Contents
Updated June 01, 2024
SUMMARY
This section summarizes how we obtain, store, and use information about you. It is intended to provide a very general overview only. It is not complete and must be read in conjunction with the corresponding entire sections of this Privacy Policy.
- Data controller: Steven A. Rodríguez
HOW WE COLLECT OR OBTAIN INFORMATION ABOUT YOU
- When you provide it to us (e.g. by contacting us or signing up for our e-newsletter),
- From your use of our website, using cookies, and
- Occasionally, from third parties.
- Information we collect: Name, contact details, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), company name or business name (if applicable), VAT number (if applicable).
- How we use your information: For administrative and business purposes (particularly to contact you, to improve our business and website, to fulfill our contractual obligations, to advertise our goods and services, to analyze your use of our website, and in connection with our legal rights and obligations.
- Disclosure of your information to third parties: Only to the extent necessary to run our business, to our service providers, to fulfill any contracts we enter into with you, where required by law or to enforce our legal rights.
- Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No
- How long we retain your information: For no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business). How long we retain your information. For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled how long we retain your information.
- How we secure your information: Using appropriate technical and organizational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary.
- Use of cookies: We use cookies and similar information-gathering technologies on our website including essential, functional, analytical and targeting cookies. For more information, please visit our [cookies policy here](https://orangeup.info/cookie-policy).
- Transfers of your information outside the European Economic Area: We will only transfer your information outside the European Economic Area if we are required to do so by law. Where we do so, we will ensure appropriate safeguards are in place.
- Use of automated decision making and profiling: We use automated decision making and profiling. e.g. use of web analytics, cookies, web beacons or server logs analysis tools (profiling) or use targeting cookies to display advertisements to people who visit our website on other websites around the internet.
- Your rights in relation to your information
- To access your information and to receive information about its use
- To have your information corrected and/or completed
- To have your information deleted
- To restrict the use of your information
- To receive your information in a portable format
- To object to the use of your information
- To withdraw your consent to the use of your information
- Not to have significant decisions made about you based solely on automated processing of your information, including profiling
- To complain to a supervisory authority
- Sensitive personal information: We do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information
OUR DETAILS
The data controller in respect of our website is Steven A. Rodríguez of OrangeUP Inc., [Mailing Address] 161-26 Grand Central PKWY, Jamaica, NY 11432-1132. You can contact the data controller by writing to the mailing address provided or sending an email to [email protected].
If you have any questions about this Privacy Policy, please contact the data controller.
INFORMATION WE COLLECT WHEN YOU VISIT OUR WEBSITE
We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.
Web Server Log Information
We use a third party server to host our website. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.
Our server is located in the United States.
Use of Website Server Log Information for IT Security Purposes
Our third party hosting provider collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analyzing log files to help identify and prevent unauthorized access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.
Legal basis for processing: Compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: We have a legal obligation to implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.
Legal basis for processing: Our and a third party’s legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: We and our third party hosting provider have a legitimate interest in using your information for the purposes of ensuring network and information security.
Use of Website Server Log Information To Analyze Website Use And Improve Our Website
We use the information collected by our website server logs to analyze how our website users interact with our website and its features. For example, we analyze the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser used.
We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based on what users are engaging most with and the duration of time spent on particular pages on our website.
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: Improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.
Cookies And Similar Technologies
Cookies are data files which are sent from a website to a browser to record information about users for various purposes.
We use cookies and similar technologies on our website, including essential, functional, analytical and targeting cookies and web beacons. For further information on how we use cookies, please see our cookies policy which is available here: insert link
You can reject some or all of the cookies we use on or via our website by changing your browser settings, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.
INFORMATION WE COLLECT WHEN YOU CONTACT US
We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.
When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): Responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
The reason why it is necessary to perform a contract: Where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Transfer and storage of your information
We use a third party email provider to store emails you send us. Our third party email provider is HubSpot Inc. located in the USA. Their privacy policy is available [here].
Emails you send us will be stored outside the European Economic Area on our third party email provider’s servers in the USA. For further information please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.
Contact Form
When you contact us using our contact form, we collect your Name, Email Address, and Telephone Number.
If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): Responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
The reason why it is necessary to perform a contract: Where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Transfer And Storage of Your Information
Messages you send us via our contact form will be stored outside the European Economic Area on our third party hosting provider’s servers in the United States. Our third party hosting provider is located in the USA. Their privacy policy is [available here].
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
We use a third party contact form provider to store messages you send us. Our contact form provider is HubSpot Inc. located in the USA. Their privacy policy is [available here].
Messages you send to us via our contact form will be stored outside the European Economic Area on our contact form provider’s servers in the USA.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Phone
When you contact us by phone, we collect your phone number and any information provided to us during your conversation with us.
We do not record phone calls.
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): Responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
The reason why it is necessary to perform a contract: Where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Transfer And Storage of Your Information
Information about your call, such as your phone number and the date and time of your call, is processed by our third-party telephone service provider RingCentral which is located in the USA. Their privacy policy is [available here].
Information about your phone call will be stored by our third-party telephone service provider within the United States.
Post
If you contact us by post, we will collect any information you provide to us in any postal communications you send us.
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): Responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
The reason why it is necessary to perform a contract: Where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
OUR USE OF AUTOMATED DECISION-MAKING AND PROFILING
We use automated decision making and profiling on our website. We do not consider that this has any legal effect on you or similarly significantly affects you.
You have the right to object to our use of automated decision making and profiling described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.
You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is [available here](https://www.orangeup.info/cookie-policy).
Automated decision making
Automated decision making is decision making by technological means (i.e. by a machine) without human involvement.
Use of automated decision making for display advertising
We automate the display advertisements containing our services on other websites you visit, based on the fact that you have visited our website using cookies. For further information on the cookies we use, please see our cookies policy which is [available here].
Logic involved: Automatically displaying advertisements to individuals who have visited our website results in increased efficiencies and costs savings for us than manually displaying advertisements or displaying advertisements by different means.
Significance and envisaged consequences: Cookies will be used to recognize the fact that you have visited our website in order to display advertisements to you (unless you have blocked such cookies) and will collect information about your online behavior.
How to object: You can block these cookies by using the cookies control management tool on your site (if you use one)] or by blocking third party cookies using browser settings.
For further information, please see [our cookies policy here].
Profiling
Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
Use of Profiling For Web Analytics
Our web analytics service, Google Analytics uses collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on). We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with [our cookies policy]. Information collected about you, once collected, is anonymized and stored on an aggregate basis.
Logic involved: By automatically analyzing and categorizing information such as the location (based on IP address) as well as the behavior and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.
Significance and envisaged consequences: Cookies will be used to track and store information about your behavior and device on our website (unless you have opted out from receiving such cookies by downloading and installing a web browser compatible with the Chrome, Internet Explorer 11, Safari, Firefox or Opera (for more information please visit: https://tools.google.com/dlpage/gaoptout) and your location will be analyzed based on your IP address. We may target advertisements based on the level of interest we receive from certain visitors and their behavior on our website.
Use of profiling in marketing emails
We use web beacons and other technologies in our marketing emails to analyse who opens our emails and what actions they take (for example, what they click on). We will only process information from web beacons if you have consented to their use in accordance with [our cookies policy here].
Logic involved: By analyzing how our email recipients respond to our emails, we are able to improve the content and effectiveness of our emails and gauge who is most interested.
Significance and envisaged consequences: Your behavior when you open our emails will be tracked using small gif files (web beacons) and insert any other technologies used, including open rates, and click-through rates.
How to object: You can contact us through email at [email protected].
Legal basis for processing: Legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: Analyzing the level of engagement and effectiveness of our marketing emails and content.
DISCLOSURE AND ADDITIONAL USES OF YOUR INFORMATION
This section sets out the circumstances in which we will disclose information about you to third parties and any additional purposes for which we use your information.
Disclosure of Your Information To Service Providers
We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:
Disclosure of Your Information To Other Third Parties
We disclose your information to other third parties in specific circumstances, as set out below.
Providing information to third parties such as Google Inc.. Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymized basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): Meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)
You can opt out of Google Analytics by [installing the browser plugin here].
Transfer and storage of your information
Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, affiliates, business partners, and independent contractors. Further information on each of these third parties is set out below.
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: Running and managing our business efficiently.
Accountants
We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.
Business partners
Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services.
Disclosure And Use of Your Information For Legal Reasons
Indicating possible criminal acts or threats to public security to a competent authority
If we suspect that criminal or potential criminal conduct has occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that a fraud or a cybercrime has been committed or if we receive threats or malicious communications towards us or third parties.
We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: Preventing crime or suspected criminal activity (such as fraud).
In connection with the enforcement or potential enforcement of our legal rights
We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: Enforcing our legal rights and taking steps to enforce our legal rights.
In connection with a legal or potential legal dispute or proceedings
We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): Resolving disputes and potential disputes.
For ongoing compliance with laws, regulations and other legal requirements
We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.
Legal basis for processing: Compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation.
Legal obligation(s): Legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: Where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.
HOW LONG WE RETAIN YOUR INFORMATION
This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.
Retention Periods
Server log information: we retain information on our server logs for 1 year.
Correspondence and enquiries: When you make an enquiry or correspond with us for any reason, whether by email or via our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry.
E-Newsletter: We retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.
Criteria for determining retention periods
In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:
- The purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
- Whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
- Whether we have any legal basis to continue to process your information (such as your consent);
- How valuable your information is (both now and in the future);
- Any relevant agreed industry practices on how long information should be retained;
- The levels of risk, cost and liability involved with us continuing to hold the information;
- How hard it is to ensure that the information can be kept up to date and accurate; and
- Any relevant surrounding circumstances (such as the nature and status of our relationship with you).
HOW WE SECURE YOUR INFORMATION
We take appropriate technical and organizational measures to secure your information and to protect it against unauthorized or unlawful use and accidental loss or destruction, including:
- Only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
- Using secure servers to store your information
- Verifying the identity of any individual who requests access to information prior to granting them access to information;
- Using Secure Sockets Layer (SSL) software to encrypt any payment transactions you make on or via our website
- Only transferring your information via closed system or encrypted data transfers.
Transmission of information to us by email
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
TRANSFERS OF YOUR INFORMATION OUTSIDE THE EUROPEAN ECONOMIC AREA
Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organization in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.
Server Log Information
Information collected when you visit our website is transferred outside of the EEA and stored on the servers of our third party hosting company Interserver Inc. located in the USA. You can access their privacy policy here: https://www.interserver.net/terms-of-service.html
Country of storage: USA. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: Our third party hosting provider has self-certified its compliance with the EU-U.S. Privacy Shield.
Contact Form
Information you submit to us via our contact form is transferred outside the EEA and stored on our third party hosting provider’s servers. Our hosting provider is: Interserver Inc. located in the USA. You can access their privacy policy here: https://www.interserver.net/terms-of-service.html
Country of storage: USA. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: Our third party hosting provider has self-certified its compliance with the EU-U.S. Privacy Shield.
Information you submit to us by email is transferred outside the EEA and stored on our third party email provider’s servers. Our third party email provider is: Google Inc. You can access their privacy policy here: https://policies.google.com/privacy?hl=en-US
Country of storage: USA. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: Our third party email provider has self-certified its compliance with the EU-U.S. Privacy Shield.
E-Newsletter
Information you submit to us when you sign up for our e-newsletter is transferred outside the EEA and stored on our third party mailing list provider’s servers. Our third party mailing list provider is: HubSpot Inc. You can access [their privacy policy here].
Country of storage: USA. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: HubSpot Inc. has self-certified its compliance with the EU-U.S. Privacy Shield.
Google Analytics
Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/
Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the [EU-U.S. Privacy Shield here].
YOUR RIGHTS IN RELATION TO YOUR INFORMATION
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to OrangeUP Inc of 161-26 Grand Central PKWY, Jamaica, NY 11432-1132 or sending an email to [email protected]:
- To request access to your information and information related to our use and processing of your information;
- To request the correction or deletion of your information;
- To request that we restrict our use of your information;
- To receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
- To object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
- To withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
- The right not to be subject to a decision based solely on automated processing, including profiling which produces legal effects concerning you or similarly significantly affects you.
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are [available here](https://ico.org.uk/global/contact-us/).
Further information on your rights in relation to your personal data as an individual
The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:
- https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and
- https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf
Verifying your identity where you request access to your information
Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and reduce the risk of identity fraud, identity theft or general unauthorized access to your information.
How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
YOUR RIGHT TO OBJECT TO THE PROCESSING OF YOUR INFORMATION FOR CERTAIN PURPOSES
You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to Steven A. Rodríguez of OrangeUP Inc, [Mailing Address] 161-26 Grand Central PKWY, Jamaica, NY 11432-1132, or sending an email to [email protected]:
- To object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analyzing or predicting your behavior based on your information) based on any of these purposes; and
- To object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).
You may also exercise your right to object to us using or processing your information for direct marketing purposes by:
- Clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
- Sending an email to [email protected], asking that we stop sending you marketing communications or by including the words “OPT OUT”.
For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is [available here].
SENSITIVE PERSONAL INFORMATION
‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.
We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.
CHANGES TO OUR PRIVACY POLICY
We update and amend our Privacy Policy from time to time.
Minor Changes To Our Privacy Policy
Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.
Major changes to our Privacy Policy or the purposes for which we process your information
Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.
CHILDREN’S PRIVACY
Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to [email protected].
CALIFORNIA DO NOT TRACK DISCLOSURES
“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org
At this time, we do not respond to Do Not Track browser settings or signals. In addition, we use other technology that is standard to the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal. For information on how to opt out from tracking technologies used on our website, see our cookies policy which is [available here].
COPYRIGHT, CREDIT AND LOGO
This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy. For further information, please visit https://gdprprivacypolicy.org
The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.
Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.
ANTI-SPOOF & PHISHING POLICY
This Anti-Spoof & Phishing Policy details domains controlled and operated by our organization and the policies that have been applied to each domain.
To protect our customers, subscribers, our brand and reputation against spoof email messages, and to ensure visibility over how we operate our domains we have implemented Trusted Sender Score.
This policy is a reference point for all internet users to check as to how we use and protect our domains.
The domains listed in this policy show which domains we use to send email and which domains do not send email.
A link is provided to each Trusted Sender Score domain profile which provides further information on each domain configuration.
If you receive emails or links that try to represent our domains in an unauthorized manner please check this policy and if you are still unsure please contact us to confirm the legitimacy of the email, link or web page.
orangeup.info – Is used to send email
orangeup.biz – Is used to send email
orangeup.org – Is used to send email
SMS MESSAGING
We send SMS Messages if you have enquired and/or have an active agreement with us.
SOCIAL MESSAGING
We send messages from social media if you have enquired and/or have an active agreement with us.
