Effective Date: 03/23/2025
UP, Inc. – California Consumer Privacy Act Policy
This notice describes the rights of Californians under the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA requires businesses like UP, Inc. (“COMPANY”), that receive information from more than fifty thousand California consumers, to provide certain information to them. COMPANY fully describes its practices to all its members and visitors in its Privacy Policy, but uses this separate notice to ensure that COMPANY meets the CCPA’s requirements. This notice contains the following four parts:
1. COMPANY DOES NOT SELL YOUR PERSONAL INFORMATION
The CCPA requires COMPANY to disclose whether COMPANY sells your personal information. COMPANY does not sell your personal information.
2. YOUR RIGHTS UNDER THE CCPA
The CCPA provides Californians with the following rights:
2.1 Requests for Information
Like all of our members, you (or your authorized agent) can request a copy of your personal information. Authorized agents will be required to verify their identity. COMPANY also will require members to confirm, by email from their primary account email address, that they granted the agent permission to submit the request. Under the CCPA, you can also request that COMPANY disclose how it has collected, used, and shared your personal information over the past 12 months, including the categories of personal information COMPANY collected and its purposes for doing so; the categories of sources for that information; the categories of third parties with whom COMPANY shared it for a business purpose and its purposes for doing so. Companies that sell personal information (COMPANY does not) must make additional disclosures.
If you are not a COMPANY member, you can submit your request via an authorized agent. The authorized agent will be required to verify their identity, and you will be asked to confirm by email that you granted the agent permission to submit the request.
2.2 Your Right to Opt Out of Sales
COMPANY does not sell personal information, so COMPANY does not have an opt out.
2.3 Your Right to Notification
Under the CCPA, a company like COMPANY cannot collect new categories of personal information or use them for materially different purposes without first notifying you.
2.4 Nondiscrimination for exercising your CCPA Rights
The CCPA prohibits businesses from discriminating against you for exercising your rights under the law. Such discrimination may include denying services, charging different prices or rates for services, providing a different level or quality of services, or suggesting that you will receive a different level or quality of goods or services as a result of exercising your rights.
2.5 Your Right to Delete Personal Information
Like all COMPANY members, you can request that COMPANY delete your personal information by closing your COMPANY account. You also can request that COMPANY delete specific information. COMPANY honor such requests, unless an exception applies, such as when the information is necessary to complete the transaction or contract for which it was collected or when it is being used to detect, prevent, or investigate security incidents, comply with laws, identify and repair bugs or ensure another consumer’s ability to exercise their free speech rights or other rights provided by law.
3. THE CCPA CATEGORIES OF PERSONAL INFORMATION COMPANY COLLECT AND THE SOURCES
Our Privacy Policy describes the information COMPANY collects and its sources. This notice organizes that information around the personal information categories set forth in the CCPA.
CCPA Personal Information Category
Sources of this Information
Identifiers (e.g., real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers)
Information you provide directly or through your interactions with our Services (as defined in our Privacy Policy) or partners
Vendors that provide information to help COMPANY serve members relevant ads and understand the ads’ effectiveness
Information from other COMPANY members or customers
Characteristics of protected classifications under California or Federal law (e.g., your gender or age) (“Characteristics of Protected Classifications”)
Information you provide to COMPANY directly and inferences COMPANY makes based on that information
Information from COMPANY customers
Commercial information (e.g., information regarding products or services purchased, obtained, or considered)
Information you provide to COMPANY directly, such as to buy a Premium service
Your interactions with COMPANY Services
Information from COMPANY partners and customers
Internet or Other Electronic Network Activity Information (e.g., browsing history, search history, and information regarding your interactions with our Services)
Your interactions with COMPANY Services
Your visits to third party sites that offer COMPANY autofill, follow or “Apply with COMPANY” functionality, as needed for fraud prevention and security purposes.
Geolocation Data
Information you provide to COMPANY directly or through your interactions with our Services, as explained in the Privacy Policy
Professional or Employment-Related Information
Information you provide to COMPANY directly
Information from COMPANY customers, partners, or from other members
Inferences
Information you provide to COMPANY directly or through your interactions with COMPANY Services
Information from COMPANY customers and partners
Personal information described in Cal. Civ. Code §1798.80(e)(such as name, address, telephone number, education, employment history, credit card or debit card number)
Information you provide directly or through your interactions with COMPANY Services
Information from COMPANY customers or partners
Audio, electronic, visual or similar information
Information you provide directly or through your interactions with COMPANY Services, customers or partners
COMPANY uses this personal information for the purposes outlined in our Privacy Policy.
4. THE CCPA CATEGORIES OF PERSONAL INFORMATION COMPANY SHARE FOR A “BUSINESS PURPOSE”
While COMPANY does not sell your personal information, COMPANY may share it to support its operational purposes in providing Services to you, as described in our Privacy Policy. These operational purposes, known as “business purposes” under the CCPA, are described below. In addition, COMPANY may share personal information at your direction, such as when you choose to communicate with other members through our Services.
4.1 Auditing Interactions
COMPANY may share the types of personal information listed in Section 3 with partners, service providers and related companies, in order to audit interactions and transactions, such as to count or verify the positioning and quality of ad impressions.
4.2 Security Purposes
In order to secure COMPANY Services, including to detect, prevent and investigate security incidents or violations of COMPANY Professional Community Policies or applicable laws, COMPANY may share the types of personal information listed in Section 3 with its partners, service providers, law enforcement and related companies.
4.3 Service Improvements
In order to improve COMPANY Services (such as to identify bugs, repair errors or ensure that services function as intended) or conduct internal research and analysis to improve COMPANY technology, COMPANY may share the types of personal information listed in Section 3 with its partners, service providers and related companies.
4.4 Service Providers and Other Notified Purposes
COMPANY may share the types of personal information listed in Section 3 with Service Providers, as defined by the CCPA, in order to have them perform services specified by a written contract or with others for a notified purpose permitted by the CCPA (e.g., to respond to law enforcement requests).
