Welcome to TheUp-Turn! At TheUp-Turn, your privacy is of the highest importance to us. We respect your rights and we are careful to protect your individual rights in operating our Services.
1. Information We Collect
Personal information refers to any information that is not anonymized and can be used to identify a real life individual. We collect the following information when you use our Services:
- Visitor Information. When you visit our website, we collect standard web analytics such as visitor IP addresses, browsing behavior, browser information, and device information.
- Contact Information. When you subscribe to our email newsletter, we collect your email address to send you our newsletter.
- Payment Information. When you purchase our products or services, we collect information needed to process the payment, such as your name, email, and financial information like credit card information.
Communications with Us. When you contact TheUp-Turn such as through our contact forms, social media, or email, or publicly share about TheUp-Turn, we collect information about the communication and any information you may provide.
1-1 Coaching Information. When you sign up for our 1-1 Coaching, we collect information needed to deliver the service, such as your past experience with the topic and other details you share. The coaching discussion is recorded in a text log. We do not record any audio or video. This is used as a record of the service rendered and as a reference for follow-up calls.
- Other Information. You may otherwise choose to provide us information when you conduct a search, respond to surveys, post blog comments, post on our forums, or use other features of our Website.
2. How the Information is Used
We use the personal information for the following purposes:
- With your consent, to send you our newsletters.
- To bill you for your purchases and to deliver the product or service you purchase. When you sign up for Live Courses, we provide course recordings for participants to review the sessions. We may publish course interactions as part of the course content. Our legal grounds for processing are the performance of a contract with our customers and where necessary, to comply with legal obligations.
- To communicate with you when you contact us or to follow up on an issue from your use of our products or services. Our legal grounds for processing are your consent and where necessary, the performance of our contract with you.
- To provide, improve, and develop products and services. We study your feedback to understand how we can improve our Services. We answer the questions sent to us on our Website to help users with similar problems. We may use the information collected from our courses to improve our courses and develop new Services. Our legal ground for processing is our legitimate interests in improving our Services, developing new Services, and helping other TheUp-Turn users.
- To highlight the value of our Services. We may feature positive feedback or user transformations on our Website with your name, comment, and accompanying information such as your profile picture. Our legal ground for processing is our legitimate interests in growing our business and promoting our Services to other TheUp-Turn users.
3. Sharing and Disclosure
We place a very high regard for your privacy, and take care not to share your personal information with anyone. However, there are circumstances when your information will be shared with others:
- With Your Consent. There are certain forms on our site where we invite users to post questions or feedback. You understand that the information that you post via these forms may be republished on our Services, absent email address.
- Part of Course Content. All course interactions are considered part of our Course Content and may be used as content in a current or future course. This includes what you share during the live webinars, your email interactions with us, and your course forum discussions. Your email address is never published.
- With Service Providers. To provide our Services, we use a variety of service providers and contractors. These service providers and contractors help us with certain functions, such as to (a) provide website analytics, (b) process and fulfill our customer orders, (c) deliver our newsletter service, (d) provide our course portal for our courses, (e) host our live webinars, (f) maintain our servers, and (g) secure our data. We require them to respect the security of your personal data and to treat it in accordance with the law, and to process your personal data for specified purposes and in accordance with our instructions.
- Information Shared with Third Party Users. You understand that when you share your personal information with third parties through our Services, this information can be seen, heard, collected, and used by other people besides us. For example, when you post on our website comment sections, other visitors can see your comments and information you provide. When you share in our live webinars, other course participants may read and hear what you share. Further to that, course interactions may be incorporated as content in future courses. Information shared on public pages such as our Website and social media pages may be indexed by search engines and saved by internet archival bots. We do not control such engines and bots, and they may use caches containing your information, including outdated information. We take care to provide a safe environment for you when using our Services but we cannot be held responsible for what third parties may do with this data and any third-party use and misuse of this information.
4. Information Storage
To provide you with our Services, we may collect, store, process, and transfer information in locations around the world, including outside your home country. Our service providers may be located inside or outside of the European Economic Area (“EEA”). In particular, our service providers are based in the United States, Europe, Israel, New Zealand, and Singapore. Our contractors may be located around the world. As such, the information provided to us is transferred to and stored in those countries.
Where we transfer, store, and process your personal information outside of the EEA, we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection, such as certification under an approved certification mechanism (like the EU-US Privacy Shield Framework) or compliance with an approved code of conduct approved by a supervisory authority.
We have in place security measures to prevent your personal information from being accidentally lost, used, altered, disclosed, or accessed without authorization. Some of these measures include protection against brute-force attacks, firewalls, and data encryption. We restrict access to personal information to trusted contractors who need this information to carry out their work with us, and they will only process your personal information based on our instructions.
However, no system is impenetrable. We cannot guarantee the security of our website and databases. We cannot guarantee that any information sent to and from us will not be intercepted when transmitted over the internet. TheUp-Turn will not be held liable for any loss to you or any third party arising from any unauthorized access, loss, misuse, or alteration of the information.
6. Your Choices
You may manage your information in various ways, including without limitation:
- You may change your email registered in our email newsletter by contacting us.
- You may opt out of our newsletter by clicking the “unsubscribe” link at the bottom of each newsletter. If you purchased our Premium Products or Live Courses, you may continue to receive transaction messages related to your purchase.
- You may prevent tracking of your opens and clickthroughs of our newsletter mailings by opting not to load images in your email client.
- If you purchased our products or services, you may update your purchase details by contacting us. You may update your account information by logging into the course portal.
- You may use a false name when using our Services.
- You may opt out of participating in the interactive areas of our Live Courses such as the text chat, audio sharing, and discussion forums.
- You may cancel your account to our course portal. Note that you will not be able to access the course you purchased after you cancel the account.
- You may disable cookies in your browser before using our Services.
Please note that doing some of the above actions will limit your experience of our Services. For example,
- Opting out of our newsletter will prevent you from receiving our website updates, exclusive messages not posted on our website, and course offers.
- Disabling image loading in your email client may cause your email subscription to be flagged out as inactive and scheduled for deletion without warning. It also prevents us from sending you more targeted mailings. It may cause you to receive duplicate mailings as certain newsletters may be re-sent to subscribers who have not interacted with them yet.
- Disabling cookies may cause our Services not to function optimally, such as having to repeatedly log in to access our course content or repeatedly seeing content only meant appear once, such as certain popups or alerts.
- Not interacting with our Services such as not posting comments and not engaging with other participants in our live courses will limit the value you may get from such Services.
7. Data Retention
We retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements. For example, for tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity,
Financial and Transaction Data) for six years after they stop being customers.
8. EU Residents: GDPR
If you reside in the EU, you may request for a record of the personal information we hold about you. There may be a charge for each record request (not more than £10). We may request proof of identification to confirm your identity and additional information to process the request. We will provide you with a copy of the personal information we hold about you not more than one month after receiving a valid request. We can refuse to comply with an access request if it is manifestly unfounded or excessive.
If you no longer want us to use your personal information, you can request that we erase your personal information with us. We will act upon the request within one month of receipt of a valid request. In certain cases, it may take us longer than a month if the request is complex and there may be a fee involved, in which case we will notify you. We can refuse to comply with an erasure request if it is manifestly unfounded or excessive.
Please note that if you have purchased any access to our Services, you will lose all access upon erasure. Additionally, please note that in some cases, we may retain data for limited periods for legitimate business or legal reasons. For example:
- We may keep some of your information for accounting compliance.
- We may keep some of your information for fraud prevention. For example, if we have terminated a user’s access to our Services for fraud, we may retain information about him/her to prevent access in the future.
- Information that you have shared with others (e.g. blog comments, during webinars) may continue to be visible through our Website and courses, even after your data is removed. However, attribution of such information to you will be removed.
- Our Services use backup systems to prevent unexpected data loss. Residual copies of your personal information may remain on such systems for a limited period of time.
- We may anonymize your personal data for legal, record, or business purposes, in which case we may use this information indefinitely without further notice to you.
Please note that removal or modification of any information from our Services does not constitute its removal from the internet, as other websites and search engines may have copied the content. We are not responsible for information held by these third party websites and search engines and you need to contact these third party websites and search engines for the removal of your data from their services.
9. Third-Party Links
Our Services may include links to third-party websites or services, such as third-party plugins, third-party applications, or co-branded services. An example is embedded videos from YouTube. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites or services and they have their own rules about the collection, use, and disclosure of information. We encourage you to read the privacy policies of other websites you visit.