1. Introduction
The privacy notice of Uma ("we," "us," or "our") demonstrates our commitment to safeguarding your privacy and protecting your personal data. By using the Uma web app or visiting uma.app ("our website"), regardless of your location, you will be informed about how we manage your personal data. This notice also outlines your privacy rights and the legal provisions that ensure your protection.
2. Important Information and Who We Are
The Uma product, developed by Keev, LLC, is registered at 1111B S Governors Ave STE 21256, Dover, DE 19904, USA. We manage the website located at uma.app as well as the Uma web app.
3. Purpose of This Privacy Notice
As required by data protection legislation, we must provide specific information about our identity, the methods we use to process personal data, the purposes behind it, and your rights concerning your personal data, along with instructions on exercising those rights. This information is detailed in our Privacy Policy, and it is crucial that you read it.
We do not design our website or the App for children, nor do we intentionally gather data about them.
Please ensure you read this privacy notice in conjunction with any other privacy notices or fair processing notices we may provide during specific instances of collecting or processing your personal data. This privacy notice supplements, rather than overrides, any other notices.
4. Controller
Keev, LLC, as the developer of Uma, serves as the controller and assumes responsibility for personal data collected from you through our website and the web app. For inquiries about this privacy notice, including exercising your legal rights, please contact us using the information provided below.
5. Contact Information
For further details, please email us at: [email protected].
If you are a data subject in the European Economic Area (“EEA”), you can file a complaint with your data protection supervisory authority at any time (in the United Kingdom (“UK”), this is the Information Commissioner’s Office (“ICO”) (www.ico.org.uk)). However, we would appreciate the opportunity to address your concerns before you contact a supervisory authority, so please reach out to us first.
6. Privacy Notice Updates and Your Responsibility to Inform Us of Changes
We routinely review our privacy policy. The latest update to this notice was on August 28, 2024. It is crucial that we maintain accurate and up-to-date personal data about you. If your personal data changes during your association with us, please keep us informed.
7. Third-Party Links
Our website and the App may feature links to third-party websites, plug-ins, and applications. By clicking on these links or activating these connections, you may allow third parties to gather or share data about you. We have no control over these third-party websites and are not responsible for their privacy policies. Upon leaving our website, we advise you to review the privacy notice of each website you visit.
8. Data We Collect About You
Under U.S. legislation, personal data or personal information refers to any details about an individual that allows for their identification. It does not encompass data where the identity has been removed (anonymous data).
We may collect, use, store, and transfer various types of personal data about you, which we have categorized as follows:
- Identity Data: First name, last name, username or similar identifier, title, date of birth, and gender.
- Contact Data: Billing address, email address, and telephone numbers.
- Financial Data: Bank account and payment card details.
- Transaction Data: Details about payments to and from you and other purchase details.
- Technical Data: Internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website and the App.
- Profile Data: Username and password, purchases or orders made by you, feedback, and survey responses (you may provide us with what is considered Special Categories of Personal Data through certain surveys, as discussed below).
- Usage Data: Information about how you use our website and the App.
- Marketing and Communications Data: Your preferences for receiving marketing from us and our third parties and your communication preferences.
- Special Categories of Personal Data: Details about your religious or philosophical beliefs (including your place of worship) and information about your physical and mental health.
We also gather, utilize, and share Aggregated Data, such as statistical or demographic data, for any purpose. Although Aggregated Data may be derived from your personal data, it is not considered personal data by law, as it does not directly or indirectly disclose your identity. For instance, we may aggregate your Usage Data to determine the percentage of users accessing a specific feature on the website and the App. By aggregating responses within the website and the App, we can offer insights to improve our services. No individual’s information is ever visible since all personal data is anonymized and combined with that of at least five other users.
Nonetheless, if we merge or connect Aggregated Data with your personal data in a way that directly or indirectly identifies you, we will treat the combined data as personal data, which will be used according to this privacy notice.
9. Special Categories of Personal Data
Special Categories of Personal Data pertain to sensitive personal data that necessitates increased protection. U.S. legislation defines Special Categories of Personal Data as personal data revealing racial or ethnic origin, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information, and genetic and biometric data.
We gather details about your religious or philosophical beliefs (including your place of worship) and information about your physical and mental health to offer certain features of the website and the App. This information is typically used to grant access to additional features, although we may aggregate this information and utilize the aggregated results for other purposes (in which case it will become Aggregated Data).
To process Special Categories of Personal Data lawfully, fairly, and transparently, and to ensure compliance with applicable data protection principles and requirements, we must identify a lawful basis for processing. Our lawful basis for processing Special Categories of Personal Data is your explicit consent.
10. Failure to Provide Personal Data
If we are required to collect personal data by law or under a contract we have with you, and you do not provide that data when requested, we may be unable to fulfill the contract we have or are attempting to establish with you (e.g., providing access to the website and/or App). In this situation, we might need to cancel your account, but we will inform you if this occurs.
11. Methods of Personal Data Collection
We employ various methods to collect data from and about you, including:
- Direct Interactions: You may provide us with your Identity, Contact, and Financial Data by completing forms or corresponding with us via email or through the App. This includes personal data you submit when logging into our App.
- Automated Technologies or Interactions: When interacting with our website and App, we may automatically gather Technical Data about your equipment, browsing actions, and patterns.
- Third Parties or Publicly Available Sources: We may receive personal data about you from different third parties, as detailed below:
- Technical Data from analytics providers like Google.
- Contact, Financial, and Transaction Data from technical and payment service providers.
- Identity Data, Profile Data, Usage Data, and Contact Data from mobile application providers, such as Google and Apple.
12. Using Your Personal Data
We will use your personal data only when permitted by law. Typically, we use your personal data in these circumstances:
- When we need to perform a contract with you, such as providing access to the website and the App.
- When it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests.
- When we need to comply with legal or regulatory obligations.
We generally do not depend on consent as a legal basis for processing your personal data. However, we will:
- Rely on consent as a legal basis for processing Special Categories of Personal Data to provide access to the website and the App.
- Obtain your consent before sending third-party direct marketing communications to you via email or text message.
14. Marketing
We aim to give you options regarding certain personal data uses, especially in marketing and advertising. We have established the following personal data control mechanisms:
15. Promotional Offers from Us
We may use your Identity, Contact, Technical, Usage, and Profile Data to determine what we believe may interest you or fulfill your needs. This helps us identify relevant products and offers for you (known as marketing). You will receive marketing communications from us if you have requested information, downloaded the App, or purchased a subscription and have not opted out of receiving marketing.
16. Third-Party Marketing
We will obtain your explicit opt-in consent before sharing your personal data with any third party for marketing purposes.
17. Opting Out
You can request that we or third parties stop sending you marketing messages at any time by following the opt-out links in any marketing message sent to you or by contacting us at any time.
18. Change of Purpose
We will use your personal data only for the purposes we initially collected it for, unless we reasonably determine that we need to use it for another reason that is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.
19. Disclosure of Your Personal Data
You agree that we have the right to share your personal information with selected third parties, including:
- Business partners, suppliers, and subcontractors, including data storage centers, for the performance of any contract we enter into with them or you.
- Analytics and search engine providers that assist us in improving and optimizing our website and the App.
We will disclose your personal information (disclosing only the minimum necessary amount) to third parties if we sell or buy any business or assets or if we are under a duty to disclose or share your personal data to comply with legal obligations.
20. Data Security
We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, accessed, altered, or disclosed without authorization. Additionally, we limit access to your personal data to those employees, agents, contractors, and other third parties with a business need. They will process your personal data only on our instructions and are subject to a duty of confidentiality.
21. Data Retention
We will retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for processing your personal data, and whether we can achieve those purposes through other means.
22. Your Legal Rights
Under certain circumstances, you have rights under data protection laws regarding your personal data, including:
- Requesting access to your personal data.
- Requesting correction of your personal data.
- Requesting erasure of your personal data.
- Objecting to the processing of your personal data.
- Requesting the restriction of processing of your personal data.
- Requesting the transfer of your personal data.
- Withdrawing your consent.
23. No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
24. Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
25. Glossary
- Lawful Basis: The basis on which we process your personal data under the General Data Protection Regulation (GDPR) and other relevant data protection laws.
- Personal Data: Any information relating to an identified or identifiable natural person.
- Processing: Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means.
26. Further Information
For further information regarding your rights and how we manage your personal data, please contact us at [email protected].
27. Glossary Terms
- Legitimate Interest: Our business's interest in conducting and managing our operations to provide the best service/product and the most secure experience. We ensure that we consider and balance any potential impact on you (positive or negative) and your rights before processing your personal data for our legitimate interests. We do not use your personal data for activities where the impact on you overrides our interests, unless we have your consent or are required or permitted by law.
- Performance of Contract: Processing your data when necessary for the performance of a contract you are a party to or taking steps at your request before entering into such a contract.
- Comply with a Legal Obligation: Processing your personal data when necessary for compliance with a legal obligation to which we are subject.
