Privacy Policy
Your Privacy Matters
At upto25, our fundamental philosophy is “members first.” That value powers all of the decisions we make, including how we gather and respect your personal information.
We’ve crafted the policy below to be as clear and straightforward as possible. Our aim is for you—our members—to always feel informed and empowered with respect to your privacy on upto25.
Introduction
Last revised on May 25, 2018
We are a social network and online platform for professionals and companies.
upto25’s mission is to connect the world’s VSEs (Very Small Entities) to allow them to be more productive and successful. Our registered users (“Members”) share their professional identities, engage with their network, exchange knowledge and company’s and professional insights, post and view relevant content, and take advantage of business opportunities. Content on some of our services is also visible to unregistered viewers (“Visitors”). We believe that our services allow our Members to effectively compete and achieve their business objectives. The cornerstone of our business is to focus on our Members first.
We protect any Company and professional information using industry-standard safeguards.
We may ONLY share your information with your EXPLICIT consent or as required by law, and we will always let you know when we make significant changes to this Privacy Policy.
Having your trust is our main concern, and therefore, we adhere to the following principles to protect all Members privacy:
- We protect all business and personal information and will only provide it to third parties: (1) with your consent; (2) where it is necessary to carry out your instructions; (3) as reasonably necessary in order to provide our features and functionality to you; (4) when we reasonably believe it is required by law, subpoena or other legal process; or (5) as necessary to enforce our User Agreement or protect the rights, property, or safety of upto25, our Members and Visitors, and the public.
- We have implemented appropriate security safeguards designed to protect your information in accordance with industry standards.
This Privacy Policy applies to upto25.net and the upto25 platform technology, any advertising platform and all other upto25 websites, apps, developer platforms and other products and services (collectively the “Services”). We may modify this Privacy Policy from time to time, and if we make material changes to it, we will provide notice through our Service, or by other means so that you may review the changes before you continue to use our Services. If you object to any changes, you may close your account. Continuing to use our Services after we publish or communicate a notice about any changes to this Privacy Policy means that you are consenting to the changes.
1. What information we collect
1.1 Data Controllers
Our Privacy Policy applies to any Member or Visitor. We collect information when you use our Services to offer you a personalized and relevant experience, including growing your network and enabling business opportunities.
The personal information provided to or collected by our Services is controlled by Softwcare S.L. located at Avenida Atlántida 100, 1-izq 36208 Vigo, Spain strictly following the General Data Protection Regulation (GDPR) and the Spanish LOPD (Law for data Protection, obligued to all Spanish companies and people, followed by The Spanish data protection Agency). If you have any concern about providing information to us or having such information displayed on our Services or otherwise used in any manner permitted in this Privacy Policy and the User Agreement, you should not become a Member, visit our websites, apps or otherwise use our Services. If you have already registered, you can close your accounts.
We collect your private information in the following ways:
1.2 Registration
When registering (create an account) with us, we collect information (including name, name of company, country, email address, and password).
To register on upto25, you must provide us with at least your Company name and/or your personal name (as representative person of your copany or as assessor), email, address and/or mobile number, your country, and a password and agree to our User Agreement and this Privacy Policy, which governs how we treat your information. Additional information may be requested to be added during the registration flow (for example, your postal code, job title, and company size) to help you build your profile and to provide you more customized services (for example: language-specific profile pages, guides, content). You understand that, by registering, we and others will be able to identify you by your upto25 profile. We may also ask for your credit card details if you purchase certain additional services.
1.3 Profile Information
We collect information when you fill out a profile. A complete upto25 profile that includes Company and professional details – like job title – helps you get found by other VSEs for opportunities.
After you register, you may choose to provide additional information on your upto25 profile. You can list honors, awards, professional affiliations, Group memberships, networking objectives, companies or individuals that you follow, and other information including content. Subject to the settings you choose, your connections may provide recommendations and endorsements of you. Providing additional information enables you to derive more benefit from our Services by helping you express your professional identity; find other VSEs, opportunities, and information; and business opportunities. It also enables us to serve you ads and other relevant content on and off of our Services.
1.4 Customer Service
We collect information when you contact us for customer support.
When you contact our customer support services (e.g. on our Help Center), we may have to access your mensages, Groups and other contributions to our Services and collect the information we need to categorize your question, respond to it, and, if applicable, investigate any breach of our User Agreement or this Privacy Policy. We also use this information to track potential problems and trends and customize our support responses to better serve you. We do not use this information for advertising.
1.5 Using the upto25 site and Applications
We collect information when you visit our Services.
We collect information when you use (whether as a Member or a Visitor) our websites, applications, our platform technology or other Services. For example, we collect information when you view or click on and off our Services, perform a search, join and participate in groups, participate in polls, view content on videos, share articles on our Services or make a review or a comment to a content of our web. If you are logged in on upto25.net, or one of our cookies on your device identifies you, your usage information and the log data described in Section 1.9 of this policy, such as your IP address, will be associated by us with your account. Even if you’re not logged into a Service, we log information about devices used to access our Services, including IP address.
1.6 Using Third-Party Services and Visiting Third-Party Sites
We collect information when you use your account to sign in to other sites or services, and when you view web pages that include our plugins and cookies.
We receive information when you use your account to log in to a third-party website or application. Also, when you visit a third-party site that embeds our social plugins we receive information that those pages have loaded in your web browser. If you are logged in as registered when you visit sites with our plugins, we use this information to recommend tailored content to you. We will use this information to personalize the functionality we provide on third-party sites, including providing you insights from your professional network and allowing you to share information with your network. Our retention of this data is addressed in Section 3.2. We may provide reports containing aggregated impression information to companies hosting our plugins and similar technologies to help them measure traffic to their websites, but no personal data.
You also allow us to receive information about your visits and interaction with the sites and services of our partners that include our cookies and similar technologies, unless you opt out. If you are not registered, we rely on the same online terms with the registered ones.
1.7 Cookies
We use cookies and similar technologies to collect information.
As describe in our Cookies Policy, We use cookies and similar technologies to help us recognize you across different Services, learn about your interests both on and off our Services, improve your experience, increase security, measure use and effectiveness of our Services, and serve advertising. You can control cookies through your browser settings and other tools. By visiting our Services, you consent to the placement of cookies and beacons in your browser and HTML-based emails in accordance with this Privacy Policy.
1.8 Advertising Technologies and Web Beacons
We do not share your personal information with any third-party advertisers or ad networks for advertising without your EXPLICIT permission. Note that, as described in Section 2.5, your profile is visible to other Members and through public search depending on your settings. Also, advertising partners may associate personal information collected by the advertiser directly from you with our cookies and similar technologies. In such instances, we contractually require such advertisers to obtain your explicit opt-in consent before doing so.
1.9 Log Files, IP Addresses, and Information about Your Computer and Mobile Device
We collect information from the devices and networks that you use to access our Services.
When you visit or leave our Services (whether as a Member or Visitor) by clicking a hyperlink or when you view a third-party site that includes our plugin or cookies (or similar technology), we automatically receive the URL of the site from which you came or the one to which you are directed. We also receive the internet protocol (“IP”) address of your computer or the proxy server that you use to access the web, your computer operating system details, your type of web browser, your mobile device (including your mobile device identifier provided by your mobile device operating system), your mobile operating system (if you are accessing upto25 using a mobile device), and the name of your ISP or your mobile carrier.
1.10 Other
We are constantly innovating to improve our Services, which means we may create new ways to collect information on the Services.
Our Services are a dynamic, innovative environment, which means we are always seeking to improve the Services we offer you. We often introduce new features, some of which may result in the collection of new information. Furthermore, new partnerships or corporate acquisitions may result in new features, and we may potentially collect new types of information. If we start collecting substantially new types of personal information and materially change how we handle your data, we will modify this Privacy Policy and notify you in accordance with Section 4.2.
2. How we use your personal information
2.1 Consent to upto25 Processing Information About You
You agree that information you provide on your profile can be seen by others and used by us as described in this Privacy Policy and our User Agreement.
The personal information that you provide to us may reveal or allow others to identify aspects that are not expressly stated on your profile. By providing personal information to us when you create or update your account and profile, you are expressly and voluntarily accepting the terms and conditions of our User Agreement and freely accepting and agreeing to our processing of your personal information in ways set out by this Privacy Policy. Supplying to us any information deemed “sensitive” by applicable law is entirely voluntary on your part. You can withdraw or modify your consent to our collection and processing of the information you provide at any time, in accordance with the terms of this Privacy Policy and the User Agreement, by changing your account settings or your profile on upto25 or by closing your upto25 account.
2.2 upto25 Communications
We communicate with you using upto25 messaging, email, and other ways available to us. We may send you messages relating to the availability of the Services, security, or other service-related issues. We also may send promotional messages to your upto25 inbox. You can change your email settings at any time.
We communicate with you through email, notices posted on the upto25 websites, messages to your upto25 inbox, and other means available through the Services, including mobile text messages. Examples of these communications include: (1) welcome and engagement communications – informing you about how to best use our Services, new features, updates about other Members you are connected to and their actions, etc.; (2) service communications – these will cover service availability, security, and other issues about the functioning of our Services; (3) promotional communications – these include email and other messages (messages are only delivered to your upto25 inbox), and may contain promotional information directly or on behalf of our partners, including job opportunities and information from companies that are hiring. These messages will be sent to you based on your profile information and messaging preferences. We track the open rate of your messages to provide your messages acceptance score. You may change your email and contact preferences at any time by signing into your account and changing your upto25 settings. You can also opt out of promotional messages by sending a request to upto25 Help Center.
Please be aware that you cannot opt out of receiving service messages from us.
2.3 User Communications
With certain communications you send on our Services, the recipient can see your name, the Company name, and some network information.
Many communications that you initiate through our Services (for example, an invitation sent to a non-Member) will list your name in the header of the message. Messages you initiate may also provide the recipient with aggregate information about your network (for example, how many contact are in your network). Other communications that you initiate through the Services, like a request for an introduction, will list your name as the initiator but will never include your personal email address contact information. Once you have connected with an individual, regardless of who sent the invitation, your contact information will be shared with that individual.
We use automatic scanning technology to help protect you and other Members. Such technology checks links and other content in your messages, network updates and Group contributions to help us identify and block malicious links and malware, reduce spam and optimize the delivery of our Services.
2.4 Service Development; Customized Experience
We use the information and content you provide to us to conduct research and development and to customize your experience and try to make it relevant and useful to you.
We use information and content that you and other Members provide to us to conduct research and development for the improvement of our Services in order to provide you and other Members and Visitors with a better, more intuitive experience and drive membership growth and engagement on our Services and to help connect professionals to economic opportunity.
We also customize your experience and the experiences of others on our Services. For example, when you sign in to your account, we may display the names and photos of new Members who have recently joined your network or recent updates from your connections and companies you follow. We try to show you content, such as news and presentations that is relevant to you, your industry. We also use Members information and content for invitations and communications promoting our Services that are tailored to the recipient.
2.5 Sharing Information with Third Parties
Any information you put on your profile and any content you post on upto25 may be seen by others.
We don’t provide any of your non-public information (like your email address) to third parties without your consent, unless required by law, or as described in this seccion and sections 2.11 of this Policy.
Other people may find your upto25 profile information through search engines or use services like Twitter in conjunction with your upto25 account.
The visibility of your profile to other Members depends on your degree of connection with the viewing Member, the subscriptions they may have, their usage of the Services, access channels and search types (e.g. by name or by keyword). For example, Premium connections can see your full profile and contact information. Others have more limited access.
We do not rent or sell personal or company information that you have not posted on our Services, except as described in this Privacy Policy. We will not disclose personal information that is not published to your profile or generated through engagement with our other services, except to carry out your instructions (for example, to process payment information) or unless we have your separate consent, unless we have a good faith belief that disclosure is permitted by law or is reasonably necessary to: (1) comply with a legal requirement or process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures; (2) enforce this Privacy Policy or our User Agreement; (3) respond to claims of a violation of the rights of third parties; (4) respond to Member service inquiries; or (5) protect the rights, property, or safety of upto25, our Services, our Members, Visitors, or the public. See Section 2.11 for additional details about our compliance with legal requests for information.
We support middleware providers that offer archiving solutions to firms subject to legal and regulatory archiving requirements, which, with your permission, facilitate the archiving of your communications and other activity by a third party . For upto25 implementation and third-party product integrations it may result in displaying some of your personal information outside of our Services. For example, when you post content to a Group that is open for public discussion, your content, including your name as VSE representative, may be displayed in search engine results.
Also, if you have opted to bind any of your Service accounts to your Twitter, Facebook or other similar account, you can easily share content from our Services to these third party services, in accordance with your account settings (which you may change at any time) and respective policies of these third parties. Further, we allow third parties to look-up profile information (subject to your privacy settings) using your email address or company name information through its profile API (see Section 2.6. below).
Third parties (for example, your email provider) may give you the option to upload certain information in your contacts stored with us onto their own service. If you choose to share your contacts in this way, you will be granting your third party provider the right to store, access, disclose and use these contacts in the ways described in such third party’s terms and privacy policy.
2.6 Third Parties using upto25 Platform Services
We work with developers to build Platform Applications using our developer tools. Whether you use Platform Applications is up to you.
If you have given a Platform Application access to your upto25 account, you can revoke that permission anytime. Also, you can opt out of providing information to developers through your connections.
We collaborate with and allow third parties to use our developer platform to offer services and functionality in conjunction with our Services. These external developers have either negotiated an agreement to use our platform or have agreed to our self-service API terms in order to build applications (“Platform Applications”). Both negotiated agreements contain restrictions on how they may access, store, and use the personal information you provide to us.
If you choose to use a Platform Application, you will be asked to confirm acceptance of the privacy policy and user agreement of external developer. To revoke permission granted to a Platform Application, please visit your settings. Note, however, that even if you revoke the permission granted to a Platform Application, your connections may still be using the Platform Application, so the Platform Application may still have access to certain information about you, just as your connections do.
2.7 Search
Our Services help you search for other professionals, companies, groups, professional content.
You can search for Members, information about companies, and community content from Groups on our Services. For example, you can find Members with particular expertise or experience, or Members that you may know from your industry or profession. You can also find information about companies. You can also find content from Groups. We use personal information from our Services, including Member profiles, Groups content, and Company Pages, to inform and refine our search service.
2.8 Groups
You are responsible for any information you post on our Services, and this content will be accessible to others.
If you participate in Groups, share content on your network update stream, or import a blog or other content, you should be aware that any information you choose to disclose using these services can be read, collected, and used by other Members in these forums, developers, , including third parties. upto25 is not responsible for the information you choose to submit in these forums. Your Groups contributions are typically searchable on our Services and some content in Groups may be public and searchable on the Internet if the group owner has not closed the group for public discussions. You can identify privatre or public groups in the bottom rigth of the group frame. You can remove your Groups posts at any time. However, others may have copied and used the information that you shared.
2.9 Testimonials
If you provide any testimonials about our goods or services, we may post those testimonials you place in connection with our promotion of these services to third parties. Testimonials may include your name and other personal information that you have provided.
2.10 Premium services
We offer a premium service, which can be used to search for, organize, and communicate with potential connections or offer business opportunities. In some cases we allow the export of public profile information.
2.11 Compliance with Legal Process and Other Disclosures
It is possible that we may need to disclose personal information, profile information, or information about your activities as a Member or Visitor when required by law, subpoena, or other legal process, or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce the User Agreement, investigate and defend ourselves against any third-party claims or allegations, or protect the security or integrity of our Service; or (3) exercise or protect the rights, property, or safety of upto25, our Members, personnel, or others. We attempt to notify Members about legal demands for their personal information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. In light of our principles, we may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but do not commit to challenge every demand. To find out more about how we engage with government requests for data see the Spanish Data Protection Agency.
2.12 Disclosures to Others as the Result of a Change in Control or Sale of upto25
If there is a change in control or sale of all or part of upto25 platform, we may share your information with a third party, who will have the right to use that information in line with this Privacy Policy.
We may also disclose your personal information to a third party as part of a sale of the assets of upto25, a subsidiary, or division, or as the result of a change in control of the platform or one of its affiliates, or in preparation for any of these events. Any third party to which we transfers or sells our assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy.
2.13 Service Providers
We may employ third party companies and individuals to facilitate our Services (e.g. maintenance, analysis, audit, marketing and development).
These third parties have limited access to your information only to perform these tasks on our behalf and are obligated to upto25 not to disclose or use it for other purposes.
2.14 Data Processing Outside Your Country
We may process your information outside the country where you live.
We may transfer your information and process it outside your country of residence, wherever upto25, its affiliates and service providers operate.
Your Choices & Obligations
3.1 Rights to Access, Correct, or Delete Your Information, and Closing Your Account
You can access and change your upto25 information at any time by editing your profile, deleting content that you have posted, or by closing your account. You can also ask us for additional information we may have about your account.
You have a right to (1) access, modify, correct, or delete your personal information controlled by upto25 regarding your profile, (2) change or remove your content, and (3) close your account. You can request your personal information that is not viewable on your profile or readily accessible to you (for example, your IP access logs) through upto25‘s Help Center. You have the right to request the rectification of inaccurate data or, where appropriate, request its deletion when, among other reasons, the data is no longer necessary for the purposes that were collected. If you close your account(s), your information will generally be removed from the Service within 24 hours. We generally delete closed account information and will de-personalize any logs or other backup information through the deletion process within 30 days of account closure, except as noted below. To unsubscribe, just send us an email requesting the closure of your account (see section 6).
Likewise, you can exercise the right to the portability of the data, as well as withdraw the consents provided at any time, without affecting the legality of the treatment based on the consent prior to its withdrawal.
Please note: Information you have shared with others (for example, through messages, network updates, content sharing, or Groups) or that others have copied may also remain visible after you have closed your account or deleted the information from your own profile. Groups content associated with closed accounts will show an unknown user as the source. In addition, you may not be able to access, correct, or eliminate any information about you that other Members copied or exported out of our Services, because this information may not be in our control.
3.2 Data Retention
We retain the personal information you provide while your account is in existence or as needed to provide you services.
We may retain your personal information even after you have closed your account if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between Members, prevent fraud and abuse, or enforce this Privacy Policy and our User Agreement. We may retain personal information, for a limited period of time, if requested by law enforcement. Our Customer Service may retain information for as long as is necessary to provide support-related reporting and trend analysis only, but we generally delete or de-personalize closed account data consistent with Section 3.1., except in the case of our plugin impression data (i.e., the information that you visited on sites carrying our social plugin, but which you did not click on), which we de-personalize within 7 days (although we do maintain 30 days worth of webserver logs for security, debugging, and site stability purposes only) by creating aggregate data sets that cannot be traced back to individuals.
Important Information
4.1 Minimum Age
You have to meet upto25’s minimum age requirements to create an account.
As described in Section 2.1 of the User Agreement, persons must be of Minimum Age to use upto25.
4.2 Changes to this Privacy Policy
We will notify you when we change this Privacy Policy.
We may change this Privacy Policy from time to time. If we make significant changes in the way we treat your personal information, or to the Privacy Policy, we will provide notice to you on the Services or by some other means, such as email. Please review the changes carefully. If you agree to the changes, simply continue to use our Services. If you object to any of the changes to our terms and you no longer wish to use our Services, you may close your account(s). Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. Using our Services after a notice of changes has been communicated to you or published on our Services shall constitute consent to the changed terms or practices.
4.3 Security
We take privacy and security seriously and have enabled HTTPS access to our site, in addition to existing SSL access over mobile devices. Also, please know that the Internet is not a secure environment, so be careful and select strong passwords.
We have implemented security safeguards designed to protect the private and personal information that you provide in accordance with industry standards. Access to your data on our Services is password-protected, and data such as credit card information is protected by SSL encryption when it is exchanged between your web browser and the Services. We also offer secure https access to the upto25.net website. To protect any data you store on our servers, we also regularly monitor our system for possible vulnerabilities and attacks, and we use a tier-one secured-access data center. However, since the Internet is not a 100% secure environment, we cannot ensure or warrant the security of any information that you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that emails, instant messaging, with other Members are not encrypted, and we strongly advise you not to communicate any confidential information through these means. Please help keep your account safe by using a strong password.
How to Contact Us
If you have questions or comments about this Privacy Policy, or unsubscribe, please contact us online (using the web or email upto25@upto25.net) or by physical mail at:
Softwcare S.L.
Attn: Softwcare S.L. – upto25
calle Sangenjo 12, 4-C
28034 Madrid
Spain
Finally, we inform you that you can contact the Spanish Data Protection Agency and other competent public bodies for any claim arising from the processing of your personal data.