Privacy Policy

Effective from 28 May, 2017

Updated 25 May, 2018

Introduction

Upleap's privacy policy helps you understand what information we do and don't collect at Upleap, how Upleap uses this information, and the choices available to you. This privacy policy has been updated to reflect the new General Data Regulation Protection (GDPR) (EU) 2016/678 act implemented on 25 May, 2018.

The responsible body of data protection:

MKN Media Ltd.
Unit Level 13(A), Main Office Tower
Financial Park Labuan, Jalan Merdeka
87000 FEDERAL TERRITORY OF LABUAN
Federal Territory of Labuan

Appointed Data Protection Officer / Data Controller: Ahmad Khan

When we use the words "Upleap," "we,", "our," or "us" throughout this policy, we're referring to Upleap, which is the company that employs account managers to provide you with the services listed on our website. When we talk about "services" in this policy, we are referring explicitly to the actions our subcontracted account managers commit in order to help you grow your social media accounts.

By using the Services we provide, you agree to be bound by the Terms & Conditions outlined on our website.

Types of Data Collected

Types of Data collected Among the types of Personal Data that this Website collects, by itself or through third parties, there are: email address, Cookies, Usage Data, first name, last name and country.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website. Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Data Controller.

Any use of Cookies – or of other tracking tools – by this Website or by the Data Controllers of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party's consent to provide the Data to the Data Controller.

Customer Data

Any content and information submitted by our registered users in order to help our account managers provide Services are collected and referred to in this policy as "Customer Data." While Upleap collects or processes Customer Data, it does so on behalf of the customer. This means that Customer Data is used to help our subcontracted account managers provide the best service they can. Upleap does not trade, misuse, or expose Customer Data outside of the company. Certain Customer Data is accessible to subcontracted account managers but is handled discreetly and within strict parameters mentioned between the company and the subcontracted manager. This means Customer Data is handled safely.

To improve our Services. We look into how our customers navigate across our dashboard portal in order to inform our account managers, allowing them to provide better more accurate Services to the Upleap user.

To maintain better support. When contacted with a problem, Upleap uses the information a customer has provided to respond.

Billing purposes. When account data provides billing information, Upleap uses this to accuratenly account for billing and payments.

How Customer Data is collected is specified in the Section § Information on Personal Data Processing

Website Visitor Data

Any content and information consented and submitted by our website visitors in order to help Upleap better tailor off-site experiences, of which may include advertisements (remarketing). While Upleap collects or processes Website Visitor Data, it does so with explicit consent of the Website Visitor. Upleap does not trade, misuse, or expose Website Visitor Data outside of the company. Certain Website Visitor Data may be used to improve the Company's understanding of its target audience. Website Visitor Data is anonymized unless specified.

We use miscellaneous types of information when we provide Services to our Website Visitors. Uses include:

To improve our Services. We look into how our website visitors navigate across our website in order to provide better, more accurate Services.

To maintain better support. When contacted with a query, Upleap uses the information a website visitor has provided to respond.

How Website Visitor Data is collected is specified in the Section § Information on Personal Data Processing

Data Processing

How Data Is Processed

Upleap takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Upleap, in some cases, the Data may be accessible to certain employees in charge and the Data Controller, who are involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Data Controller. The updated list of these parties may be requested from Upleap at any time.

Legalities of Data Processing

Upleap may process Personal Data relating to Users provided one of the following is applicable:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Data Controller may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Data Controller;
  • processing is necessary for compliance with a legal obligation to which the Data Controller is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Data Controller
  • processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party.

Upleap and its Data Protection Officer can and will gladly help clarify the specific legal basis that applies to said processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Where Data is Processed

The Data is processed at the Data Controller's operating offices and in any other places where the parties involved in the processing are located. Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

If broader protection standards are applicable, Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Data Controller to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Data Controller using the information provided in the contact section.

Data Retention

Personal Data shall be processed and stored for as long as required by the legitimate purpose they have been collected for.

Information on Personal Data Processing

The Company collects Personal Data in and through the use of the following services:

Analytics

Upleap uses Analytics platforms to monitor its web traffic and better understand behavior of the User.

GOOGLE ANALYTICS (GOOGLE INC)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States - Opt Out Here

Contact With User

Upleap gets in touch with Website Visitors and/or Users who opted-in to using our service or receiving a newsletter..

MAILING LISTS (MAILERLITE, SENDGRID, MAILCHIMP)

By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase.

Personal Data collected: Country, Email Address, First & Last Name

Place of processing: United States - Opt out via email Unsubscribe link.

Displaying Content From External Platforms

You are able to view content on our website in and through services provided by external platforms. External platforms may still collect web traffic data for the pages where the service is installed, even when Users do not use it.

GOOGLE FONTS (GOOGLE INC.)

Google Fonts is a typeface visualization service provided by Google Inc. that allows this Website to incorporate content of this kind on its pages.

Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.

Place of processing: United States - See their Privacy Policy attached

Payment Providers

Payment providers enable Upleap to process Credit Card and Debit Card purchases. Upleap shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction. Transactions are created, conducted, and processed on a third-party website.

PAYPAL (PAYPAL HOLDINGS INC.)

PayPal is a payment processor offered by PayPal Holdings Inc. The payment provider allows us to process transactions on behalf of the Customer

Personal Data collected: Name, Country, Billing Details, other Payment Data and various types of Data as specified in the privacy policy of the service.

Place of processing: United States - See their Privacy Policy attached

Hosting and Web Infrastructure

This type of service has the purpose of hosting Data and files that enable this Website to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Upleap. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

DIGITALOCEAN (DIGITALOCEAN INC.)

DigitalOcean is a hosting service provided by DigitalOcean Inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States

Support

This type of service has the purpose of helping users with their queries pertaining to the Service provided by Upleap.

ZENDESK (ZENDESK INC.)

Zendesk is a customer service software. They are a fully GDPR compliant solution.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States - See their Privacy Policy attached

Age Information

Services we provide are unavailable to children under the age of 18. If a child under the age of 18 has provided us with their information without a consenting parent/guardian, please contact us immediately.

User Rights

Users may exercise rights regarding the processing of their Persoanl Data by the Data Controller and/or the Company. Depending on the protection standards of the region the User finds themselves in, the User might have the right to:

  • Withdraw Consent. Users may withdraw previously given consent to the processing of their Personal Data.
  • Object to Data Processing. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
  • Access Their Data. Users have the right to learn if Data is being processed by the Data Controller, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and Seek Rectification:Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict Data Processing:Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Data Controller will not process their Data for any purpose other than storing it.
  • Remove or Delete Personal Data: Users have the right, under certain circumstances, to obtain the erasure of their Data from the Data Controller.
  • Transfer their Data: Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge Complaint: Users have the right to bring a claim before their competent data protection authority.

The Right to Object to Processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Data Controller or for the purposes of the legitimate interests pursued by the Data Controller, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Data Controller is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

Exercising Rights

Any requests to exercise User rights can be directed to the Data Controller through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Data Controller as early as possible and always within one month.

Defining Broader Protection Standards Applicability

Most provisions of this document concern all Users. Some provisions expressly only apply if the processing of Personal Data is subject to broader protection standards.

Such broader protection standards apply when the processing:

  • is performed by an Data Controller based within the EU;
  • concerns the Personal Data of Users who are in the EU and is related to the offering of paid or unpaid goods or services, to such Users;
  • concerns the Personal Data of Users who are in the EU and allows the Data Controller to monitor such Users’ behavior taking place in the EU.

Cookie Policy

Cookies are miniature text files that are sent by us to your computer, and from your computer or mobile device to us. Some of the purposes for which Cookies are installed may also require the User's consent.

Where the installation of Cookies is based on consent, such consent can be freely withdrawn at any time following the instructions provided in this document.

Technical Cookies and Cookies serving aggregated statistical purposes

The Website of Upleap uses Cookies to save the User's session and to carry out other activities that are strictly necessary for the operation of this Website, for example in relation to the distribution of traffic.

Activity re. Saving of Preferences, Optimizations, and Statistical Information

This Website uses Cookies to save browsing preferences and to optimize the User's browsing experience. Among these Cookies are, for example, those used for the setting of language and currency preferences or for the management of first party statistics employed directly by the Data Controller of the site.

Third Parties Using Cookies

Some of the services listed below collect statistics in an anonymized and aggregated form and may not require the consent of the User or may be managed directly by the Data Controller - depending on how they are described - without the help of third parties.

If any third party operated services are listed among the tools below, these may be used to track Users’ browsing habits – in addition to the information specified herein and without the Data Controller’s knowledge. Please refer to the privacy policy of the listed services for detailed information.

GOOGLE ANALYTICS (GOOGLE INC)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States - Opt Out Here

PROOF (Proof Technologies LLC.)

Google Analytics is a social proof plugin service provided by Proof Technologies LLC. Proof may utilize Data collected to track and examine the use of this Website in order to display publicly available information on non-European Customers. Proof list themselves as a GDPR compliant company.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States - See their Privacy Policy

Third-Party Cookies Notice

Since the installation of third-party Cookies and other tracking systems through the services used within this Website cannot be technically controlled by the Data Controller, any specific references to Cookies and tracking systems installed by third parties are to be considered indicative. In order to obtain complete information, the User is kindly requested to consult the privacy policy for the respective third-party services listed in this document.

Given the objective complexity surrounding the identification of technologies based on Cookies, Users are encouraged to contact the Data Controller should they wish to receive any further information on the use of Cookies by this Website.

Additional Information on Data Collection & Data Processing

Legal Action

The User's Personal Data may be used for legal purposes by the Data Controller in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.

The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System Logs

For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not mentioned in this Privacy Policy

More details concerning the collection or processing of Personal Data may be requested from Upleap at any time. Please see the contact information at the beginning of this document.

“Do Not Track” Requests

This Website does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Privacy Policy Improvements

We may occasionally update this policy. If you continue using the Services we provide after changes are put into effect, you hereby agree to our latest policy revision.


Contact Us

If you have any questions about this Privacy Policy, please do not hesitate to contact us addressing the Data Controller as specified above in the section "Appointed Data Protection Officer / Data Controller".