Privacy Policy

Data Protection Addendum (DPA)

California Privacy Choices

California Supplemental Privacy Notice

Privacy Notice for Utobo Users in California

Privacy Policy

Last updated: 10.18.2022

1. Introduction

We at utobo Inc., a Delaware C Corp, are committed to protecting your privacy. This Privacy Policy applies to the information and data collected by utobo when you interact with our websites, product and services, and any other sites or services that link to this Privacy Policy. This includes when you:
- use our product and services
- Interact with us through events and webinars

This Privacy Policy describes how we collect, receive, use, store, share, transfer, and process your Personal Data. For the purposes of this Privacy Policy "Personal Data" means any information relating to an identified or identifiable individual. If you do not agree with this Privacy Policy, you must not use our websites, product and services, or any other sites or services that link to this Privacy Policy.

2. Information that you provide to utobo:

We may collect information that you provide when using our website, product and services, such as when you: (a) Sign-up for a free trial (b) subscribe to our Product and services (c) participate in events, promotions and community discussions; (d) send questions or comments via email or live chat; (e) interact with our team and affiliates; (f) apply for a job using our website; (g) fill out surveys and feedback forms.

The types of personal information that you provide may include your full name, email address, telephone number, billing address, debit/credit card information, and other contact or identifying information that you choose to provide. We store, process, and maintain files and content that you create and/or upload using our Product and services, as well as other data related to your account in order to provide the Product and services to you.

We do not store any credit/debit card information we receive except as necessary to complete and satisfy our rights and obligations with regard to such transaction, invoice generations, and/or as otherwise authorized by you.

3. Information we collect from your usage of our products and services:

We collect usage data when you or your users in your utobo account interact with the Subscription Service. Usage data includes metrics and information regarding your use and interaction with the Subscription Service such as what product features you use the most, when your raise a ticket and close a ticket etc. We engage third party providers to collect usage data. For more information about how we protect your information with these service providers, please see Section 4 and Section 5.

You may connect third party integrations to your utobo account, which may ask for certain permissions to access data or send information to your utobo account. It is your responsibility to review any third-party integrations you authorize. Any permission(s) granted by you, grants these third parties access to your data, which may include (but is not limited to) granting third party applications access to view, store, and modify your utobo account data. We are not responsible for the practices of third-party integrations, so please carefully review the permissions you grant to third party applications.

We may receive information about you or other users of your utobo account from our network of affiliates and partners. We may receive this data from our deal and lead registration process through our partners and social media sites such as LinkedIn, Facebook, Instagram, Twitter.

If you participate in a video conference with us, we may record the session and retain the recordings. We will notify you first that the session is being recorded so that you can choose to terminate the meeting. If you participate in a training or product course, we collect completion data.

We may receive information from third party service providers, from related companies, and from our business and solution partners.

Like most websites and technology services delivered over the Internet, we automatically collect and store information about your computer hardware and software when you visit our websites, use our product and services, or visit other sites or services that link to this Privacy Policy. This information can include your IP address, browser type, domain names, internet service provider (ISP), and the files viewed on our websites (e.g., HTML pages, graphics, etc.), the files viewed on our, or our customer’s websites (if those websites are hosted on utobo e.g. HTML pages or, graphics etc), your operating system, access times and referring website addresses.

We use a variety of technologies to collect this information, such as first party and third-party cookies and tracking services that employ cookies and page tags. This data includes usage and user statistics. Emails sent by utobo or by users through our Product also include page tags that allow the sender to collect information about who opened those emails and clicked on links in them.

4.How we use the information we collect

We may use the personal information collected through our Product/Services to:
• To communicate with you about our product and services.
• To Improve and Develop Our Product and Services.
• Promote and advertise about our product, services, and offerings.
• Process subscription transactions and send you relevant information such as invoice and transaction summary.
• Send you technical notices, updates, security alerts, and support and administrative messages.
• Respond to your comments, questions, and requests and provide you with requested customer support.
• Monitor and evaluate trends, usage, and activities in connection with our Product and services.
• Secure our systems, prevent fraud, and help us to protect the security of your account.
• Prevent, detect, and investigate potentially prohibited or illegal activities and to enforce our terms and policies.
• Personalize and improve the Product, and provide content, communications, or features that match users’ interests and
• Link or combine with other information we obtain from third parties to help understand your needs and provide you with better service

We always reserve the right to review your content and information to help resolve problems with our software, Product and services, or to ensure that you remain in compliance with our Terms of services, Creators Terms and End User License Agreement.

5. Information we may share

We will never “sell” your personal information (as that term is defined in the California Consumer Privacy Act). However, we may share your personal information with third parties as follows:

1. Third Party Service Providers
We use third party service providers to support our websites, products, and services. For example, we use service providers for data hosting, software application design and development, sales and marketing. We may need to share your information with service providers to provide information about products or services to you. Examples may include hosting your course video, PDF on server, analyzing data or performing statistical analysis on your use of the Subscription Service or interactions on our websites, providing marketing assistance, processing debit and credit card payments, supplementing the information you provide us in order to provide you with better service, developing and improving the product and services, and providing customer service or support. These service providers are prohibited from using your Personal Data except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we share your information in this way, we explicitly require the third-party service providers to acknowledge and adhere to our privacy and data protection policies and standards.

2. Business affiliates and partners
We may share data with trusted utobo affiliates and partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide sales support, or provide customer support. Partners are prohibited from using your Personal Data except for these purposes, and they are required to maintain the confidentiality of your data. We also partner with trusted third parties to provide you with co-marketing content that we think may be relevant to you.

3. Change in ownership
If utobo is acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by utobo on the websites and the Subscription Service. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Data, and choices you may have regarding your Personal Data.

4. Public Forums
Our websites may offer publicly accessible message boards, blogs, and community forums (e.g. utobo Slack and Facebook community). Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums (including profile information associated with the account you use to post the information) it may be read, collected and used by any member of the public who accesses these websites. Your posts and certain profile information may remain even after you terminate your account. We urge you to consider the sensitivity of any information you may disclose in this way.

5. Compelled Disclosure
We reserve the right to use or disclose your Personal Data if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.

6. Advertising and analytics services provider by others
We may allow others to provide analytics services and display advertisements for our Product. These providers (for example, Google Analytics, Microsoft Clarity, HubSpot Analytics,Intercom Chat & Support) may use cookies, web beacons, device identifiers, and other tracking technologies that collect information about your use of our Product. This information may be used by us and others to determine the popularity of our Product, deliver advertising and content targeted to your interests in the Product, and on other websites, apps, and other services, and to better understand your online activity.

6.Where we store your personal data

(a) Data Storage: All data you provide through our Product is stored on our server providers, Microsoft Azure, and AWS servers, located in the USA. Any payment transactions will be encrypted using SSL technology; all payment data is stored by our payment processor Stripe and is never stored on our servers.

(b) Data Security: Utobo takes reasonable measures to protect your personal information and your content from loss, misuse, and unauthorized access, disclosure, modification, and destruction and to ensure that your content remains protected and available to you. Unfortunately, the transmission of data via the internet is not completely secure and although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted through the Product. All transmissions are at your own risk.

(c) Data Retention: utobo stores the information we collect for as long as necessary for the purpose for which it was originally collected and in compliance with our legal obligations. We may retain certain information for legitimate business purposes or as required by law.

7. Cookies and other tracking technologies

When you visit our websites, sign up for a utobo account, attend a utobo virtual event, or request more information about utobo, we collect information automatically using tracking technologies, like cookies and tracking pixels. You have choices and rights about the collection of data through cookies and tracking technologies.
• You may terminate your use of the Product at any time. However, please note that utobo may still process your personal information as a service provider to our customers if your personal data.
• If you have created an account, you may at any time access, edit, or delete your personal information. Please note that even if you delete information from your account, or deactivate your account, we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of your information for a certain period of time.
• You may opt out of receiving promotional emails, text messages, or mail from utobo by unsubscribing from our email list through email sent to you or simply by mailing us at support@utobo.com.

8.Malware/Spyware/Viruses

We do not knowingly permit the use of malware, spyware, viruses, and/or other similar types of software.

9. Links to external sites

Our website and product may contain links to and from third party websites, such as partners, affiliates, and advertisers. If you follow a link to any external website, it will have its own terms and policies and we are not responsible for the content or practices of such third-party websites or their policies. We are also not responsible for any information that you might share with such linked websites.

10. California privacy rights:

a. Applicability
This section applies only to California consumers. For purposes of this section "Personal Information" has the meaning given in the California Consumer Privacy Act ("CCPA"). It describes how we collect, use, and share California consumers' Personal Information in our role as a business, and the rights applicable to such residents. The California Consumer Privacy Act ("CCPA") requires businesses to disclose whether they sell Personal Information. utobo is a business and does not sell Personal Information. We may share Personal Information with third parties if those third parties are authorized service providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such Personal Information.

b. How We Collect, Use, and Share your Personal Information
We have collected the following statutory categories of Personal Information in the past twelve (12) months:
- Identifiers, such as full name, e-mail address, billing address, and phone number. We collect this information directly from you or from third party sources.
- Commercial information, such as subscription records. We collect this information directly from you.
- Internet or network information, such as browsing and search history. We collect this information directly from your device.
- Geolocation data, such as IP address. We collect this information from your device.
- Financial information, such as Payment Information or financial account numbers in the process of providing you with a subscription. We collect this information from you.
- Inferences.
- Other Personal Information, in instances when you interact with us online, by phone or mail in the context of receiving help through our help desks or other support channels; participation in customer surveys or contests; or in providing the Subscription Service.
The business and commercial purposes for which we collect this information are described in 2,3 and 4 section of this policy.

c. Your California Rights
You have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.
The right of access means that you have the right to request that we disclose what Personal Information we have collected, used and disclosed about you in the past 12 months.
The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions. The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.
utobo does not sell Personal Information to third parties (pursuant to the California Consumer Privacy Act of 2018).

d. How to Exercise your California Rights
You can exercise your rights yourself or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your Personal Information, we will verify your identity by a method appropriate to the type of request you are making. We may also request that your authorized agent have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent's identity to protect your Personal Information.

11. Data protection officer

If you have any questions about this Privacy Policy or our privacy practices, please contact us at support@utobo.com.
You may also contact us by postal mail for all utobo brands at:
Chintan Poriya
Utobo, Inc.
800 W El Camino Real suite 180, Mountain View, CA 94040, United States

12. Children

you must be at least 18 years old to use the Platform, or, if you are between the ages of 13 and 18, you must have your parent or guardian’s permission to use the Platform. utobo does not knowingly collect or store any personal information from or about children under the age of 13, and we will delete such information if we become aware that it has been submitted through our Platform. Parents or guardians who believe that utobo might have any personal information from or about a child under the age of 13 may submit a request to support@utobo.com for us to remove such information.

13. Changes to our privacy policy

We may update this Privacy Policy to reflect changes to our data practices. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of a notice on our website or in the Product prior to becoming effective. We encourage you to periodically review this page for the latest data on our privacy practices.

14. Your acceptance of these terms

By using our website or Product, you accept the policies and restrictions set forth in this Privacy Policy. If you do not agree to this policy, please do not use the website, or the product and services.

Data Protection Addendum (DPA)

Last updated: 07.28.2023

This Data Protection Addendum (DPA) builds upon the Utobo Terms of Service Agreement between the customer and Utobo, Inc (Utobo).

Terms and Definitions:

− "Customer" is the person or entity buying Utobo’s product.

− "Customer Account Data" includes personal data relating to the customer’s relationship with Utobo.

− "Customer Data" includes all information provided by the customer to Utobo.

− "Data Protection Law" refers to all laws concerning the processing of personal data.

− "GDPR" is the General Data Protection Regulation.

− "Industry Standards" are the standards employed by Utobo’s industry peers regarding privacy and security.

− "Information Security Incident" is any breach leading to unauthorized access to Customer Data or Personal Data.

− "Personal Data" is any information related to an identified or identifiable natural person.

− "Product" means the Utobo product as defined in the agreement.

− "Product Generated Data" is data generated by Utobo’s product.

− "Standard Contractual Clauses" are specific contracts approved by the European Commission or the UK depending on the customer’s unique situation.

General Terms:

Relation Between Parties: As to Customer Data, Utobo is a processor while the customer can be a controller or processor. As to Customer Account Data, Utobo is an independent controller. As to Product Generated Data, both Utobo and the customer can be independent controllers.

Permitted Processing: Utobo processes Customer Data as necessary for the provision of the product and as per customer's instructions. Utobo also processes data for its Legitimate Business Operations which include delivering the product, providing customer service, improving the product, account management, internal operations, etc.

Customer Obligations: The customer is responsible for complying with all Data Protection Laws, obtaining consent, providing notices, and deleting data as required by law. The customer ensures that Utobo's processing of data, in accordance with the customer's instructions, will not violate any laws.

Roles and Responsibilities: The customer is responsible for responding to data subject rights requests, and Utobo will assist in fulfilling such requests. The customer also has the ability to access, download, extract, and delete Customer Data. Utobo will delete all Customer Data 90 days after the termination of the customer’s right to use the product, unless required or permitted by law to retain it.

Compliance with Data Protection Law: Both parties will maintain and keep up-to-date all required information under Data Protection Laws, and make such information available to the other party upon request.

Impact Assessments and Consultations: Utobo will provide reasonable cooperation in connection with any data protection impact assessment. However, Utobo may seek additional compensation for cooperation that imposes unreasonable costs or efforts.

Data Usage: Utobo can use and share your Personal Data as needed to provide the agreed-upon product. This will always be in line with Data Protection Laws.

Limits on Data Sharing: Utobo won't share your data unless specified in this agreement, you've given permission, or it's required by law. If legal forces request your data, we'll try to get them to ask you directly and will let you know unless prohibited by law.

Third Party Processing: We work with other companies to help provide our service. We'll ensure they protect your data to an appropriate level given the nature of their work and the data they handle. We remain responsible for their data protection practices.

New Third Parties: We may bring on new third parties over time. We'll let you know 30 days before they access your data. If you don't approve, we'll try to resolve your concerns, stop using them, or cancel the part of the service they were going to help with.

Data Security: We'll use reasonable efforts to protect your data from unauthorized use, accidental loss, and damage. More details can be found in Schedule 2.

Security Review: We'll regularly check our security measures and cooperate with any legally required audits.

Customer's Role: You're responsible for deciding if our security measures meet your needs. We're not responsible for your compliance with Data Protection Laws, and we won't guide you on your data security obligations.

Security Incidents: We'll let you know if there's a security issue affecting your data, investigate, take action, and help with any follow-up steps you request.

Public Communications: Any public statements related to a security incident involving your data will need your approval unless the law says otherwise.

International Provisions: As of the start date, we mostly process data in the U.S. If we process data from certain jurisdictions, additional terms may apply. Details can be found in Schedule 3.

Changes to Agreement: If legal changes make this agreement impossible or unreasonable, we'll renegotiate. If we can't agree on new terms, we can decide together to cancel the agreement.

Updates: We might change this agreement occasionally, but we'll let you know 30 days in advance if changes are due to new laws, corporate transactions, or major changes to our products or services.

Contact Information:
You can reach out to us about privacy and security at support@Utobo.com or mail us at: Utobo, INC
ATTN: Data Protection Officer
800 W El Camino Real Suite 180, Mountain View, CA 94040

Schedule 1: Processing Details

Processing Purpose: Utobo will process Personal Data to provide the Product as per our agreement.

Processing Activities:

Customer Data: Used for business operations including:
Delivering product functionality as used by customers and end-users. Troubleshooting and resolving issues.
Auditing and improving the product and customer services.

Customer Account Data & Product Generated Data:

Used for operations such as:
Account and record services (billing, account management).
Administrative services (customer support, troubleshooting).
Fraud prevention.
Improving product functionality and customer services.
Internal operations (account management, reporting, legal compliance).
Processing Duration: Utobo will process Customer Data as long as the customer uses the Product. Upon termination, data will be returned, deleted, or destroyed as per law.

Categories of Data Subjects: Personal Data processed pertains to:

Customer Data: Customer's end-users.
Customer Account Data: Customer's employees and authorized individuals.
Product Generated Data: Customer and Customer's end-users.
Categories of Personal Data: Utobo processes data including personal contact information, account authentication data, location data, commercial information, education data, financial information, and special categories of data.

Special Data Categories: Special data categories might be processed if shared by customers. Customers are responsible for ensuring proper safeguards before sharing such data.

Schedule 2: Security Measures

Technical and organizational security measures at Utobo include pseudonymization, encryption of personal data, restricted access to data, regular data backup, and regular assessments for security. User identification and authorization are ensured by password protection and role-based access.

Data is encrypted during transmission and storage. Physical security at data processing locations is ensured via stringent access controls and monitoring.

System configuration is maintained by removing unnecessary user accounts and changing default passwords. IT governance is in place with an organization-wide information security policy.

Utobo ensures data minimization, data quality, and limited data retention. Measures are in place for ensuring accountability, including regular review of GDPR compliance and data protection impact assessments.

Data portability and erasure are supported, and additional measures like maintaining information security policies and appointing a Data Protection Officer are taken.

Supplemental safeguards for cross-border data transfers include redirecting requests for personal information disclosure to the customer and publishing a transparency report on binding legal demands.

Schedule 3: Jurisdiction Specific Terms

California:

The term "Data Protection Law" includes the California Consumer Privacy Act (CCPA).
Key terms redefined to include CCPA equivalents: "Personal Data", "controller", "processor", and "data subject".

Utobo will handle personal data according to CCPA requirements and the terms of the Agreement. Utobo ensures CCPA compliance of its sub-processors.
Utobo is committed to implementing adequate security measures.

European Economic Area (EEA):

The term "Applicable Data Protection Law" includes the General Data Protection Regulation (GDPR).

Each party is individually responsible for GDPR-related penalties for non-compliance.

United Kingdom (UK):

References to GDPR are treated as references to UK GDPR and Data Protection Act 2018.
Each party is individually responsible for UK GDPR-related penalties for non-compliance.

Canada:

The term "Applicable Data Protection Law" includes the Personal Data Protection and Electronic Documents Act (PIPEDA).

Australia:

The term "Applicable Data Protection Law" includes the Australian Privacy Principles and the Australian Privacy Act (1988).

"Personal data" and "Sensitive Data" include equivalents as defined under Australian Law.

New Zealand:

The term "Applicable Data Protection Law" includes the New Zealand Privacy Act of 2020.
Utobo and the Customer are defined as “agencies” under this Act.

Sub processors are also defined as “agencies”, with all Personal Information treated as held by the Customer.

This Data Protection Addendum forms a part of the agreement between the Customer and Utobo and governs the processing of personal data in relation to the Product. It ensures compliance with Data Protection Laws and sets forth the responsibilities and obligations of both parties regarding data protection and security.

California Privacy Choices

California Privacy Choices

Last updated: 07.28.2023

Utobo cares about your privacy. We respect the privacy of California residents and protect their personal information according to the California Consumer Privacy Act (CCPA) and other laws. This summary tells you about your privacy rights, how we handle your personal data, and what choices you have.

What We Collect and Why

As per CCPA rules, we inform you about the types of personal data we collect and why. Detailed information can be found in our Privacy Notice for California Residents.

Our Detailed Privacy Policy

To get a thorough understanding of how we gather, use, disclose, and sell your personal data, as well as what rights you have under the CCPA, please refer to our privacy policy.

Exercise Your CCPA Rights

You can ask us about your personal data, correct it, or ask us to delete it by contacting us at support@utobo.com.

Opt-Out of Sale or Sharing of Personal Data

If you don't want us to sell or share your personal data with others, let us know by contacting us at support@utobo.com.

Our Commitment to Californians

We provide extra protections for Californians. This includes our specific ways of handling personal data and your rights under CCPA and other California laws.

What We Collect and Why

We explain our practices around collecting and using your personal data in our Privacy Policy. This includes what data we collect, where it comes from, who we share it with, and why we collect and use it.

We use your personal data to:

- Provide our products and services

- Enforce our policies

- Send you marketing materials

- Customize your ads

- Count ad views and website interactions

- Provide customer service

- Prevent fraud

- Process your transactions

- Defend against legal claims

- Assess your employment eligibility

- Manage claims and benefits

- Communicate with our employees, partners, investors, and advisors

Data Retention

We only keep your personal data for as long as we need to. This is based on why we collected it, potential risks, and legal requirements. You can ask us to delete your data, and we may make your data anonymous for research or stats.

Your Rights in California

As a Californian, CCPA gives you certain rights, such as the right to know, delete, correct, opt-out of sale/sharing, limit use of sensitive personal data, and not be discriminated against for exercising these rights.

How to Use Your CCPA Rights

You or your authorized agent can exercise your CCPA rights. We may ask for information to confirm your identity or that your agent has your permission. Contact us to exercise these rights.

Do-Not-Track and Global Privacy Controls

We respect your online tracking choices and support Global Privacy Control (GPC) to honor these choices. You can use GPC through certain browsers or extensions.

California's Shine the Light Law

California law lets you ask about our disclosure of personal data to others for direct marketing. To ask about this, email support@utobo.com with "Shine the Light Request" in the subject line.

Questions?

If you have any questions or comments about this privacy policy or how we handle data, email us at support@utobo.com.

Policy Updates

We may change this policy from time to time. We'll update the date at the top of the page and let you know when needed.

Compliance with Laws

This policy meets the requirements of the California Government Privacy Act. It gives Californians relevant information about their privacy rights and our practices.

California Supplemental Privacy Notice

California Supplemental Privacy Notice

Last updated: 07.28.2023

THIS SUPPLEMENT IS FOR CALIFORNIA RESIDENTS ONLY

Utobo values simplicity in providing information to our users and has diligently worked on our Privacy Policy. This California Supplemental Privacy Notice (“California Privacy Notice”) complements the information presented in the Privacy Policy and applies exclusively to California residents. This notice outlines your rights under the California Consumer Privacy Act of 2018 (“CCPA”) and other applicable California laws. Terms defined in the CCPA retain their meaning in this document.

While we fulfill the CCPA's requirement to present the following categories, please consult our Privacy Policy for illustrative examples and additional details about our data collection and usage, which remain unaffected by this notice.

Understanding the CCPA

The CCPA is a California law that grants specific rights to California residents regarding their personal information.

According to the CCPA, California residents (referred to as "consumers") possess the following rights:

• The right to request information about the collection and use of personal information over the past 12 months.

• The right to request the deletion of personal information collected and retained by us, subject to exceptions.

• The right to opt out of the sale of personal information.

• The right not to be discriminated against for exercising privacy rights under the CCPA.

Further instructions on how to exercise these rights are provided below.
As per the CCPA, "personal information" refers to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked to, directly or indirectly, a particular consumer or household. Personal information excludes publicly available information or deidentified and aggregated consumer information. The CCPA does not apply to personal information covered by specific sector-specific privacy laws, such as the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), the Driver's Privacy Protection Act of 1994, or health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), including clinical trial data.

Scope of the California Privacy Notice

Utobo's services are intended for use by our customers, and the majority of personal information processing occurs at their direction. This California Privacy Notice solely pertains to our processing activities for the data we own and control. If you are a California resident interacting with our site as a subscriber to one of our customers' businesses, please contact them directly to understand their practices under the CCPA.

This California Privacy Notice does not cover personal information collected from employees or job applicants in their capacity as employees or job applicants. It also does not apply to personal information collected from employees, owners, directors, officers, or contractors of businesses during the provision or receipt of business-related services. Consequently, any CCPA-related responses may exclude these categories of personal information.

Information Collected About Consumers in the Last 12 Months

The categories of personal information we collect about you (as described below) originate from the following sources:

• Information provided by you, including through the use of our services and products.

• Automatically collected information.

• Information obtained from third parties, such as when you authorize social networks to share your information with us or when you publicly make your personal information available online.

The chart below details the CCPA categories of personal information we have collected from consumers within the preceding twelve (12) months.

Purposes for Collecting Personal Information

We collect personal information for one or more of the following business purposes:

• Providing our services (e.g., account servicing, customer service, advertising and marketing, analytics, and communication about our services).

• Fulfilling operational purposes for us, our service providers, and integration partners.

• Improving our existing products and services and developing new ones (e.g., conducting research to create new features or products).

• Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activities.

• Bug detection, error reporting, and maintaining service quality or safety.

• Auditing consumer interactions on our site (e.g., measuring ad impressions).

• Short-term, transient use, such as customizing displayed content by us or our service providers.

• Other uses that advance our commercial or economic interests, including third-party advertising and relevant offers communication.

• Responding to law enforcement requests, complying with applicable laws, court orders, or governmental regulations.

• Evaluating or conducting mergers, divestitures, restructurings, reorganizations, dissolutions, sales, or transfers of some or all of Utobo's business or assets.

• As disclosed during the collection of personal information or as set forth in the CCPA.

Sale of Personal Information

The CCPA defines a "sale" of personal information as the disclosure, sharing, or provision of a consumer's personal information by a business to another business or third party in exchange for monetary or other valuable consideration. However, Utobo does not monetize your personal information. Although we share certain device and interaction information to enhance your experience and engage in legitimate advertising and marketing activities, we do not "sell" your personal information as defined by the CCPA and its regulations. If you consider a website's use of third-party cookies or similar technologies for advertising or analytics purposes a "sale" under the CCPA, please consider that Utobo may be considered to have "sold" what the CCPA refers to as "identifiers" (e.g., IP addresses), "internet or other electronic network activity information" (e.g., information about browsing activity on Utobo websites), and "commercial information" (e.g., indication of a browser visiting Utobo-related webpages). For more information, including how to exercise your right to opt out or manage your cookie preferences, please consult our Privacy Policy.

Exercising Your California Privacy Rights

Only you or someone legally authorized to act on your behalf can make a verifiable consumer request regarding your personal information. Agents must provide proof of authorization from the consumer to act on their behalf. Making a verifiable consumer request does not require creating an account with us. Any personal information provided in a verifiable consumer request will only be used to verify the requestor's identity or authority.

We verify requests by sending a confirmation email to the requestor and comparing the identifying information provided with the personal information we possess. If we cannot: (i) verify your identity or authority, and (ii) confirm that the personal information pertains to you, we cannot fulfill your request or provide personal information. If we are unable to verify a consumer's identity with sufficient certainty, we will explain the reasons for denying the request.

For further information on your legal rights under applicable law or to exercise any of those rights, please contact us at support@utobo.com.

You may make a verifiable request for access or data portability twice within a 12-month period.

California residents can exercise their California privacy rights by submitting their request to support@utobo.com.

Privacy Notice for Utobo Users in California

Last updated: 07.28.2023

Notification Regarding Your Right to Opt-Out of Personal Information Sale

As a Utobo user in California, you possess the right to instruct us not to sell or share your personal information with third parties. This right is commonly referred to as the "opt-out" right concerning the sale or sharing of personal information.

Definition of the "Sale" of Personal Information

In accordance with the California Consumer Privacy Act, the term "sale" encompasses activities such as selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a user's personal information to a third party in exchange for monetary or other valuable consideration.

Please note that many instances of personal information disclosure do not fall under the category of sales.

For instance, if we disclose or make available personal information to service providers or other contractors who provide business services on our behalf, it does not constitute a sale. Similarly, if you direct us to intentionally disclose personal information to or intentionally interact with one or more third parties, it does not count as a sale. Additionally, the transfer of personal information as an asset during a merger, acquisition, bankruptcy, or other transfer of business control is not considered a sale.

Understanding the "Sharing" of Personal Information

"Sharing" refers to the act of sharing, disclosing, making available, or otherwise communicating orally or in writing a user's personal information for the purpose of cross-context behavioral advertising, commonly known as targeted advertising.

Consequences of Opting Out of Personal Information Sale/Sharing

Should you choose to exercise your right to opt-out of the sale/sharing of personal information, we will promptly cease selling and/or sharing your personal information with third parties, ensuring compliance within a reasonable timeframe, not exceeding 15 days from the receipt of your request. Furthermore, we will notify all third parties to whom we have previously sold or shared your personal information about your opt-out request and instruct them to comply with the requirements set forth by our privacy policy.

For additional details regarding our privacy practices, please refer to our Privacy Policy https://utobo.com/privacy-policy.

Procedure for Submitting an Opt-Out Request for Personal Information Sale/Sharing

To initiate an opt-out request for the sale/sharing of your personal information, kindly email us at support@utobo.com. The information you provide will facilitate the processing of your request. Please note that failure to provide the requested information may hinder our ability to identify you and fulfill your opt-out request. Rest assured that any information you provide will be used solely for processing your opt-out request and will not be utilized, disclosed, or retained for any other purpose.

[If you do not have an Utobo account or are not currently logged in, your opt-out request for the sale/sharing of personal information will be linked solely to your browser identifier, as we do not possess information regarding the connection between your browser and your account.]