Legal and Security

Privacy Policy

Last updated: August, 2019

Introduction

The purpose of this Privacy Policy is to inform you how we collect, use and share your Personal Data in connection with your use of our Website, Services and Content (collectively, the “Services”) and the choices available to you regarding our use of your Personal Data. This Privacy Policy governs the privacy terms of the Services that offered, launched, administered or owned by UCX LLC. For more information about us, please refer to the Terms of Service. If you have concluded a separate agreement with UCX LLC the data protection provisions of which conflict with the terms of this notice in any way, the terms of the separate agreement shall prevail. Some terms used through the Privacy Policy are defined. Please find the meaning of capitalized term under the Definitions section below. We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us.

Definitions of terms

UCX (“us”, “we”, or “our”) means UCX LLC, its subsidiaries and affiliates. For the purposes of this Privacy Policy, we are also a data controller of your Personal Data.

User (“you”) means any individual visiting and/or using our Websites and/or Services, including registered buyers and sellers. Buyers are registered Users of the UCXmarket Platform that represent organizations interested in buying cloud storage, whereas sellers are registered Users of the UCXmarket Platform that represent organizations that are interested in providing their excess cloud storage capacity to potential buyers.

Content means, without limitation, any information, statement, data, material, article, research, text, written posts, reviews, and comments, software, scripts, graphics, and interactive features generated, provided, or otherwise made accessible on the Website or through the Services. Account means to sign up / register to have access to Services from the Platform

Personal Data means any information relating to an identified or identifiable natural person.

Platform means the UCX market platform launched, administered and owned by UCX. UCXmarket website is https://ucxmarket.com/ucx

Cookies means small pieces of data stored on a User’s device.

Services means the Website, Platform and services, features, content or application offered and operated by UCX

Websites means all the websites launched, administered or owned by UCX, including but not limited to https://ucxmarket.com/ucx, https://ucxtech.com/, or affiliate portals.

Personal Data we collect from you

We may collect information about Users when you provide that information upon registration in our Website and when you use our Services. In addition, and whenever lawful, we might collect information about you from other sources, including service providers, partners, and publicly available sources, and when you contact and interact with us through emails or other means. Types of data we collect include the following:

  • Personal Data – When you register to our Websites by opening an account, we will collect the necessary Personal Data to enable you access to our Services. We may require you to provide us with your name, surname, email, password, organization’s name, phone number, email and address. As you use our Services, we may also require from you to provide us with additional Personal Data.
  • Payment Information – The information you add with regard to your financial account to the Account is directed to UCX’s third-party processor.
  • Cookies and Other Tracking Technologies – We use Cookies as small text files with small amount of data to track the activity of our Users in our Websites and hold certain information. This enables our systems to recognize you and to gather non-personal information regarding your use of the Websites. We use persistent Cookies for authentication purposes and Local Storage for storing user preferences. You can set your browser to refuse all Cookies, or refuse them yourself. If you do not accept Cookies, you may not be able to use part or all of our Websites and Services. You may erase persistent Cookies and Local Storage deleting your browser’s history.
  • Usage Data – We may collect information from devices that you use to access the Websites or use our Services. This is also known as log data, which is collected automatically and may include information such as the IP address, duration of the page visit, statistics how pages are viewed, browser type, etc. In addition, we use third party services such as Google Analytics that collect, monitor and analyze the Usage Data.

Legal Basis

We your Personal Data (a) to perform a contract with you (b) because we have a legitimate interest and not overridden by your rights (c) because we have your consent to do so. Our legal basis for collecting and using your Personal data will depend on context in which we collect your Personal data and on the Personal Data concerned. Sometimes we may also have a legal obligations to collect personal information from you.

Use of Personal Data

We may use/process your Personal Data for the following reasons:

  • To operate our Websites and to provide the Services, including: registration and access to your Account. Your data may be used also for processing transactions, subscriptions, purchases, and payments, once these options are available in our Websites.
  • Measure, Support, and Improve our Websites and Services: We use your Personal Data to measure use of, analyze performance of, fix errors in, provide support for, improve, and develop our Websites and Services.
  • Recommendations, Personalization and Authentication: We use your Personal Data to recommend services that might be of interest to you, identify your preferences, and personalize your experience with our Websites and Services. We also use your Personal Data for authentication and user customization purposes for which we can identify the user who has logged in and what level of access the user has.
  • Comply with Legal Obligations: In certain cases, we have a legal obligation to collect, use, or retain your personal information and to enforce our Terms of Service.
  • Communicate with You: We use your personal information to communicate with you in relation to our Services via different channels (e.g., by phone, email, chat) and to respond to your requests.
  • Marketing: We use your Personal Data to market and promote our Services to you. We might display ads/promotions from suppliers and partners of UCXmarket in our Websites.
  • Fraud and Abuse Prevention and Credit Risks: We use your personal information to prevent and detect fraud and abuse in order to protect the security of our customers, UCXmarket, and others. We may also use scoring methods to assess and manage credit risks. We may also ask for your consent to use your personal information for a specific purpose that we communicate to you.

Do we disclose your Personal Data with anyone else?

We may disclose your Personal Data:

a) if we sell or transfer all or a portion of our company’s business interests, assets, or both, or in connection with a corporate merger, restructuring consolidation, or other company change;

b) as required by law or if we believe that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by law enforcement officials, or private parties, including but not limited to in response to search warrants, subpoenas, or court orders; or

c) to our vendors if necessary in order to provide you with the Services;

d) if legally permissible, we may use and share information about Users with our partners in aggregated or de-identified form that can’t reasonably be used to identify you.

We may use third party vendors to perform certain hardware, software, networking, storage and related technology services on our behalf, for example:

  • hosting our website and our company email server;
  • processing and fulfilling your payments;
  • maintaining, enhancing, operating website’s features or adding to the functionality of our website;
  • assisting with promotions and advertising;
  • collecting web analytics data; and
  • enabling us to send you emails, or performing other administrative services.

We may share your Personal Data with these third party vendors solely to enable them to perform the services for us and we require that those third party vendors maintain at least the same level of data protection that we maintain for such data. However, some of our vendors may process your data outside of the United States.

Our website may contain links to third party content and websites that we do not control. This includes links to clients and partners. If you click on these links and enter third party websites those third parties may use their own cookies to collect your data. You should read the third parties’ privacy notices to learn how they will collect and use your data as their policies may differ from ours and will apply to your use of their websites.

How long do we retain your Personal Data?

We retain your Personal Data for the purposes as underlined in this Privacy Policy and in order to enable your continued use of our Services. How long we retain specific personal information varies depending on the purpose for its use. As long as we have an ongoing legitimate business need to retain you data, we will do so. When we have no ongoing legitimate business need to process your Personal Data we will either delete or anonymize it. If this is not possible we will securely store your personal information and isolate it from any further processing until deletion is possible. We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Website and Services, or we are legally obliged to retain this data for longer periods of time.

Security of your Personal Data

When you provide us with your Personal Data, we take steps to ensure that it is treated securely. We will take steps to make sure the right security measures are taken, in order for your privacy rights to be protected as specified under this Privacy Policy. Note UCX participates in the EU-US and Swiss-US Privacy Shield frameworks as set forth by the U.S. Department of Commerce regarding the processing of the Personal Data. While we are committed to protect your Personal Data, unfortunately we cannot guarantee the security of any data you transmit to us or from our website since data transmission over the internet is never 100% secure, therefore you use our Website and Services and you communicate with us at your own risk. If you were provided the opportunity to have a password in order to access certain part of our Services, you are responsible for keeping the password confidential.

Do we collect Personal Data from children?

The Websites and Services are not intended for use by children under the age of 18, and we do not knowingly collect and process Personal Data from children. If we become aware that we have unknowingly collected Personal Data from a child under the age of 18, we will make all reasonable efforts to delete such information from our database. If you become aware that we have unknowingly collected Personal Data from a child under the age of 18, please contact us immediately at support@ucxchange.com and we will delete and/or stop processing your child’s Personal Data within a reasonable time.

Your rights regarding your Personal Data

As a registered User you an access certain information with regard to your Account by either logging into our Services or sending an email at support@ucxmarket.com. Accessing your information may be temporarily limited where access and correction could hinder UCX’s ability to investigate, make or defend legal claims; result in disclosure of personal information of a third party; hinder UCX’s ability to comply with a legal obligations or result in breach of a contract or disclosure of trade secretes or other proprietary business information belonging to UCX or a third party.

Your Data Protection Rights Under GDPR (General Data Protection Regulation)

If you are a resident of the EEA you can access, correct, update or request deletion of your Personal Data. To do so you have to email support@ucxmarket.com. In addition you can:

  • Object the processing of your Personal Data, ask us to restrict the processing of your Personal Data or Request Portability of your Personal Data.
  • Opt out of marketing communications we send you at any time
  • Withdraw your consent for collecting and processing your personal data
  • Complain to a data protection authority about our collection and use of your Personal Data.

To exercise any of the aforementioned rights, please send an email to support@ucxmarket.com specifying your name, surname and email.

How can you make a complaint?

In the event that you wish to make a complaint about how we process your Personal Data, please contact us in the first instance at support@ucxchange.com and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.

International Transfer of Your Personal Data

We may transfer your Personal Data to countries other than the country in which the data was collected originally. It is possible that these countries do not have the same data protection laws as the country in which you provided your information initially. We will protect your Personal Data when we transfer your Personal Data as described in this Privacy Policy.

Changes to this Privacy Policy

We will revise this Privacy Policy from time to time. If we do so, we will post the new policy on our website and change the effective date, so we encourage you to review it frequently. Your continued use of the Websites and Services after changes in this Privacy Policy will mean that you accept such changes except as otherwise required by local law.

Contact us

Thank you for reading our Privacy Policy. If you have any questions about this Privacy Policy, please contact us at support@ucxmarket.com.