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Privacy Policy

Effective Date: 01-Apr-2024; Last Updated: 01-Jul-2024

Your privacy is important to us. This Privacy Policy covers what we collect and how we use, disclose, transfer and store your information.

I. NAME OF THE PERSON RESPONSIBLE

The person responsible within the meaning of the GDPR and other national data protection laws of the member states as well as other data protection regulations is the

Winny Solutions LLC 1309 Coffeen Avenue STE 1200 Sheridan, Wyoming 82801 United States Email: support@ultie.org Phone: +1 307 683-0983

You may submit inquiries regarding personal data protection, privacy and security matters to privacy@ultie.org.

II. GENERAL INFORMATION ABOUT THE COLLECTION AND PROCESSING OF YOUR DATA

1. Scope of processing In principle, we process personal data only insofar as this is necessary to provide a functioning website and our content and services. The processing of personal data takes place regularly only with consent. An exception applies to cases in which prior consent can not be obtained for reasons of fact and the processing of the data is permitted by law.

2. Legal basis The processing of your data is either based on your consent or in case the processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract, or based on legitimate interest, cf. GDPR art. 6(1)(a)-(b), (f). If the processing is based on your consent, you may at any time withdraw your consent by contacting us using the contact information in clause 1.

3. Storage and deletion of your data In principle, we only store personal data for as long as is necessary to fulfill contractual or legal obligations for which we collected the data. After that, we delete the data immediately, unless we still need the data until the expiry of the statutory limitation period for evidence purposes for claims under civil law or due to statutory retention obligations. We delete or block the personal data of the data subject as soon as the purpose of the storage is fulfilled. It may also be stored if provided for by the European or national legislator in EU regulations, laws or regulations to which our company is subject (see details in sections 3.1-3.3). Blocking or deletion of the data also takes place when a storage period prescribed by the standards mentioned expires, unless there is a need for further storage of the data for conclusion of a contract or fulfillment of the contract.

3.1. Data Retention Policy Due to tax regulations, Account Data will be retained for up to five full fiscal years from your cancellation of your Ultie account.

Configuration Data and System Generated Data will be erased immediately when you cancel your Ultie account.

End User Data will be erased on an ongoing basis after 12 months from registration, and immediately when you cancel your Ultie account.

3.2 Data Retention for Compliance with Legal Requirements

You may not require Ultie to change any of the default retention periods, except for the reasons for erasure pursuant to clause 3.3, but you may suggest changes for compliance with specific sector laws and regulations.

3.3 Data Restitution and/or Deletion

No data except Account Data will be retained after the termination of the Agreement. You may request a data copy before termination. You must not cancel the Ultie account until the data copy has been delivered, as Ultie will not otherwise be able to deliver the data copy.

III. PROVISION OF THE WEBSITE AND CREATION OF LOG FILES

1. Scope of data processing

Ultie processes personal data only if this is necessary to provide a functioning website and our content and services. The processing of personal data takes place regularly only with consent. An exception applies to cases in which prior consent can not be obtained for reasons of fact and the processing of the data is permitted by law.

Any of the information we collect from you may be used for one or more of the following purposes:

1.1. To personalize your experience (the information will help Ultie to better respond to your individual needs);

1.2. To improve our website (Ultie continually strives to improve our website offerings based on the information and feedback we receive from you);

1.3. To establish a primary channel of communication with you;

1.4. To enable you to scan your website for trackers;

1.5. To enable you to talk to our experts.

2. Data processed

2.1 Each time our website is accessed, our system automatically collects data and information from the computer system of the calling computer. E.g. this is information like:

– Information about the type and version of your internet browser,

– The operating system of your computer, tablet or smartphone,

– Your internet service provider,

– Your IP address,

– Date and time of your access,

– Geographic location,

– Websites from which you came to us,

– Websites that you visit from our site;

We collect such technical information in so-called “log files”, so that you can display our website correctly and we can identify the causes of any technical problems, for the technical optimization of our websites and for the purpose of the security of our computer systems and networks. For these purposes, the legal basis is legitimate interest in the processing of data according to GDPR art. 6(1)(f).

The data will be deleted as soon as it is no longer necessary for the purpose of its collection. Typically, this technical information will be erased or rendered unrecognizable at the latest after ninety (90) days.

The collection of data for the provision of the website and the storage of the data in log files is essential for the operation of the website.

IV. CONTACT REQUESTS FOR PRODUCT INFORMATION, A DEMO OR OTHER CONCERNS

1. Description and scope of data processing

On our website you can contact us via various options: e.g. book a demo, request a quote, request product information, contact request form, support tickets and our chat function. If you make use of these options, the data entered in the input mask will be transmitted to us and saved. In addition to the specific input macro data, the IP address and the date and time of the request are collected and stored.

Alternatively, a contact via email address or Telegram messenger is possible. In this case, your personal data transmitted by email or Telegram respectively will be stored.

In this context, there will be no disclosure of the data to third parties, unless this is necessary for the processing of the query (for example, demo booking tool). In any case, the data will be used exclusively for processing the conversation, unless agreed upon otherwise.

2. Legal basis for processing

Legal basis for the processing of the data is in general the consent of the user, GDPR art. 6(1)(a).

3. Purpose of the data processing

The processing of personal data from the input mask is solely for the processing of your request.

4. Duration of storage

If you have booked a demo, requested product information or an offer, we reserve the right to store the data for two (2) years to measure the profitability of our sales and marketing. Otherwise, we will delete the data as soon as it is no longer necessary to achieve the purpose of its collection. For the personal data entered in the contact form and those sent by email or Telegram, this is the case when the respective conversation with you has ended. The conversation is ended when it can be inferred from the circumstances that the relevant facts have been finally clarified.

5. Revoking consent and removal possibility

You have the possibility at any time to revoke your consent to the processing of the personal data. If you contact us by email or Telegram, you may object to the storage of your personal data at any time. In such a case, the conversation can not continue. All personal data stored in the course of contacting will be deleted in this case.

V. WEBINARS

Ultie may offer from time to time webinars, to which you will be able to sign up from our website. In these cases the data put in the sign-up form during the sign-up process will be used by Ultie for the purposes of the webinar and communication regarding the webinar and other relevant topics. If the webinar is organized together with a partner, then the data might be shared with them. The data is processed on the legal basis of consent, Art. 6 para. 1 s. 1 lit. a GDPR. You have the right to withdraw your consent to process your data at any time by contacting us as provided hereinabove.

VI. YOU BECOME A CUSTOMER OF ULTIE

1. Scope of data processing

You can become a Customer of Ultie. Any of the information we collect from you may be used for one or more of the following purposes:

1.1 To identify you as a contracting party;

1.2 To enable secure login for you in the Control Panel at https://ultie.org;

1.3 To establish a primary channel of communication with you;

1.4 To enable Ultie to issue valid VAT invoices and to process transactions (your information will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the service requested);

1.5 To enable automated handling of the subscriptions; and/or

1.7 To send periodic emails (the email address you provide for order processing may be used to send you information and updates, in addition to receiving occasional company news (if accepted), updates, related product or service information, etc).

If at any time you would like to unsubscribe from receiving future emails, you may cancel your account as provided in this document.

2. Data processed

If you choose to register on our website and become a Customer, four categories of data to and on behalf of you will be processed:

“Account Data”

When you register for an account on our site, create a tournament or a team, subscribe to our newsletter or respond to a survey, basic contact details may be collected, such as the email address and your first and last name, social media profile, age, gender, and currency, and masked credit card or bank account details.

“System Generated Data”

The Service automatically creates and stores metadata on the basis of the other types of data, e.g.:

  • In case you become a customer, subscription data, like start date, latest invoice date and the result of a mandatory VAT number validation, if applicable. Issued invoices are stored so that you may access any issued invoices from within the Control Panel

  • In case you sign up for an Ultie account, please note that we evaluate your user behaviour when you register for our service. We record your campaign behaviour. Embedded links contain UTM parameters and other identifiers which will identify all parameters of your “clicks”. The UTM parameters allow us to add trackable extensions to your URLs. The parameters are:

    • Medium: this parameter describes the medium in which the link is embedded. Examples: email, social media or website.

    • Source: with this UTM parameter we define the source of the link. This can be newsletters, websites, apps or social media channels.

    • Campaign: this type of UTM parameter is used to identify the actual campaigns. For example, if we send you a newsletter every month, the individual newsletters can be evaluated separately.

    • Term: keywords, so that the link can be identified better.

    • Content: within a campaign we insert different elements to be tracked in order to identify them clearly and evaluate them separately. Examples: button, image or video.

The identifiers are generated by the service providers listed in section 11.3 of this privacy policy. We use the identifiers in combination with conversion events, such as account creation (for example, if you buy a subscription) to inform the service providers about the event in relation to the provided identifiers.

3. Legal basis for processing

Legal basis for the processing of the data, is in the presence of consent, GDPR art. 6(1)(a). With registration for an Ultie account the legal basis is GDPR art. 6(1)(b) for the fulfillment of a contract or the implementation of pre-contractual measures.

4. Purpose of the data processing

Registration is required to fulfill the customer contract or to carry out pre-contractual measures.

5. Opposition and removal possibility

You always have the option to cancel your account. You can change the data stored about you at any time. If the data is required to fulfill a contract or to carry out pre-contractual measures, premature deletion of the data is only possible, unless contractual or legal obligations preclude deletion.

VII. COOKIES AND TRACKING TECHNOLOGIES

See Ultie's Cookie Policy for information on the cookies we use.

VIII. CALIFORNIA CONSUMER PRIVACY ACT COMPLIANCE

In addition to the above mentioned, the following provisions apply specifically for residents of California, USA.

The California Privacy Laws provide users who reside in California with specific rights regarding their personal information. This section describes the customers’ rights and explains how to exercise those rights, subject to exceptions under the law.

  1. Your rights under California Privacy Law

  • Right to Know About Personal Information Collected, Sold or Shared (“Right to Know”)

You have the right to request to know what personal information we have collected about you, including:

  • The categories of personal information collected

  • The categories of sources from which the personal information is collected

  • The business or commercial purpose for collecting or selling personal information

  • The categories of third parties with whom the personal information is shared

  • The specific pieces of personal information collected about you that are permitted by law

  • Right To Request Deletion of Personal Information (“Right to Delete”)

You have the right to request that we delete any of your personal information that we collect, subject to certain exceptions. Once we receive your request and verify your identity, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

  • Right to Correct Inaccurate Personal Information (“Right to Correct”)

You have the right to request correction of inaccurate personal information that we maintain about you or update the information we have on file.

  • Right to Opt Out of Sale or Sharing of Your Personal Information

You have the right to opt out of the sale or sharing of personal information. Ultie does not sell personal information, including personal information of minors under the age of 16. You can make use of your right to opt out of the sale or sharing of personal information by clicking the “Do Not Sell Or Share My Personal Information” link at the bottom of the page.

  • Right to Non-Discrimination For The Exercise Of Your Privacy Rights

You have the right to be protected from discrimination for exercising your rights. We will not discriminate against you for exercising your right.

  • Right to Limit the Use of Sensitive Personal Information

Ultie does not use sensitive personal information in any manner that requires offering a right to limit its use.

  1. How To Submit a Request to Exercise Your Right to Know, Delete, or Correct

You may submit your request by sending an email to privacy@ultie.org. We will compare the information you submit to us with the information we have in our records to ensure your request meets the definition of “verifiable consumer request” under the California Privacy Laws. We will then respond to your request in accordance with the requirements.

Response Timing and Format

Ultie endeavors to respond to a request within forty-five (45) days of its receipt. If Ultie requires more time (up to 90 days), you will be informed of the reason and extension period in writing. Any disclosures provided will only cover the twelve (12) month period preceding the receipt of the verifiable request. If applicable, the response will also explain the reasons for which Ultie cannot comply with a request. For data portability requests, Ultie will select a format to provide the Personal Information that is readily usable and should allow transmission of the information from one entity to another entity without hindrance. Ultie does not charge a fee to process or respond to the verifiable request unless it is excessive, repetitive, or manifestly unfounded. If Ultie determines that the request warrants a fee, we will inform why Ultie made that decision and provide a cost estimate before completing the request.

  1. Children Under the Age of 16

Ultie does not knowingly collect or disclose the personal information of children under the age of 16. Children under the age of 16 may only use Ultie if it is consented to by their Parent or Legal Guardian. As stated above, Ultie also do not sell or share personal information, including personal information of children under the age of 16.

IX. MINORS

Our services are not aimed at children under 13 years. We do not knowingly collect information from children under the age of 13. If you have not reached the age limit, DO NOT use the services and DO NOT provide us with your personal information. If you are a parent of a child below the age limit and you learn that your child has provided Ultie with personal information, please contact us at privacy@ultie.org and insist on exercising your rights of access, correction, cancellation and / or opposition. If you are resident in California and are under 18 years of age and wish to erase publicly available content, please contact us at privacy@ultie.org.

X. ONLINE PRESENCE IN SOCIAL NETWORKS

We maintain online presences in social networks in order to communicate there with our customers and interested parties, among others, and to provide information about our products and services.

The users’ data is usually processed by the social networks concerned for market research and advertising purposes. In this way, usage profiles can be created based on the interests of the users and on-site behavior, if it exists. For this purpose, cookies and other identifiers are stored on the users’ computers. On the basis of these usage profiles, advertisements, for example, are then placed within the social networks but also on third-party websites.

As part of the operation of our online presences, it is possible that we can access information such as statistics on the use of our online presences, which are provided by the social networks. These statistics are aggregated and may include, in particular, demographic information and data on interaction with our online presences and the posts and content distributed via them. Please refer to the list below for details and links to the data of the social networks that we can access as operators of the online presences.

The legal basis for data processing is GDPR art. 6(1)(a)-(b), in order to stay in contact with and inform our customers and to carry out pre-contractual measures with future customers and interested parties.

For the legal basis of the data processing carried out by the social networks on their own responsibility, please refer to the data protection information of the respective social network. The links below also provide you with further information on the respective data processing and the options to object.

We would like to point out that data protection requests can be asserted most efficiently with the respective provider of the social network, as only these providers have access to the data and can take appropriate measures directly. Below is a list with information on the social networks on which we operate online presences:

XI. THIRD PARTY SOURCES OF INFORMATION, RECIPIENTS OF DATA AND DATA TRANSFER TO THIRD COUNTRIES

Information we obtain from third parties:

Social media information. We may maintain pages on social media platforms, such as Facebook, Instagram, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.

Third-party login information. When you link, connect, or login to Ultie with a third party service (e.g. Google or Facebook), you direct the service to send us your profile information such as your first and last name, age, city and country as controlled by that service or as authorized by you via your privacy settings at that service.

Other Sources. We do not presently obtain anyone's personal information from any third parties, such as marketing partners, publicly-available sources and data providers.

11.1 Recipients of Data

Ultie does not sell, trade or otherwise transfer to outside parties any personally identifiable information.

This does not include trusted third parties or processors who assist us in operating our website, conducting our business, or servicing you. Such trusted parties may have access to personally identifiable information on a need-to-know basis and will be contractually obliged to keep your information confidential.

We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect our rights or the rights of others, property, or safety. Furthermore, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

We only pass on the data we have collected if this is necessary for the fulfillment of the contract or for the provision of the technical functionality of the website, or if there is another legal basis for passing on the data.

In principle, we process your data ourselves. In some cases, however, we also use service providers. In addition to the processors mentioned in this privacy policy, these may include, in particular, data centers that store our website and databases, IT service providers that maintain our systems, and consulting companies. If we pass on data to processors, they may only use the data to fulfill their tasks. The processors have been carefully selected and commissioned by us. They are contractually bound to our instructions, have suitable technical and organizational measures in place to protect the rights of the data subjects and are regularly monitored by us.

In addition, disclosure may take place in connection with official enquiries, court orders and legal proceedings if it is necessary for legal prosecution or enforcement. When governments make a lawful demand for customer data from Ultie, Ultie strives to limit the disclosure. We will only release specific data mandated by the relevant legal demand.

If compelled to disclose your data, Ultie will promptly notify you and provide a copy of the demand unless legally prohibited from doing so.

If Ultie commissions third parties with the collection, processing and use of data within the scope of commissioned processing in accordance with Art. 28 GDPR, this will also take place exclusively in compliance with the statutory provisions on data protection.

Importantly, unless you specifically prohibit this, your team's manager(s) may receive access to some of your personal information, solely for the purpose of sending you an invitation to a respective team. Team's manager(s) are registered and verified on Ultie platform. They are also contractually bound to all our instructions, have a duty to protect your privacy rights, and are regularly monitored by us.

11.2 Data Transfer to third Countries

As explained in this privacy policy, we use services whose providers are partly located in so-called third countries (outside the European Union or the European Economic Area) or process personal data there, i.e. countries whose level of data protection does not correspond to that of the European Union. Where this is the case and the European Commission has not issued an adequacy decision (Art. 45 GDPR) for these countries, we have taken appropriate precautions to ensure an adequate level of data protection for any data transfers. These include, among others, the standard contractual clauses of the European Union or binding internal data protection regulations.

If a third country transfer is provided for and no adequacy decision or appropriate safeguards are in place, it is possible and there is a risk that authorities in the respective third country (e.g. intelligence services) may gain access to the transferred data in order to collect and analyze it, and that enforceability of your data subject rights cannot be guaranteed.

11.3 Processors /Trusted Third Parties

Processor

Function

Data Processing

Location

Legal Basis

Privacy Policy of Processor for further information

Amplitude Inc., 201 3rd Street, Suite 200, San Francisco, CA 94103, USA

Analytics service

IP address, Geographical location

In the USA

GDPR Art. 6 (1) lit. a

https://amplitude.com/privacy

Google Ads, Google Building Gordon House, 4 Barrow Street, Dublin D04 E5W5, Ireland By accepting the use of Google Ads, “Enhanced Conversion” will also be activated

Advertising Web analytics service

Gclid, Ads viewed, Cookie ID, Date and time of visit, Device info, Geographic location, IP address, Search terms, Ads shown, Impressions, Online identifiers, Browser info For Enhanced conversion: email address, phone number, name, street and number, city, zip code and country

In Ireland and the USA

GDPR Art. 6 (1) lit. a

https://policies.google.com/privacy?hl=en

Google Analytics, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (By consenting to the use of Google Analytics data will also be shared with Google Ads for marketing purposes. Please see above under “Google Ads” for more information about this provider.)

Advertising Web analytics service

Google Client ID, Click path, Date and time for visit, Device info, Location info, IP address, Pages visited, Referrer URL, Browser Info, Hostname, Browser language, Browser type, Screen resolution, Device operating system, Interaction data, User behavior, Visited URL

In Ireland and the USA

GDPR Art. 6 (1) lit. a

https://policies.google.com/privacy?hl=en

Meta Platform Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin, D02, Ireland

Facebook Pixel – Advertising Web analytics service

FBClid, Ads viewed, Content viewed, Device info, geographic location, HTTP-header, Interactions with advertisement, services and product, IP address, Items clicked, Marketing info, Pages visited, Pixel ID, Referrer URL, Usage behavior, Facebook cookie info, Facebook user ID, Usage/click behavior, Browser info, Device operating system, Device ID, User agent, Browser type

In the EU (Ireland), Singapore and the USA

GDPR Art. 6 (1) lit. a

https://www.facebook.com/privacy/explanation

PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg

Payment provider

PayPal information, Payment data, Order number, Credit Card information, Credit check and statistical data if applicable, Address data if applicable

Worldwide

GDPR Art. 6 (1) lit. b

https://www.paypal.com/dk/webapps/mpp/ua/privacy-full

Sentry/Functional Software, Inc., 45 Fremont Street, 8th Floor, San Francisco, CA 94105, USA

Error logging for frontend errors happening for users of our product.

IP address

In the USA

GDPR Art. 6 (1) lit. b

https://sentry.io/privacy/

YouTube Video, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland

Advertising Web analytics service

Gclid, Device info, IP address, Referrer URl, Video viewed

In Ireland and the USA

GDPR Art. 6 (1) lit. a

https://policies.google.com/privacy?hl=en

XII. YOUR RIGHTS

If we process your personal data you have – after successful identification – the following rights towards us:

  • Right to information (Article 15 GDPR)

  • Right to deletion (Article 17 GDPR)

  • Right to rectification (Article 16 GDPR)

  • Right to restriction of processing (Article 18 GDPR)

  • Right to data portability (Article 20 GDPR) – You may at any time order a complete data copy, which you may transmit to another controller of the data. Your data will be delivered within 10 working days by Ultie as spreadsheet files in Microsoft Excel format. Logical relations between datasets will be preserved in the form of unique identifiers. You are required to pay €1,000 (One Thousand Euros) and any applicable taxes on delivery for each data copy order.

  • Right to withdraw consent (Article 7(3) GDPR)

  • Right to object to certain data processing activities (Article 21 GDPR).

In order to exercise your rights described here, you can contact us at any time using the contact details above, listed under “Name of the person responsible“.

You may at any time lodge a complaint with a supervisory authority regarding Ultie's collection and processing of your personal data.

XIII. SECURITY AND INTEGRITY OF THE DATA

Protecting the information you give us or that we receive about you is our priority. We take appropriate security measures to protect your information from loss, misuse, and unauthorized access, alteration, disclosure, or destruction. Ultie has taken measures to ensure the ongoing confidentiality, integrity, availability and resiliency of systems and services that process personal information, and will restore the availability and access to information in the event of a physical or technical incident in a timely manner.

Find out more information in our Data Processing Agreement.

XIV. Terms of Service and Data Processing Agreement

Please also visit our Terms of Service section establishing the use, disclaimers and limitations of liability governing the use of our website and services and our Data Processing Agreement.

XV. UPDATES

We reserve the right to update this privacy policy from time to time. In the event that we make material changes that restrict Ultie's rights or obligations under this Privacy Policy, we will publish a clear notice in this section of this Privacy Policy that informs users when they are updated.

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