Privacy Policy

Private Data We Receive And Collect

The technologies offered by UPDAT (‘We’, ‘Us’, ‘Our’) amongst other purposes can be used to share information, to communicate with other people and to create new content. In doing so, data is being shared and processed and We want to ensure that your privacy is always guaranteed.

Whichever way you are sharing your data with Us, be it by creating an account, or by inputting data, we want to ensure you that your data is kept private whilst in parallel improving the quality of our services to guarantee that you remain connected with people and facilitating the sharing of information. In doing so, we prioritise the protection of your privacy.

When we process any personal data which you provide to Us we comply with all applicable law in Malta, particularly the General Data Protection Regulation (‘GDPR’) 2016/679 (as may be amended from time to time) and the Data Protection Act, Chapter 586 Laws of Malta.

Our Privacy Policy Explains:

1. 1. What data We collect and why We collect it.
   2. How We use that data.
   3. The options We offer, including how to access and update information.

Your privacy matters to Us; whether you are new to UPDAT or a long-time customer, please do take the time to get to know our practices – and if you have any questions, contact us.

Transparency and choice

We want to be as transparent as possible thus We want to be clear about what data We collect, so you can then decide what data to share and how such data shall be used. By providing personal data to Us, you consent to Us collecting, processing, using, storing and disclosing your personal information in accordance with this Privacy Policy. You are not obliged to provide personal data to Us, however, certain functions may not function efficiently if you do not, and may affect your use of this Site or the products and/or services offered on or through it.

You may also set your browser to block all cookies, including cookies associated with our services, or to indicate when a cookie is being set by Us. However, it’s important to remember that many of our services may not function properly if your cookies are disabled. For example, you may not be able to login to UPDAT or utilise other services.

Data we collect

We collect data to provide better services to all of Our users – from figuring out basic stuff like which language you speak, to more complex things like what content of Ours matters most to you

We collect information in the following ways:

1. Information you give Us. We collect information about you and your company as you register for an account with Us, create or modify your profile, use, access, or interact with our services or Our websites (including but not limited to when you upload, download, collaborate on or share content, including photos and videos). Such content includes any personal data or other sensitive information that you choose to include. For example, many of our services require you to sign up for an account with Us. When you do, we’ll ask for personal data, including your name, email address, telephone number or credit card. We may present your name, email address or image to other users in your organisation, or otherwise associated with your account in order to assist in sharing or recommendations.
2. Information We get from your use of Our services. We may collect information about the services that you use and how you use them, like when you visit a website that uses Our services, or you view and interact with Our content. This information includes:
   1. Device information – We may collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). We may associate your device identifiers or phone number with your account.
   2. Log information – When you use Our services or view content provided by Us, We may automatically collect and store certain information in server logs. This may include:
      1. details of how you used Our service, such as your search queries;
      2. Internet Protocol address;
      3. device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL; and
      4. cookies that may uniquely identify your browser or your account.
   3. Location information – When you use a location-enabled UPDAT service, We may collect and process information about your actual location, like GPS signals sent by a mobile device. We may also use various technologies to determine location, such as sensor data from your device that may, for example, provide information on nearby Wi-Fi access points and cell towers
   4. Unique application numbers – Certain services include a unique application number. This number and information about your installation (for example, the operating system type and application version number) may be sent to Us when you install or uninstall that service or when that service periodically contacts Our servers, such as for automatic updates.
   5. Local storage – We may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.
   6. Cookies and anonymous identifiers – We use various technologies to collect and store data when you visit Our services, and this may include sending one or more cookies or anonymous identifiers to your device. We also use cookies and anonymous identifiers when you interact with services we offer to our partners, such as advertising services or UPDAT features that may appear on other sites.

How We use data We collect

We may use the data We collect, including your personal data and transaction information, from all of Our services in any one or more of the locations that UPDAT has operations or otherwise conducts business for the following purposes:

1. for internal and service-related purposes, such as to provide, maintain, protect, improve, and personalise our services, to develop new ones and to protect the rights, property, or safety of UPDAT and Our users;
2. to communicate with you in order to provide you with data We think may be useful or relevant to you;
3. to promote Our services and related services;
4. to analyse information in order to offer aggregated anonymised data products to third parties;
5. to facilitate the sharing of aggregated and anonymised information with third parties, including transaction data. An example of anonymised information would be the number of times a template is used or location data, which may be used by those third parties to inform judgements about the organisation using the software, but not about any individuals whose data is processed using the software;
6. to enforce the Privacy Policy and Our terms and conditions for use of Our services and websites;
7. to monitor and analyse trends, usage, and activities in connection with Our services and for marketing or advertising purposes or to offer you tailored content;
8. to investigate and prevent fraudulent transactions, unauthorised access to or use of Our services, and other illegal or unusual activities;
9. to use the name you provide for your UPDAT profile across all of the services We offer that require a UPDAT account. In addition, we may replace past names associated with your UPDAT account so that you are represented consistently across all our services. If other users already have your email, or other information that identifies you, we may show them your publicly visible UPDAT profile information, such as your name and photo;
10. when you contact Us, to keep a record of your communication to help solve any issues you might be facing. We may use your email address to inform you about our services, such as letting you know about upcoming changes or improvements;
11. from cookies and other technologies, to improve your user experience and the overall quality of our services;
12. to combine information from one service, including personal information, into other UPDAT services – for example to make it easier to share things with people you know;
13. as otherwise stated in this Privacy Policy.

To use the information We collect, We may require our systems to access, screen capture, store, video and/or scan your information. Where appropriate or required by data protection laws, we will ask for your consent before using information for a purpose other than those that are set out in this Privacy Policy.

Retention of Personal Data

We will retain your personal data for the time necessary to provide the services we perform for you, or to achieve other purposes outlined in this Privacy Policy, and you can always request that We stop processing or delete your personal data.

We’re required to keep some of your information for certain periods of time under law. When we no longer require your information, we’ll ensure that your information is destroyed or de-identified.

We may need to retain certain personal information after we cease providing you with products or services to enforce our terms, for fraud prevention, to identify, issue or resolve legal claims and/or for proper record keeping.

Information you share

Many of our services let you share information with others. Remember that when you share information publicly, it may be indexable by search engines. Our services provide you with different options on sharing and removing your content.

Information we share

We do not share personal information with companies, organizations and individuals outside of UPDAT unless one of the following circumstances apply:

1. With your consent
   We will share personal information with companies, organizations or individuals outside of UPDAT when we have your consent to do so.
2. With account administrators
   If your account is managed for you by an organisation administrator then your organisation’s administrator and resellers who provide user support to your organization will have access to your information (including your email and other data). Your account administrator may be able to:
   1. view statistics regarding your account;
   2. change your account password;
   3. suspend or terminate your account access;
   4. access or retain information stored as part of your account;
   5. receive your account information in order to satisfy applicable law, regulation, legal process or enforceable governmental request;
   6. restrict your ability to delete or edit information.
3. With Third Party Service Providers
   We may disclose personal information to:
   1. third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, and payment systems operators;
   2. our existing or potential agents or business partners;
   3. third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you.
4. To address fraud, security or technical issues
   We will share your personal information with trusted third parties where necessary to detect, prevent or otherwise address fraud, security or technical issues.
5. For legal reasons
   We may disclose your information if required by applicable law, regulation or as part of any actual or prospective legal process (including if reasonably necessary to enforce applicable Terms of Service or in order to establish, exercise or defend our legal rights). If we receive a request from a regulatory body or law enforcement agency, and if permitted under the GDPR law, we may disclose certain information to such bodies or agencies.
6. Merger or acquisition
   If we merge with or are acquired by another business, we may share your personal information with the new owners of the business and their advisors. We will continue to ensure the confidentiality of any personal information and give affected users notice (for example, via a message to the email address associated with your account) before personal information is transferred or becomes subject to a different privacy policy.

We may share aggregated, non-personally identifiable information publicly and with our partners – like publishers, advertisers or connected sites. For example, we may share information publicly to show trends about the general use of our services. This could also include government bodies, industry groups, insurers and educational/training facilities.

Information Security

We have put in place robust measures regarding the security of the information we collect and store about you (including through the use of network and database security measures) and will use our reasonable endeavours to protect your personal data from unauthorised access to or unauthorised alteration, disclosure or destruction. In particular:

1. We encrypt many of our services using Secure Sockets Layer (SSL) or Transport Layer Security (TLS).
2. We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems.
3. We restrict access to personal information to our employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
4. We have multiple authentication and access control measures to ensure data is only accessed by authorised personnel

The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our servers via third party networks; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Application

Our Privacy Policy applies to all of the services offered by UPDAT and its affiliates, including services offered on other sites, but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you in search results, sites that may include UPDAT services, or other sites linked from our services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our services.

Enforcement

We regularly review our compliance with our Privacy Policy. We also adhere to several self regulatory frameworks. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.

Restriction

You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.

Access

You may request details of the personal information that we hold about you. An administrative fee may be payable for the provision of such information. In certain circumstances, as set out in the Privacy Act 1988 (Cth), we may refuse to provide you with personal information that we hold about you.

Correction

If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

Other Websites

Please note that clicking on links and banner advertisements on our websites can result in your browser accessing a third party website, where data privacy practices are different to that of UPDAT.

We are not responsible for, and have no control over, information that is submitted to or collected by these third parties and you should consult their privacy policies.

Changes

We may revise this Privacy Policy from time to time and will post the most current version on our website. If a revision meaningfully reduces your rights or involves a material change to our processing your personal information, we will notify you.

Contact

If you have any enquiries or if you would like to contact us about our processing of your personal information, please contact us by any of the methods below. When you contact us, we will ask you to verify your identity.

Contact name: Privacy Officer

Email: [email protected]