Privacy Policy
Last updated: August 30, 2022
Welcome to www.uplead.com (“Site”), a website owned and operated by UpLead, LLC, (“UpLead,” “we,” “us” or “our”). This Privacy Policy, along with our Cookie Notice, explains how we collect, use, share and protect personal information processed in relation to the Site and the services that we offer (“Services”) (collectively, “Platform”) and other interactions (e.g., customer service inquiries, live chat, social media etc.) that you may have with UpLead. It also tells you about your choices with respect to our collection, use and disclosure use of your personal information.
We recommend that you read this Privacy Policy carefully as it provides important information about your personal information and your rights under the law.
IF YOU ARE AN INDIVIDUAL LOCATED IN THE EEA OR THE U.K.: If you are located in the European Economic Area (“EEA”) or the United Kingdom (“U.K.”), this entire Privacy Policy applies to you. However, please see the section titled Additional Information for Users in the EEA and the U.K., which provides more information about which rights you have regarding the processing of your personal data.
IF YOU ARE CALIFORNIA RESIDENT: If you are a resident of California, this entire Privacy Notice applies to you. However, please see the section titled Additional Information for California Residents below, which will inform you in detail about our information collection practices and your specific rights.
If you have any questions, comments, or concerns regarding this Privacy Policy, our Cookie Notice and/or our data practices, or would like to exercise your rights, do not hesitate to contact us at [email protected] or see our information below.
Who We Are and How to Contact Us
Changes to This Privacy Policy
This Privacy Policy was last updated on the date indicated above. Our business and/or the Platform may change from time to time, and as a result, at times it may be necessary for UpLead to make changes to this Privacy Policy. UpLead reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. However, if we make changes that we believe will materially impact this Privacy Policy or your rights, we will promptly notify you of those changes. We encourage you to review this Privacy Policy from time to time. Your continued use of the Platform after any changes or revisions to this Privacy Policy will indicate your agreement to the terms of any such revised Privacy Policy.
Children’s Privacy
UpLead does not knowingly collect information from children under the age of 16. If you are under the age of 16, please do not submit any personal data through the Platform. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal data on our Platform without their permission.
If you have reason to believe that a child under the age of 16 has provided personal data to UpLead through the Platform, please contact [email protected] and we will endeavor to delete that information from our databases.
To Whom Does This Policy Apply
Throughout this Privacy Policy, “personal information” (or “personal data” as used interchangeably) refers to any information that is unique to an individual, such as name, address, email address, phone number, IP address and other information that can reasonably identify an individual. This Privacy Policy applies to personal information (that we collect, store, disclose or otherwise process) from or about:
- Site Visitors – this includes visitors to our Site, including those who do not register for our Services.
- Customers – this includes any individual who registers individually or on behalf of an entity or organization in order to use the Services, whether as part of a free trial or paid subscription.
- Business Profiles – our business is to help people connect professionally, and for this we collect and compile business information about individuals and their companies. As such, we store and process personal information to create Business Profiles of individuals as part of our Services. Please see below for more information on how this information is collected.
Personal Information That We Collect
What personal information we collect and process depends on a number of factors. As explain in more detail below, we process personal information that we receive directly from you when you provide it to us, such as when you sign up for our Services, or indirectly, such as through automated technologies (e.g., cookies) or from third parties. We also collect information for Business Profiles in a variety of ways as explained below.
You can generally visit our Site without having to submit any personal information. However, if you wish to use our Services, you will be asked to provide information about yourself.
If you contact us through our “Contact Us” form on the Site, via the chat feature or otherwise send us an email, we process any personal information contained in those communications, including name, contact information, company and any other information that you submit to us.
If you sign up for our Services, whether as a free trial or paid subscription, we will collect personal information as follows:
- First and last name
- Company name
- Email address
- Username
- Password
- Job title
- Location (Country/State/Zip Code)
- Phone number
- Billing address
If you are a Customer, we use PCI-compliant third-party processors, as explained in Payment Processing. Payment information is processed by our payment service providers, and we receive a confirmation of payment, which we then associate with your account and any relevant transactions.
Customer reviews contain names, photos and contact information. If you submit a Customer review, with your consent, it may be posted on the Site and publicly visible. We may also share it with strategic partners.
Information We Collect Indirectly
If you are browsing or interacting with the Site, we collect the same basic information that many other websites collect. Even if you do not have an account, we, or authorized third parties engaged by us, automatically collect information about your use of the Site, which consists of:
- Device Information – information about the devices and software you use to access the Site – primarily the internet browser or mobile device that you use, the website or source that linked or referred you to the Site, your IP address or device ID (or other persistent identifier that uniquely identifies your computer or mobile device on the Internet), the operating system of your computer or mobile device, device screen size and other similar hardware and software information, and language preference
- Usage Information – information about your interactions with the Site, including access dates and times, device event information, log data, crash data, and cookie data. This information allows us to understand the screens that you view, how you’ve used the Site and/or our Services (which may include administrative and support communications with us), and other actions on the Site. We, or our authorized third parties, automatically collect log data when you access and use the Site for all Site Vistors, even if you have not created an account or logged in. We use this information to administer and improve the Services, analyze trends, track users’ use of the Site, and gather broad demographic information for aggregate use.
- Location Information – based on this Device and Usage Information – mainly IP address – we are also able to determine general location information (country, city).
We (and certain authorized third parties) uses cookies and similar technologies in order to collect Device, Usage and Location Information. Some cookies are necessary to make the Site and our content available to you, while others are meant to improve the Site and enable us to analyze and measure audience and traffic. For more information on our use of cookies and the data that they collect, see our Cookie Notice.
Business Profile Data
UpLead collects and compiles information about individuals with whom it does not have a direct relationship, but whose Business Profiles are included on our Platform. This information is gathered, compiled (and updated) and provided to our Customers as part of the Services. Information that we collect and store to create Business Profiles (“Business Profile Data”) consists of business or professional information and includes personal and non-personal information, as described below. We collect Business Profile Data in a variety of ways:
- Directly from individuals who submit Business Profile Data to us
- From the publicly-available information available on the internet or otherwise
- From third-party companies that collect information on our behalf and license it to us
A Business Profile includes (but does not always contain all of) the following Business Profile Data:
- First and last name
- Business e-mail address
- Business telephone (mobile in some cases)
- Company
- Job Title
- Location (City)
- Photo
- Education
- Experience
- Public social media handles
Individuals whose information is contained in a Business Profile on the Platform may contact us at [email protected] to access or have their Business Profile Data updated, rectified or deleted. You may also click here.
Google Analytics
Hotjar
Payment Processing
Social Media
How Do We Use Personal Information We Collect
We use your personal information for a number of different reasons, as further explained below.
In addition, for users located in the EEA and the U.K., we must have a valid legal basis in order to process your personal data. Generally speaking, the main legal bases under the European Union’s General Data Protection Regulation (GDPR) that justify our collection and use of your personal data are:
- Performance of a contract – When your personal data is necessary to enter into or perform our contract with you.
- Consent – When you have consented to our use of your personal data via a consent form (online or offline).
- Legal obligation – When we need to use your personal information to comply with our legal obligations.
- Legal claims – When your personal information is necessary for us to defend, prosecute or make a claim.
- Legitimate interests – When we use your personal data to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights. For instance, our processing of Business Profile Data in connection with our Services is within our legitimate interests because the business nature of the information (while still personal information) is widely available and distributed across the internet and otherwise. The information does not concern any special categories of data nor does it include personal details about individuals’ private lives. Moreover, UpLead provides adequate notice, access and choice (including the ability to delete said Business Profile Data directly by clicking here) and technical and organizational measures with respect to the Business Profile Data. As such, UpLead’s use of personal data as part of the Business Profile Data outweigh any prejudice to the individuals’ data protection rights. If we rely on our (or another person’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. You can ask us for information on this balancing test by contacting us at [email protected].
Below are the general purposes and corresponding legal bases (in brackets) for which we may use your personal information:
- Providing, updating and maintaining the Platform – In particular, we will use your data to ensure that the Site loads and works for you, to set-up an account, or provide you with notices regarding purchases or other important information. Depending on the context, performance of a contract, legitimate interests, and in some cases, legal claims
- Collecting Business Profile Data to create and disclose Business Profiles for use by our Customers – See description above. Legitimate interests
- Processing and completing transactions, and sending you related information, including purchase confirmations and invoices – In particular, we will use your data to complete any purchases for the Services, set up billing and resolve any issues with respect to the foregoing. Performance of a contract
- Responding to your queries and requests, including to respond to rights requests and customer support requests – In particular, if you contact our support team we may use the information that you provide to us in order to help us respond to your enquiry. Our use of your personal information in this way is necessary to perform our customer service obligations to you, under our Terms of Use. If you are a Site Vistor or are an individual with a Business Profile, we may process your personal information for these purposes where it is in our legitimate interests to do so for customer services purposes. Depending on the context, performance of a contract, legitimate interests, and in some cases, legal claims
- To otherwise communicate directly with you – In particular, if you contact us or otherwise send as a communication, we may process your personal information. Depending on the context, performance of a contract, legitimate interests, and in some cases, legal claims
- Improving the content and general administration of the Platform, including to perform system maintenance and upgrades – In particular, we may use Device, Usage and Location Information to make changes to certain features or improve the Site, or use other information derived from personal information to offer new Services or make upgrades to the Platform. Legitimate interests
- Detecting fraud, illegal activities or security breaches – In particular, we may use information such as your IP address to help us prevent abuse of the Platform and investigate any potential unauthorized use of the Platform or other security breaches. Legitimate Interests
- Interacting with individuals on social media via our social media accounts and marketing our Platform – This includes any data we collect when you interact with our social media handles, and any advertising or re-targeting that we may undertake as set forth in this Privacy Policy. Consent where required (e.g., third-party cookies) or legitimate interests
- Conducting statistical analyses and analytics by monitoring and analyzing trends, usage, and activities in connection with the Platform – In particular, we do this internally or via third parties such as Google Analytics, Hotjar and other partners. Consent where required (e.g., third-party cookies) or legitimate interests
- Sending marketing communications, in line with your communication preferences
Consent (depending on location and Customer relationship) or legitimate interests - As required by applicable law, legal process or regulation – We may use your information to comply with valid court orders and similar legal or regulatory obligations which apply to us. This may include where we reasonably consider it is in our legitimate interests (or the legitimate interests of others) to comply, as well as where we are legally required to do so
Legal obligations or claims
Disclosure of Personal Information
UpLead discloses users’ information to our third party agents, contractors or service providers who are hired to perform services on our behalf. These companies do things to help us provide the Platform, and in some cases collect information directly, for example as explained in Payment Processing above. Below is an illustrative list of functions for which we may use third-party service providers:
- Hosting and content delivery network services
- Analytics services
- Lead generation partners
- Marketing and social media partners
- Customer support services
- Payment processors
- Hosting and content delivery network services
- Functionality and debugging services
Professional service providers, such as auditors, lawyers, consultants, accountants and insurers
Advertising & Marketing
We advertise our Platform by targeting (and measuring the performance of) ads to Site Visitors, Customers on other websites and platforms directly or through a variety of partners, including third party advertisers, ad server companies, social networks and ad networks (collectively, “External Ad Partners”). In order to advertise our Services, we or our External Ad Partners use the following information, whether separately or combined:
- Device Information and Location Information collected via cookies and similar technologies on our Site
- Information provided directly by Customers or individuals who reach out to us directly
- Usage Information from your use of the Platform
- Information from External Ad Partners
- Information inferred the categories of information described above.
When we serve ads based on the foregoing information, it is referred to as “targeted advertising” because External Ad Partners track your activity on and off the Site in order to deliver targeted advertising based on your activity, such as one of your visits to the Site. In addition, as noted above, the information that External Ad Partners collect from our Services may be combined with other information from other sources and be used to build profiles on you and other individuals for the purposes of delivering targeted advertising.
In addition to advertising our Services, we use Customer data and content to market our Services, promote additional features or encourage Customers to share our Platform.
You can opt-out from some third party behavioral adverting by clicking here.
Please visit our Cookie Notice for more information on the types of cookies that are used by us and our External Ad Partners within the Services, as well as information on your choices and how to opt -out.
For users in the EEA and U.K., we provide opt-in mechanisms with respect to non-essential cookies. If you opt-in and subsequently change your mind, you may withdraw your consent at any time by clicking here.
Links to Third Party Sites
Social Media
“Do Not Track”
How to Change Your Communication Preferences
Your Choices
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject first and third-party cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. For more information on controlling how cookies and similar technologies are used on the Site, see our Cookie Notice.
For users in the EEA and U.K., we provide opt-in mechanisms with respect to non-essential cookies. If you opt-in and subsequently change your mind, you may withdraw your consent at any time by clicking here.
How Long Do We Keep Your Personal information?
Data Security and Integrity
Notice to Nevada Consumers
International Transfers
We have implemented safeguards designed to ensure that the personal information we process remains protected in accordance with this Privacy Policy. Safeguards we may take in our discretion include, for instance, entering into standard contractual clauses in connection with any onward transfers of personal information, as can be viewed here for transfers from the European Union, Switzerland and the United Kingdom. We may implement other mechanisms and take similar appropriate safeguards with our third-party service providers and partners. Further details can be provided upon request.
Additional Information for Users in the EEA and the U.K.
If you are in the EEA or the U.K., you have certain rights in relation to your personal data:
- The right to be informed – our obligation to inform you that we process your personal data (and that’s what we’re doing in this Privacy Policy);
- The right of access – your right to request a copy of the personal data we hold about you (also known as a ‘data subject access request’);
- The right to rectification – your right to request that we correct personal data about you if it is incomplete or inaccurate (though we generally recommend first making any changes in your account settings);
- The right to erasure (also known as the ‘right to be forgotten’) – under certain circumstances, you may ask us to delete the personal data we have about you (unless it remains necessary for us to continue processing your personal data for a legitimate business need or to comply with a legal obligation as permitted under the GDPR, in which case we will inform you). Note that Business Profile Data may be deleted by clicking here;
- The right to restrict processing – your right, under certain circumstances, to ask us to suspend our processing of your personal data;
- The right to data portability – your right to ask us for a copy of your personal data in a common format (for example, a .csv file);
- The right to object – your right to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); Rights in relation to automated decision-making and profiling – our obligation to be transparent about any profiling we do, or any automated decision-making; and
- The right to lodge a complaint at any time to the supervisory authority for data protection issues in your country of residence – however, we ask that you please contact us first so that we can first address your concerns.
These rights are subject to certain rules around when you can exercise them.
If you are located in the EEA or the U.K. and wish to exercise any of the rights set out above, you may contact us at [email protected]. If you are in the EEA, you may contact our representative in the EU, as explained below.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request under those circumstances.
We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. If we cannot reasonably verify your identity, we will not be able to comply with your request(s).
We will 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 a number of requests. In this case, we will notify you and keep you updated as required by law.
Sometimes, UpLead acts as a ‘joint controller’ with certain third parties, namely certain social media sites, such as LinkedIn. When UpLead and a partner act as joint controllers, you (as a data subject) may exercise your rights against UpLead and/or the third party. For a list of joint controller relationships, please contact us at [email protected].
In order to market our Platform and stay in touch with users, we maintain a Facebook page and use Facebook Pixel (“Facebook Products”). With respect to our use of these Facebook Products, we are jointly responsible with Facebook Ireland for the processing activities (“Joint Processing”):
4 Grand Canal Square, Grand Canal Harbor
Dublin 2, Ireland
Information about the personal data that is collected from you by Facebook, as well as how and why it is processed by Facebook, can be found at https://www.facebook.com/about/privacy. UpLead and Facebook have entered into entered into an agreement in order to determine the respective responsibilities for compliance with our obligations in connection with the Joint Processing within the meaning of the GDPR. This joint controller agreement, which sets out the reciprocal obligations, is available here.
Please note that Facebook Ireland is responsible for enabling data subjects’ rights under Articles 15-20 of the GDPR with regard to the personal data stored by Facebook Ireland in connection with the Joint Processing, as further described in Facebook’s privacy policy. To exercise your rights, please go to your Facebook settings or contact Facebook as set forth in its privacy policy.
It cannot be excluded that some processing by Facebook Ireland Ltd. will also take place in the United States by Facebook Inc.
With respect to our use of the “Page Insights”, we are joint controllers of your personal data with LinkedIn. You may find the joint controller addendum at https://legal.linkedin.com/pages-joint-controller-addendum.
Representative in the European Union and in the U.K.
General Data Protection Regulation (GDPR) – European Representative
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), UpLead LLC has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR by:
- Using EDPO’s online request form: https://edpo.com/gdpr-data-request/
- Writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium
UK General Data Protection Regulation (GDPR) – UK Representative
Pursuant to Article 27 of the UK GDPR, UpLead LLC has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR by:
- Using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/
- Writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom
Additional Information for California Residents
This Notice for California Residents (“CCPA Notice”) supplements the information contained in the Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“Consumers”). We have created this CCPA Notice in order to comply with the California Consumer Privacy Act of 2018 (“CCPA”).
Please note that this CCPA Notice does not apply to employees and job applicants.
Within the last twelve (12) months, UpLead has collected the following categories of personal information (as defined in the CCPA) from or about Consumers (note that the lettered categories are according to lettering in the CCPA):
- A. Identifiers, such as a real name, unique personal identifier, online identifier, IP Address, email address, or account name
- B. Personal information categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)), such as a name, signature or telephone number
- C. Protected classification characteristics under California or federal law, such as age or gender
- D. Commercial information, such as records of products purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
- F. Internet or other similar network activity, such as browsing history or information on a Consumer’s interaction with a website or application.
- G. Geolocation data, such as physical location.
- H. Visual information, such as a photograph.
- I. Professional or employment-related information
- K. Inferences drawn from other personal information, such as profile information reflecting a person’s preferences.
Personal information does not include:
- Publicly available information from government records
- Deidentified or aggregated Consumer information
- Certain other information that is already regulated by other laws or regulations
Information that is specifically exempt from the scope of the CCPA.
As explained in more detail here, UpLead obtains the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, when you sign up to use the Services.
- Indirectly. For example, from observing your actions on our Services, or from the internet (including publicly-available sources) – this includes data collected via cookies (or similar technologies) or from third parties.
Service Providers
UpLead may disclose your personal information to service providers for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the services for us. As explained in more detail above, we also share your personal information with certain categories of service providers who assist us in providing our Services and with our business.
In the preceding 12 months, UpLead has disclosed the following categories of personal information for a business purpose:
- A. Identifiers
- B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- C. Protected classification characteristics under California or federal law
- D. Commercial information
- F. Internet or other similar network activity
- G. Geolocation data
- H. Visual information
- I. Professional or employment-related information
- K. Inferences drawn from other personal information
Sale of Personal Information
The CCPA defines ‘sale’ very broadly. It includes the sharing of personal information with third parties in exchange for anything of value. According to this broad definition, in the year before this section was last updated, we may have sold the following categories of personal information to third parties:
- A. Identifiers
- B. Personal information categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))
- C. Protected classification characteristics under California or federal law
- F. Internet or other similar network activity
- G. Geolocation data
- H. Visual information
- I. Professional or employment-related information
- K. Inferences drawn from other personal information
The third parties to whom we may sell personal information are:
- Our Customers
- Social Media Platforms – these third parties maintain networks connecting individuals and organizations – such as Facebook, LinkedIn, or Twitter
- Advertising Partners – these third parties help us advertise our Services
- Promotional Partners
The CCPA provides Consumers with specific rights regarding their personal information, provided that we are able to verify their identities.
Opting-out of Sales of Personal Information
If your information is contained in a Business Profile and you would like to opt-out of us selling your personal information, please click here. You can also opt-out of the sale of your personal information that is collected automatically when you visit the Site by clicking here.
Access to Specific Information and Data Portability Rights
You have the right to request that UpLead disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive your request and verify your identity, we will disclose such information to you.
Deletion Request Rights
You have the right to request that UpLead delete any of your personal information that we collected from you and retained, 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.
Note: we may deny your deletion request if retaining the information is necessary for us or our service provider(s) for certain reasons as permitted and set forth in the CCPA, in which case we will inform you of those reasons.
Exercising Your Consumer Rights
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable Consumer request related to your personal information. You may also make a verifiable Consumer request on behalf of your minor child. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
An authorized agent is a natural person or a business entity registered with the Secretary of State that a Consumer has authorized to act on his or her behalf. When a Consumer uses an authorized agent to submit a request to know or a request to delete, UpLead may require that the Consumer provide the authorized agent written permission to do so and verify his or her own identity directly with UpLead, unless the Consumer has provided the authorized agent with a valid power of attorney. UpLead may deny a request from an agent that does not submit proof that he or she has been authorized by the Consumer to act on his or her behalf.
Please note that the methods for verification are set forth in the CCPA, which also requires us to consider a number of factors, such as the type, sensitivity, and value of the personal information or the risk of harm posed by unauthorized access or deletion, on a case-by-case basis.
To exercise the rights described above, please submit a verifiable Consumer request to us by either:
- Emailing [email protected]
- Business Profile Data may be deleted by clicking here
You may only make a verifiable Consumer request for access or data portability twice within a 12-month period. We do not charge a fee to process or respond to your verifiable Consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We endeavor to respond to a verifiable Consumer request within the timeframes set forth in the CCPA. If applicable, in our response, we will also explain the reasons we cannot comply with a request.
Non-Discrimination
We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. Please note that to use our Services, we do require the collection of your personal information – for example, to sign you up or to complete a paid transaction. While you may request to delete your personal information under CCPA, such deletions may affect our ability to offer the Services.