PRIVACY POLICY
Universal Conversion Technologies (“UCT”, “we”, “us” and “our”) provides to its business customers a suite of front-to-back technology solutions, sales-oriented solutions and data conversion solutions and services with global points-of-presence. At UCT, we understand the importance of protecting personal information. For this reason, we have business procedures and security safeguards in place to protect all personal information under our control, and to ensuring the confidentiality of the personal information entrusted to us in the course of our business transactions.
Our Privacy Policy sets out our standards for collecting, using, communicating and storing your personal information. This policy also explains our responsibilities and your rights as a user of our applications.
WHAT’S IN THIS PRIVACY POLICY?
Application and Scope
Your Consent
Data Collection
Privacy Policies of Third Parties
Use of Personal Information
Sharing of Personal Information
Storage of Personal Information and Cross-border Transfers
Security of Personal Information
Retention of Personal Information
Opting Out of Communications
Your Rights Regarding Personal Information
Contact Us
Change of Privacy Policy
Application and Scope
By accessing, consulting, or visiting our website, https://www.uctcorp.com, our platforms or our applications (together the “Website”), by contacting us or by agreeing to receive e-mails from us, by using our services, you agree to the terms of this Policy. The Website and the various associated services are collectively referred to as the “Services”.
This Policy is incorporated and subject to our other applicable terms and conditions, such as the Terms of Use of our Website. In this Policy, terms beginning with a capital letter, but not defined, have the meanings given to them in the above terms.
This Privacy Policy (“Policy”) explains how UCT uses and discloses information collected from you and it also explains how we use cookies and similar technologies.
Your consent
When we gather personal information about you, we shall obtain your consent to use the information for the purposes for which it was gathered. We must obtain your consent to use your personal information for any other purposes or for gathering additional information about you. We generally seek your express written consent in order to gather, use or communicate your personal information. Under certain circumstances, for less sensitive information, we may accept your verbal consent. From time to time, and according applicable privacy laws, we may infer your implicit consent from your action or inaction. Consent must be given by you or by your duly authorized representative, such as a legal guardian or a person holding power of attorney.
You may withdraw your consent at any time, subject to legal or contractual restrictions. We shall inform you of the consequences of such a withdrawal, including the possibility that we may no longer be able to provide you with a product or service. If you choose to withdraw your consent, we shall record the decision in our file. In certain situations, we have the right (or obligation) to gather, use or divulge personal information without your knowledge or consent. This occurs when legal, medical, or security reasons may make it impossible or difficult to obtain consent. When information is being gathered for the purpose of investigating a potential breach of contract, the prevention or detection of fraud, or for law enforcement purposes, obtaining consent may defeat the purpose of gathering the information. In certain cases, obtaining consent may be impossible or untimely if you are a minor, seriously ill or incapacitated.
Data Collection
Personal Information is defined as any information concerning an individual and which allows one to identify the individual, such as financial, lifestyle or health information. Personal information must be protected regardless of the nature of its characteristics or its form, whether written, graphic, audio, visual, computerized or other.
Gathering information concerning you is necessary in order for us to provide you with high quality services. The nature and sensitivity of the information that we gather about you varies according to the services that we provide to you and to the legal requirements imposed on us (such as your social insurance number, where investment income is generated by a chosen product). The purposes for which we gather your personal information are determined at or before the time of gathering.
In general, when you access, visit or use our Services, we may collect the following data:
A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit our website, we may collect, using electronic means such as cookies, technical information. This information may include information about website users’ visits, including the IP address of the computer and type of browser used to view our website, the operating system, resolution of screen, location, language settings in browsers, the site the website visitors came from, keywords searched (if arriving from a search engine), the number of page views, information entered, advertisements seen, etc. This data is used to measure and improve the effectiveness of our website or enhance the experience for our website users. We may also collect and use the following type of information when online users visit and/or interact with us on our websites:
Google Analytics
We use Google Analytics which allows us to see information on user website activities including, but not limited to, page views, source and time spent on our website. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. Online users may opt-out of Google Analytics by visiting the Google Analytics opt-out page.
Google AdWords
We use Google AdWords Remarketing to advertise UCT across the Internet and to advertise on third party websites (including Google) to previous visitors to our websites. AdWords remarketing will display ads to our website visitors based on what parts of the UCT website they have viewed by placing a cookie on their web browser. This cookie does not in any way identify the website visitor or give access to such visitor’s computer or mobile device. The cookie is only used to indicate to other websites that a particular page on our website has been visited, so that ads relating to that page may be shown. If online users do not wish to participate in Google AdWords Remarketing, they can opt out by visiting Google’s Ads Preferences Manager.
For more information on cookies, please refer to the Cookies Policy [NTD: link to be inserted].
Privacy Policies of Third Parties
This Policy only addresses the use and disclosure of information by UCT. Other websites of third-parties that may be accessible through our website have their own privacy policies and data collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information or taking advantage of an offer or promotion.
Unless required or authorized by law, UCT will not collect or use personal information for any other or new purpose without obtaining further consent.
Use of Personal Information
We may use your personal information and other information for purposes such as:
We may use your personal information and other information for purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable law.
Sharing of Personal Information
Personal information that we collect, access or process may be made available by UCT to third parties or service providers to fulfill the purposes for which it has been collected or as set forth in this Policy. UCT will not sell, rent or trade personal information to any third party. However, we may share personal information when authorized and/or required by law or as follows:
We may hire service providers to perform services on our behalf. This may include, without limitation, a person or an organization retained by UCT to perform work on its behalf. We provide them with a limited amount of information which is necessary in order for them to provide the services required. They are prohibited from using the information for purposes other than to facilitate and carry out the services they have been engaged to provide. These service providers are not permitted to disclose this information to others. UCT will strive to protect personal information disclosed to third parties using contractual agreements requiring that those third parties adhere to confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by UCT itself.
Please find below a list of our third-party service providers that may process your personal information:
We may disclose personal information when UCT is compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant, government investigation or other legally valid request or enquiry. We may also disclose information to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights. We may also release certain personal information when we have reasonable grounds to believe that such release is reasonably necessary to protect the rights, property and safety of others and ourselves, in accordance with or as authorized by law.
We may disclose personal information to a third party in connection with a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets. However, in the event the transaction is completed, personal information will remain protected by applicable privacy laws. In the event the transaction is not completed, we will require the other party not to use or disclose your personal information in any manner whatsoever and to completely delete such information.
Storage of Personal Information and Cross-border Transfers
Your personal information may be stored in any country where we have facilities or in which we engage third party service providers. As a result, your personal information may be transferred to countries outside your country of residence, which may have different data protection rules than in your country. While such information is outside of your country, it is subject to the laws of the country in which it is located,and may be available to government authorities under lawful orders and laws applicable there.
However, our practices regarding your personal information will at all times continue to be governed by this Privacy Policy and, if applicable, we will comply with the General Data Protection Regulation ("GDPR") requirements providing adequate protection for the transfer of personal information from the EU/EEA to third country.
Security of Personal Information
We will use reasonable security measures to protect personal information against unauthorized access that are compliant with applicable data protections laws. UCT has implemented security measures that contain administrative, technical and physical controls that are designed to safeguard personal information.
Despite the measure outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information in the “Contact Us” section below.
Retention of Personal Information
Personal information that we collect, access or process will be retained only as long as necessary for the fulfilment of the purposes for which it was collected and/or for which consent was received, unless otherwise required by law. Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased or made anonymous. UCT will ensure destruction of personal information in a method that prevents improper access.
Opting Out of Communications
If you no longer want to receive marketing-related e-mails from us, you may opt-out of receiving marketing-related e-mails by clicking the “unsubscribe” link at the bottom of any e-mail you receive from us, or, if you created an online account when you registered to receive our e-mails, you may log-in to your account and make changes to your communication preferences. You may also opt-out by contacting us directly using the contact information in the “Contact Us” section below.
We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request. Please note that if you opt-out from receiving marketing-related e-mails, we may still need to send you communications about your use of our products or services, or other matters.
Your Rights Regarding Personal Information
We will take steps to ensure that your personal information is kept as accurate, complete and up-to-date as reasonably necessary. We will not routinely update your personal information, unless such a process is necessary. We expect you, from time to time, to supply us with updates to your personal information, when required.
You may make a written request to access or to correct any personal information about you that we have collected, used or disclosed, and we will provide you with any such personal information to the extent required by law. You may also challenge the accuracy or completeness of your personal information in our records. If you successfully demonstrate that your personal information in our records is inaccurate or incomplete, we will amend the personal information as required.
Where applicable, under the GDPR, you may be entitled to additional rights, including: (i) the right to withdraw consent to processing where consent is the basis of processing; (ii) the right to object to unlawful data processing, under certain conditions; (iii) the right to erasure of personal information about you, under certain conditions; (iv) the right to demand that we restrict processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, are processing, or believe your personal information is inaccurate; (v) the right to data portability of personal information concerning you that you provided us in a structured, commonly used, and machine-readable format, under certain conditions; (vi) the right object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you, under certain conditions. If you want to learn more about your rights under the GDPR, you can visit the European Commission's page on Data Protection at: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.
This information will be provided to you within a reasonable length of time from the date we receive your written request but no later than one month, it being specified that period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We can charge a reasonable fee for processing your request.
Under certain specific circumstances, we can refuse to provide the requested information to you, notably if the request is manifestly unfounded or excessive, if it would be extremely costly to provide the information requested, information containing references to other individuals, that information cannot be disclosed for legal, security or business proprietary reasons, that information has been obtained during the course of an investigation of a potential breach of contract or to prevent or detect fraud, and even information that is subject to lawyer-client or judicial privilege.
You also have the right to lodge a complaint with data protection authorities.
We may require that you provide sufficient identification to fulfill your request to access or correct your personal information. Any such identifying information will be used only for this purpose.
Contact Us
Any questions or complaints regarding this Policy or UCT’s handling of personal information can be addressed by sending an e-mail to our privacy officer privacy@uctcorp.com.
Change of Privacy Policy
UCT will review and update its policies and procedures as required to keep current with rules and regulations, new technologies, standards and customer concerns. Our Policy may therefore change from time to time. We will post any changes on our website and, if the changes are material, we will provide a more prominent notice.
This Policy was last updated on October 28, 2020.
[Please note that the English, Spanish and French versions of our Policy have equal legal value.]