10/30/2024

This Privacy Notice applies to the processing of personal information by ROI Manufacturing Inc., d/b/a Uptool (“Uptool”,” “we,” “us,” or “our”) including on our website available at app.uptool.com and our other online or offline offerings which link to, or are otherwise subject to, this Privacy Notice (collectively, the “Services”).

1. UPDATES TO THIS PRIVACY NOTICE

2. PERSONAL INFORMATION WE COLLECT

3. HOW WE USE PERSONAL INFORMATION

4. HOW WE DISCLOSE PERSONAL INFORMATION

5. YOUR PRIVACY CHOICES

6. RETENTION OF PERSONAL INFORMATION

7. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

8. CHILDREN’S PERSONAL INFORMATION

9. THIRD-PARTY WEBSITES/APPLICATIONS

10. CONTACT US

1. UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Notice on our website, and/or we may also send other communications.

2. PERSONAL INFORMATION WE COLLECT

We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.

A. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us. 

• Account Information: We may collect personal information in connection with the creation or administration of your account. This personal information may include, but is not limited to, your name, email address, phone number, personal information about your customers, leads, or potential customers when you upload or provide us with access to this information, and other information you store with your account.

• Purchases: We may collect personal information and details associated with your purchases,

including payment information. Any payments made via our Services are processed by third-party

payment processors. We do not directly collect or store any payment card information entered

through our Services, but we may receive information associated with your payment card

information (e.g., your billing details).• Your Communications with Us. We, and our service providers, may collect the information you

communicate to us, such as through email or our web chat tool.

• Surveys: We may contact you to participate in surveys. If you decide to participate, we may collect

personal information from you in connection with the survey.

• Interactive Features: We and others who use our Services may collect personal information that

you submit or make available through our interactive features (e.g., messaging features,

commenting functionalities, forums, blogs, and social media pages). Any information you provide

using the public sharing features of the Services will be considered “public.”

• Sweepstakes or Contests: We may collect personal information you provide for any sweepstakes

or contests that we offer. In some jurisdictions, we are required to publicly share information of

sweepstakes and contest winners.

• Conferences, Trade Shows, and Other Events: We may collect personal information from

individuals when we attend or host conferences, trade shows, and other events.

• Business Development and Strategic Partnerships: We may collect personal information from

individuals and third parties to assess and pursue potential business opportunities.

• Job Applications: If you apply for a job with us, we will collect any personal information you

provide in connection with your application, such as your contact information and CV.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use the Services.

• Device Information: We may collect personal information about your device, such as your

Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser

or device information, Internet service provider, and location information (including, as

applicable, approximate location derived from IP address and precise geo-location information).

• Usage Information: We may collect personal information about your use of the Services, such as

the pages that you visit, items that you search for, the types of content you interact with,

information about the links you click, the frequency and duration of your activities, and other

information about how you use the Services.

• Cookie Notice (and Other Technologies): We, as well as third parties, may use cookies, pixel tags,

and other technologies (“Technologies”) to automatically collect personal information through

your use of the Services.

   - Cookies: Cookies are small text files stored in device browsers.

   - Pixel Tags/Web Beacons: A pixel tag (also known as a web beacon) is a piece of code

embedded in the Services that collects personal information about use of or engagement

with the Services. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

C. Personal Information Collected from Third Parties

We may collect personal information about you from third parties. These third parties may include, but are not limited to, the examples described below.

● Third-Party Services. If you access or interact with the Services using a Third-Party Service (defined below), we may collect personal information along with information associated with your account from that Third-Party Service that you have made available via your privacy settings. This may include, but is not limited to, contact details about you, contents of your emails when

you provide us with access to your email inbox, and personal information about your customers, leads, or potential customers when you upload or provide us with access to this information.

The use of information received from the Google Workspace APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. Google Workspace APIs are not used to develop, improve, or train generalized AI and/or ML models.

Uptool will use commercially reasonable efforts to implement and maintain safeguards designed to protect information that it collects from Google Workspace APIs, including sensitive data. Examples of the safeguards we may use include, but are not limited to, encryption and access controls.

To the extent this Privacy Notice conflicts with the Google API Services User Data Policy, the Google API Services User Data Policy shall control with respect to our processing of information that is received from the Google Workspace APIs.

● Other Users. Users of the Services may upload or otherwise provide personal information about

others.

● Publicly Available Information. We may collect personal information from publicly available sources.

3. HOW WE USE PERSONAL INFORMATION

We use personal information for a variety of business purposes, including to provide the Services, for

administrative purposes, and to provide you with marketing materials, as described below.

A. Provide the Services

We use personal information to fulfill our contract with you and provide the Services, such as:

• Managing your information;

• Providing access to certain areas, functionalities, and features of the Services;

• Answering requests for support;

• Communicating with you;• Sharing personal information with third parties as needed to provide the Services;

• Processing your financial information and other payment methods for products and Services

purchased;

• Processing applications if you apply for a job we post on our Services; and

• Allowing you to register for events.

B. Administrative Purposes

We use personal information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including

marketing research), network and information security, and fraud prevention;

• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity,

and prosecuting those responsible for that activity;

• Carrying out analytics;

• Measuring interest and engagement in the Services;

• Improving, upgrading, or enhancing the Services;

• Developing new products and services;

• Creating de-identified and/or aggregated information. If we create or receive de-identified

information, we will not attempt to re-identify such information, unless permitted by, or required

to comply with, applicable laws;

• Ensuring internal quality control and safety;

• Authenticating and verifying individual identities, including requests to exercise your rights under

this Privacy Notice;

• Debugging to identify and repair errors with the Services;

• Auditing relating to interactions, transactions, and other compliance activities;

• Enforcing our agreements and policies; and

• Carrying out activities that are required to comply with our legal obligations.

C. Marketing

We may use personal information to tailor and provide you with marketing and other content. We may provide you with these materials as permitted by applicable law.

If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.

D. With Your Consent or Direction

We may use personal information for other purposes that are clearly disclosed to you at the time you

provide personal information, with your consent, or as otherwise directed by you.

4. HOW WE DISCLOSE PERSONAL INFORMATION

We disclose personal information to third parties for a variety of business purposes, including to provide the Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide the Services 

We may disclose any of the personal information we collect to the categories of third parties described below.

• Service Providers: We may disclose personal information to third-party service providers that assist us with the provision of the Services. This may include, but is not limited to, service providers that

provide us with hosting, customer service, analytics, marketing services, IT support, and related services. In addition, personal information and chat communications may be disclosed to service

providers that help provide our chat features.

• Other Users You Share or Interact With: The Services may allow Uptool users to share personal

information or interact with other users of the Services.

• Third-Party Services You Share or Interact With: The Services may link to or allow you to interface,

interact, share information with, direct us to share information with, access and/or use third-party

websites, applications, services, products, and technology (each a “Third-Party Service”).

Any personal information shared with a Third-Party Service will be subject to the Third- Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.

• Business Partners: We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with

business partners with whom we jointly offer products or services.

Once your personal information is shared with our business partner, it will also be subject to our

business partner’s privacy policy. We are not responsible for the processing of personal information

by our business partners.

• Uptool Customers (Authorized Users Only): In cases where you use our Services as an employee,

contractor, or other authorized user of an Uptool customer, that customer may access information

associated with your use of the Services including usage data and the contents of the communications

and files associated with your account. Your personal information may also be subject to the Uptool

customer’s privacy policy. We are not responsible for the Uptool customer’s processing of your personal information.

• Affiliates: We may share your personal information with our corporate affiliates.

• Advertising Partners: We may share your personal information with third-party advertising partners.

These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie

identifiers, page(s) visited, location, time of day). These advertising partners may use this information

(and similar information collected from other services) for purposes of delivering personalized

advertisements to you when you visit digital properties within their networks. This practice is

commonly referred to as “interest-based advertising”, “personalized advertising”, or “targeted

advertising.”

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or

national security requests and legal process, such as a court order or subpoena; protect your, our, or

others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.

5. YOUR PRIVACY CHOICES

Your Privacy Choices: The privacy choices you may have about your personal information are described below.

• Deletion of Information Collected the Google Workspace APIs: To request deletion of your

information that we have collected from the Google Workspace APIs, please email us as forth in

“Contact Us” below.

• Email Communications: If you receive an unwanted email from us, you can use the unsubscribe

functionality found at the bottom of the email to opt out of receiving future emails. Note that you

will continue to receive transaction-related emails. We may also send you certain non-

promotional communications regarding us and the Services, and you will not be able to opt out

of those communications (e.g., communications regarding the Services or updates to this Privacy

Notice).

• Text Messages: If you receive an unwanted text message from us, you may opt out of receiving

future text messages from us by following the instructions in the text message you have received

from us or by otherwise contacting us as set forth in “Contact Us” below.

• “Do Not Track”: Do Not Track (“DNT”) is a privacy preference that users can set in certain web

browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms

transmitted by web browsers.

• Cookies: You may stop or restrict the placement of Technologies on your device or remove them

by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Services may not work properly.

The online advertising industry also provides mechanisms that may allow you to opt out of

receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative, the Digital Advertising Alliance, and the European

Digital Advertising Alliance. Please note you must separately opt out in each browser and on each device.

6. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Notice for as long as you use the Services, or as necessary to fulfill the purpose(s) for which it was collected, provide the Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes

through other means.

7. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

All personal information processed by us may be transferred, processed, and stored anywhere in the

world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.

8. CHILDREN’S PERSONAL INFORMATION

The Services are not directed to children under 13, and we do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has uploaded personal information to the Services in violation of applicable law, you may contact us as described in “Contact Us” below.

9. THIRD-PARTY WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications and other websites/applications may

reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

10. CONTACT US

If you have any questions about our privacy practices or this Privacy Notice, please email us at:

info@uptool.com