PRIVACY POLICY – PRODUCTS AND SERVICES UPX

Welcome to UPX. When using our websites, products and services (“UPX services”), rules and standards of our Privacy Policy, appropriate to the relevant legislation, will apply for greater security and transparency in the treatment of data provided by users. 

As our products and services are varied and UPX always seeks improvement and innovation, additional Terms, Licenses and Contracts may provide for specific terms and conditions of use for each product or service. Such documents will be available to each client and user in their access panel when contracting UPX products and services. Federal Brazilian Law no. 13,709 / 2018 (LGPD - General Data Protection Law) will be applied for data and information from brazilian citizens.

I. PERSONAL DATA – COLLECT & USE

UPX only collects data necessary for the Contract and for the execution of products and services. In this way, data will be collected from the legal entity, (eg. Corporate Name, address, telephone, e-mail) and from the individual authorized representative of the company to sign contracts and participate in the management of the contracted services (eg. full name, official identification document, e-mail, telephone, business position and address).

Other data may be collected depending on the use and experience of the products and services, such as eg, usage time data, monitoring via "cookies", date and time of access to the website, among others necessary for the good execution of UPX products and services.

If you do not wish to provide data necessary for the use of a product or services, you will not be able to use it. The time for using and processing the data will be the validity period foreseen in the UPX product and service contracts, which each customer has access at the time of contracting, or as long as the user wishes to keep his customer account active in the UPX systems. The data may also be stored under the law or required by public entities  and authorities.

Personal data will be used to prepare and sign contracts and legal documents between the parties, as well as to identify users and their use of products and services, access to the customer panel, payment and purchase processing, to improve, develop and personalize the products. and services and communication with the customer, including sending promotional offers, advertisements and advertising.

There may be other specific purposes for using data depending on the product or service, due to its technical characteristics, which will be expressly informed in the respective contract. The user who signs contracts and accepts the expression of consent on behalf of a legal person, declares, under the penalties of the law, that he is his legitimate legal representative (eg partner, manager, employee, agent or legal attorney). 

In order to improve the quality of our services, in some cases, we remove the personal identity from the data transmitted by you. Such data is gathered to others to produce aggregated and anonymous statistical information (eg number of visitors, source IP address and country of the internet access provider's domain, date and time of access). 

Services in which the user wishes to protect his data on the internet or monitor if there has been a leak (eg financial data such as a credit card), UPX will use the personal data provided by the user or third party Controller (eg financial institutions or public entities), authorized under legal terms, for the purpose of executing the digital protection service, seeking to anonymize data whenever possible.

II. COOKIES 

UPX’s websites, products and services may use "cookies". Cookies are text files generated by your browser that are placed on your computer's hard drive when you access certain websites. Cookies help to inform you whether or not you have visited the website before, it helps to identify resources in which you may be most interested, filling out data in forms, saving passwords and preferences, improving the online experience. 

When required by law, you can visit our websites and refuse the use of cookies at any time on your computer. The refusal to use cookies may impact or prevent the use of resources, products and services, depending on your need for use.

III. USER’S SAFETY OBLIGATION

UPX uses security systems, rules and other procedures to ensure the protection of personal data, as well as to prevent unauthorized access to data, improper use, disclosure, loss or destruction. However, despite UPX's best efforts, it is the duty of each user to ensure and ensure that their computer is adequately protected against harmful software, such as viruses, spyware, adware, unauthorized remote access, among other activities and programs malicious in the digital environment. 

In addition, you should be aware that, without the adoption of adequate security measures (for example, the secure configuration of your browser, use of updated antivirus software, “firewall”, non-use of software of illegal or doubtful origin), the risk of the personal data and passwords to be accessed by third parties, without authorization to do so, is considerably higher. 

It is also advised that whenever data is provided on open and public networks, such as the Internet, your data may circulate without security conditions, with the risk of being seen and used by unauthorized third parties. So, follow the basic rules of digital security, keeping your computer and your data safe.

IV. RIGHTS OF PERSONAL DATA HOLDERS

Personal data is all information related to the identified or identifiable natural person. The data will only be used for the specific purposes of access and use of users to the products and services offered and their contracting. The holder of personal data has the right to request the correction and updating of his data, as well as to ask about its use and treatment and to cancel his consent. 

If it is necessary to provide information on minors (child and teenager under 18), they can only be provided with express parental consent, and UPX does not promote or market its products and services to minors under age 18. 

You can contact UPX through the means provided at the end to answer questions and exercise your rights, such as access and correcting data, requesting exclusion, providing additional consent or revoking it, opt-out, portability and data transfer, file a complaint among others provided for in the legislation. Florida State law will apply for UPX Miami-LLC Company data operations.

V. DATA TRANSFER

By providing our services for the benefit of our customers or between our branches, we may process personal data on behalf of a Controller (whether a customer or any other UPX branch or unit) primarily for the effective operation, management, performance and delivery of our services and products in Brazil and internationally. The personal data processed will be treated in an appropriate, relevant and limited to what is necessary for the purposes for which they will be processed.

Personal data will only be shared with relevant personnel within UPX Group companies, including UPX US LLC, or with duly authorized employees, contracted or subcontracted, and outsourced companies that are part of the UPX product and service supply chain and data processing, in order to guarantee the execution and quality of the services and products offered, guaranteeing commercial and technical operability.

You can at any time request information about the use and treatment of your data, according to the service channels made available at the end. According to Brazilian, American and European legislation on the protection of personal data, the international transfer of personal data will only be made to countries that guarantee an adequate level of protection. If international data transfer is required for a country that does not yet meet European and Brazilian standards for the protection of personal data, due to the need to execute the contracted product or service, UPX will inform the customer and provide additional protection so that the transferred data remains adequately secure.

UPX may eventually be required to disclose personal data to regulatory authorities, Court’s, agencies or other governmental entities and will only do so when there is a clear legal requirement, court order or to defend rights, interests and property of UPX and related third parties, especially its customers, always seeking to protect the privacy and confidentiality of third party data in their custody to the maximum. Except for the above, we will not share your personal data unless you request or have prior approval for sharing.

VI. PRIVACY POLICY - UPDATE

The PRIVACY POLICY may be changed at any time, at UPX's discretion and in accordance with any legal changes and / or judicial and administrative requirements. When the change occurs, customers will be informed by e-mail or on the access panel to products and services.

VII. DATA CONTROLLER IDENTIFICATION AND CONTACT CHANNELS

All our products and services are provided by UPX TECNOLOGIA LTDA, with address at Rua Guapuruvu, nº 200, Sala 02, CEP 13.098-322, ALPHAVILLE CAMPINAS, CAMPINAS-SP, Brazil, registered with CNPJ / MF no. 08.184.140 / 0001-79, telephone +55 (19) 3368-0609, contato@upx.com and UPX US LLC, headquartered at UPX US LLC 318, Atlantic Isle, Sunny Isle Beach, 33160 - FL - USA, contact@upx.com. 

The data reported above (UPX TECNOLOGIA LTDA) also refer to the Personal Data Controller (“Data Protection Officer”), for the purposes of Brazilian Law No. 13,709 / 2018 (LGPD - General Data Protection Law). The holder of personal data will be able to contact UPX in its Customer Service through the following channels: e-mails dpo@upx.com and contact@upx.com, telephone +55 (19) 3368-0609.