digital formation, you may have the right to receive a copyof your Personal Data that you previously provided to us in a portable formatand, to the extent technically feasible, in a readily usable format that allowsyou to transmit the data to another controller without hinderance.

(v)        You may have theright to opt-out from ourprocessing of your Personal Data for any of the following purposes:  (a) targeted advertising, (b) the sale ofyour Personal Data, or (c) profiling in furtherance of decisions that produce alegal or similarly significant effect concerning yourself; however,please note that we do not, at this time, process your Personal Data for any ofthe above-mentioned purposes.

7.6.3    Torequest access to or deletion of your Personal Data, or to exercise any otherprivacy rights under Texas law, please contact us at info@partnerutopia.com,or via any other method which may be specified in the “Contact Us” section below. If you would like to appeal our refusal to take action on aprior submitted request, you may do so by submitting an appeal to us at info@partnerutopia.com.

7.6.4    Pleasenote that to respond to some rights we may need to verify your request eitherby asking you to log in and authenticate your account or otherwise verify youridentity by providing information about yourself or your account. You maydesignate another person to serve as your authorized agent and to act on yourbehalf to opt-out of the processing of your Personal Data under specifically Section7.6.2(v)(a)-(b); however, we may request certain information inorder to verify your identity and the authorized agent’s authority to act onyour behalf.

7.7 AdditionalInformation for Utah Residents (Effective December 31, 2023).

7.7.1    Ifyou are a Utah resident, pursuant to the Utah Consumer Privacy Act, we mustshare with you that:

(i)         We collectPersonal Data for the business and commercial purposes described in the sectionabove titled “How We Use Your Information”;

(ii)        We may share yourPersonal Data to third parties as described in the section above titled “How WeShare and Disclose Information”; and

(iii)       We collect thecategories of Personal Data described in the section above titled “InformationWe Collect and Receive”.

7.7.2    Utahlaw, if applicable to us, provides some Utah residents with the rights listedbelow:

(i)         You may have theright to know and see what Personal Data we have collected about you in aportable format.

(ii)        You may have theright to request that we delete the Personal Data we have collected about you.

(iii)       You may have theright to opt-out of targeted advertising (as defined under Utah law).

7.7.3    Torequest access to or deletion of your Personal Data, or to exercise any otherprivacy rights under Utah law, please contact us at info@partnerutopia.com,or via any other method which may be specified in the “Contact Us” section below.

7.8 Additional Information for Virginia Residents (EffectiveJanuary 1, 2023).

7.8.1    Ifyou are a Virginia resident, pursuant to the Virginia Consumer Privacy Act, wemust share with you that:

(i)         We collectPersonal Data for the business and commercial purposes described in the sectionabove titled “How We Use Your Information”;

(ii)        We may share yourPersonal Data to third parties as described in the section above titled “How WeShare and Disclose Information”; and

(iii)       We collect thecategories of Personal Data described in the section above titled “InformationWe Collect and Receive”.

7.8.2 Virginialaw, if applicable to us, provides some Virginia residents with the rightslisted below:

(i)         You may have theright to know and see what Personal Data we have collected about you.

 (ii)        You may have theright to request that we correct your inaccurate Personal Data.

 (iii)       You may have theright to request that we delete the Personal Data we have collected about you.

 (iv)       You may have theright to opt out of targeted advertising (as defined under Virginia law).

 

7.8.3    To request access to ordeletion of your Personal Data, or to exercise any other privacy rights underVirginia law, please contact us at info@partnerutopia.com, or viaany other method which may be specified in the “Contact Us” section below.

 

8. EuropeanResidents.

If you are a resident of theEuropean Economic Area, we rely on our legitimate interest as described in thisPrivacy Policy to process your Personal Data. Additionally, subject to anyexemptions as provided by law, you may have certain rights regarding thePersonal Data we maintain about you. We offer you certain choices about whatPersonal Data we collect from you, how we use that information, and how wecommunicate with you. If, at any time, you wish to exercise your rights, pleasereach out to us in accordance with the “Contact Us” section below.

8.1 Right of Access.

If you ask us,we will confirm whether we are processing your Personal Data and, if so,provide you with a copy of that Personal Data along with certain other details.If you require additional copies, we may charge a reasonable fee.

8.2 Right to Rectification.

Ifyour Personal Data is inaccurate or incomplete, you are entitled to ask that wecorrect or complete it.

8.3 Right to Erase. 

Youmay ask us to erase your Personal Data in some circumstances, such as where weno longer need it, or you withdraw your consent (where applicable) and there isno other legal basis for processing.

8.4 Right to Restrict Processing. 

Youmay ask us to restrict or ‘block’ the processing of your Personal Data incertain circumstances, such as if you contest its accuracy or object to usprocessing it.

8.5 Right to Data Portability.

Youhave the right to obtain your Personal Data from us that you consented to giveus or that was provided to us as necessary in connection with our contract withyou, and if the processing is carried out by automated means.

8.6 Right to Object. 

You may askus at any time to stop processing your Personal Data, and we will do so: (a) ifwe are relying on a legitimate interest to process your Personal Data, unlesswe demonstrate compelling legitimate grounds for the processing or your data isneeded to establish, exercise, or defend legal claims; or (b) if we areprocessing your Personal Data for direct marketing and, in such case, we maykeep minimum information about you (for example, in a suppression list) asnecessary for our and your legitimate interest to ensure your opt out choicesare respected in the future and to comply with data protection laws.

8.7 Right to Withdraw Consent.

 Ifwe rely on your consent to process your Personal Data, you have the right towithdraw that consent at any time, but this will not affect any processing ofyour Personal Data that has already taken place.

8.8 Right to lodge a Complaint.

Ifyou have a concern about our privacy practices, including the way we handledyour Personal Data, you can report it to the data protection authority that isauthorized to hear those concerns.

9. Scopeof Compliance with Foreign Privacy Laws.

We do not acknowledge, nor do we agree toadhere to, privacy laws, regulations, or guidelines of any other jurisdictions,other than those of the United States of America, and such U.S. States, and,solely with respect to users’ privacy rights, the European Union. If you areaccessing our Services from a location outside of the foregoing jurisdictions,it is your responsibility to ensure that your use of the Services complies withsuch applicable foreign and local privacy laws. The privacy rights afforded tousers under foreign privacy laws, which are outside of the foregoing jurisdictions,will not be recognized or enforceable under this policy.

10.  InformationRetention.

We keepyour information for no longer than is necessary for the purposes for which itis processed. The length of time for which we retain information depends on thepurposes for which we collected and use it and/or as required to comply withapplicable laws.

11. DataProcessing and Data Transfers.

In connection with your use of the Services, we may store, process, andtransmit data in the United States of America and locations around theWorld—including those outside your country of residence. Your PersonalData, therefore, may be subject to privacy laws that are different from thosein your country of residence. In such instances, we shall ensure that thetransfer of your Personal Data is carried out in accordance with applicableprivacy laws and, in particular, that industry appropriate contractual,technical, and organizational measures are in place.

12. Security.

Wetake reasonable precautions intended to help protect your Personal Data that wecollect. Unfortunately, no system or online transmission of data is completelysecure, and we cannot guarantee the security of data transmitted across theInternet. If you believe that information you provided to us is no longersecure, please notify us immediately using the contact information providedbelow.

13. Links to Third-PartyWebsites.

The Services may include links tothird-party websites and services that we do not own or operate. When you clickthese links, you will be directed away from the Services to that third-party’swebsite. Any information you submit on that third-party’s website will besubject to that third-party’s practices and privacy policy. We encourage you toread these third-party privacy policies carefully before submitting yourinformation.

14. Children’s Privacy.

The Servicesare directed to individuals over the age of eighteen (18). We do not knowinglycollect Personal Data from individuals under the age of eighteen (18) (“Children”).If we become aware of any Children who have provided us with Personal Data, wewill take steps to delete their Personal Data. If you become aware ofinformation from Children, which has been provided to us, please contactus in accordance with the “Contact Us” section below.

15. Contact Us.

If you have questions regarding this Privacy Policy, pleasecontact us at: info@partnerutopia.com.