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LEGAL

Privacy Policy

We value our users’ privacy and protection of their data. 

This Privacy Policy describes how UC Initiatives LLC (trading as NRM Communications) (“NRM Communications”, “we”, “our” or “us”) collects, stores, uses and discloses data. It also describes your rights with respect to your personal data.

Please read this Privacy Policy carefully and make sure that you fully understand it. You are not legally required to provide us with any of your personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of the third parties providing services through us (‘Third Party Services’), please simply do not visit or interact with our Website or Application (‘Site/ Application’), nor use our Services. By using our Services, you are expressly consenting to our collection, processing, storing, disclosing, using and handling of your data as set forth in this Policy now, and as amended by us from time to time, in terms hereof.

 

Data Collection

Information you voluntarily provide

To register and interact with our Site/ Application, you will be prompted to share information with us.  Some of the information you may share with us includes: Full Name, Phone Number, Email ID, Address, Business Name, Business Address, Designation, Company Name, Payment Information such as Bank Accounts/ Credit or Debit Card (secured).

Information We Collect About You And Your Device

When you use our Site/ Application and interact with our services, we may use technology to collect information about your activity. Some of the data that is collected while using the Site/ Application and mobile/desktop clients may include: IP address, Type of browser you use, Number of sessions per browser/client on each device, Type of device and operating system, Local language, Actions taken while on the Site/ Application, Device identifiers, web browser, mobile device, your mobile devices unique device ID, time zone.

We collect and generate this information automatically, including through the use of analytics tools, including cookies and pixels. We use this information to help tailor your experience for your device/language.  We also use this information to help prevent fraud as well as identify service issues.  

 

Cookies and other technologies

Our Site/ Application and Services (including some of our Services Providers) utilize “cookies”, anonymous identifiers, pixels, container tags analytics signals, web beacons, log files, and other technologies in order for us to provide and monitor our Services, to ensure that they perform properly, to analyze our performance and marketing activities, and to personalize your experience. Such cookies and similar files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall personal data, such as an IP address or User. You may also use the “Cookie settings” feature available in our Services depending on your location and activity on our Services, as applicable. We may also use Google Analytics to help us understand how you use the Site/ Application. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Cookies are small pieces of data that are stored on your computer, mobile phone or other device.  Pixels are small blocks of code on web pages that do things like allow another server to measure viewing of a web page and are often used in connection with cookies. HTML5 Local Storage is a small database located inside your browser which web pages can use to store data to speed up their processing. Cookies do lots of different jobs, like letting you navigate between pages efficiently, storing your preferences, and generally improving your experience on our Site/ Application. Cookies make the interaction between you and our Site/ Application faster and easier. Cookies and other things like local storage also help us authenticate you to deliver personalized content to you.

Please refer to your device’s help material to learn what controls you can use to remove or block cookies. Please remember that if you do this, it may affect your ability to use our Site/ Application.  As you use your device, you will encounter third parties that make use of cookies and similar technologies.  We are not responsible for those third parties or what they may place on your device or in your browser.

Data Use and Legal Basis

We use personal data for the following purposes (and in accordance with the legal bases as provided):

  • Enable us to provide the Services
  • Ensure that our Site/ Application are presented in an effective manner for you and for your device
  • Provide you with marketing information about us and our services, including personalised marketing 
  • Notify you about changes to our Service
  • Carry out our obligations arising out of the Terms
  • Keep the platform secure
  • Improve user experience and our Services
  • Enable us to be legally compliant
  • Defend our servers against malicious attacks
  • Communicate with you

We process your personal data for these purposes based on our legitimate interests or a third party’s legitimate interest, as the case may be, to ensure we provide our Services in an effective, safe and efficient manner. Where we process your personal data for administering your account, or to the extent necessary to allow you to access our Services, we do so for the purposes of our contract with you. We will not process any special (or sensitive) categories of Personal Data or Personal Data, except where we are able to do so under applicable legislation or with your explicit consent. When we use the term “personal data” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual. 

Our Use Of Aggregated And Anonymized Information

We may share anonymized usage data which does not identify you specifically with third parties.  We may combine your data with those of other users of NRM Communications and share this information in aggregated and anonymized form with third parties to help us improve the design and delivery of our Services, increasing the effectiveness for all users.

 

Communications

We engage promotional communications, through email, phone, SMS and notifications.

Services Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, log-in attempts or password reset notices, etc. You can control your communications and notifications settings from your User Profile settings, or otherwise in accordance with the instructions that may be included in the communications sent to you. However, please note that you will not be able to opt-out of receiving certain Services communications which are integral to your use (like password resets or billing notices).

Promotional Communications: We may also notify you about new features, additional offerings, events and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or email), through the Services, or through our marketing campaigns on any other sites or platforms. If you do not wish to receive such promotional communications, you may notify us at any time by sending an email to us, changing your communications preferences in your User Profile settings, or by following the “unsubscribe”, “stop”, “opt-out” or “change email preferences” instructions contained in the promotional communications you receive.

 

Data Sharing

When processing your Personal Data, we may need to share it with other users of the Site/ Application, and third parties (including other entities within our Group of Companies). Data with users of the Site/ Application will be shared in order to facilitate provision of our Services.

Data with third parties is shared only as reasonably necessary to provide the Service(s) and subject to confidentiality obligations. This list is non-exhaustive and there may be circumstances where we need to share Personal Data with other third parties:

  • With Third Party Service providers.
  • With third party service providers providing us with services, such as research and analytics, anti-spamming and anti-phishing services.
  • With third parties assisting us in providing the Services, and assisting us with marketing, advertising our product/service offerings, or providing, maintaining and improving the features and functionality of the Services.
  • With payment processors who process your credit card and other payment information. In addition, we may disclose information to third parties to verify the authenticity of any financial transaction involving our company or to update your billing information.
  • If you submit a public review or feedback, note that we may (at our discretion) store and present your review publicly, on our Site/ Application and Services.
  • In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations.
  • We may share your personal data with others if we believe in good faith that this will help protect the rights, property or safety of NRM Communications, any of our users, or any members of the general public.
  • With our affiliates and companies that we will acquire in the future when they are made part of our group – this may be for customer support, marketing, technical operations, account management or organizational purposes and to provide, enhance and improve the Services. In addition, should we undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your personal data may be shared with the parties involved in such an event.
  • With auditors, lawyers, accountants and other professional advisers who advise and assist us in relation to the lawful and effective management of our organization and in relation to any disputes we may become involved in

Some of our advertising partners may deploy their own tracking or cookies not administered by Us. These technologies are subject to our advertisers’ Privacy Policies.

 

Data Storage

Data Storage: We and our authorized service providers maintain, store and process personal data in your local jurisdiction or such other locations as reasonably necessary for the proper performance and delivery of our Services, or as may be required by applicable law.

Our headquarters are in Arizona, USA. While privacy laws vary between jurisdictions, NRM Communications, and its affiliates are each committed to protect personal data in accordance with this Privacy Policy, customary and reasonable industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. These steps may include implementing standard contractual clauses where recognized by law, obtaining your consent, or other lawful means of transferring personal information.

Data Retention: We may retain your personal data for as long as it is reasonably needed in order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy and at our reasonable discretion. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of such data, the potential risk of harm from unauthorized use or disclosure of such data, the purposes for which we process it, and the applicable legal requirements. If you have any questions about our data retention policy, or wish to inquire about your personal data in our possession or request the deletion of any personal data that you have submitted to us, please contact us at support@nrmcommunications.com, or by calling +1 602 845 8600.

 

Data Security

We take all appropriate technical and administrative security measures to protect your personal data from loss and misuse. The information you provide to us is stored on our platform, Third Party Service providers (in case where their services are availed by you) and servers owned and operated by Amazon Web Services Inc. and Microsoft Azure Cloud (‘Authorised Service Providers’) More information on this provider is available at https://aws.amazon.com and https://azure.microsoft.com/en-u.

 

We use industry standard security measures to keep your data safe including private networking, firewalling, role-based access controls, authentication, backups, and monitoring. Your data is stored in a secure operating environment, which is not publicly accessible. Your personal data is encrypted when transferred using Secure Socket Layer (SSL) technology. This means that communication between your computer and our servers uses a recognized encryption method, provided your browser supports SSL. We regularly review our security procedures to consider appropriate new technology and methods. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable.

We have appropriate internal policies regarding standard operating procedures in handling your personal information and/or data. Only employees who need access to such information to perform a specific job, as provided in this Policy, are granted access to personal data. In addition, we are committed to taking strict action to enforce the privacy responsibilities of our employees.

In the event that the security of information and/or personal data is breached as a result of a security failure, We will immediately, and not later than any period specified under any applicable law, notify the person/s/ user whose personal information security is breached.

Where we have given you a username, password and/or security information which enables you to access particular features of the Service, you are responsible for keeping these access credentials confidential. You must not share these details with anyone, or store them in a way that may allow a third party to access them.

 

Your Rights

As an individual protected under GDPR, CCPA, or any other data protection law providing same or similar protection, you will have the ability to exercise certain controls and choices regarding our collection, use and sharing of your personal information, as provided under such laws. Your controls and choices may include:

  • Right to obtain information about the clarity of identity, the basis of legal interests, the purpose of the request and use of personal data, and about our accountability;
  • Correcting, updating, and deleting your account with us; 
  • Choosing or changing your choices for subscriptions, newsletters, and alerts;
  • Right to withdraw consent granted for personal data;
  • Right to data portability;
  • Choosing whether to receive from us offers and promotions for our products and services, or products and services that we think may be of interest to you;
  • Controlling targeted advertising from many ad networks and partners; data exchanges; and marketing analytics and digital advertising and marketing service providers;
  • Choosing whether we share your personal information with other companies so they can send you offers and promotions about their products and services;
  • Requesting removal of your personal information from our Site/ Application or Services;
  • Requesting access to the personal information we hold about you and that we amend or delete it.

If you wish to exercise your privacy rights under applicable law (including the EU or UK GDPR or the California Consumer Privacy Act (CCPA), or any other similar Data Protection Law), such as (each to the extent applicable to you under the laws which apply to you) the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request rectification or erasure of your personal data held with NRM Communications, or to restrict or object to such personal data’s processing (including the right to direct us not to sell your personal data to third parties now or in the future), or to obtain a copy or port such personal data - you may email us at support@nrmcommunications.com, or We will comply with your requests in accordance with the applicable law.

If you are a GDPR protected individual, and wish to complain about the processing of your personal information then please contact us first, and if we do not satisfactorily deal with your complaint, then you may proceed in accordance with the GDPR.

California Requirements: This Privacy Policy describes the categories of personal information we may collect and the sources of such information, and our retention and deletion practices. We also included information about how we may process your information, which includes “business purposes” under the California Consumer Privacy Act (CCPA). We do not sell your personal information for the intentions and purposes of CCPA. We may disclose personal data to third parties or allow them to collect personal data from our Services as described hereinabove, if those third parties are authorized services providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal data, or if you integrate Third Party Services with our Services, or direct us to disclose your personal data to third parties, or as otherwise described hereinabove.

If you have any questions or would like to exercise your rights under the CCPA, you can contact us by email.

Please note that when you ask us to exercise any of your rights under this Privacy Policy or applicable law, we may instruct you on how to fulfil your request independently through our Application; and/ or require additional information and documents, including certain personal data and credentials in order to process your request in a proper manner (e.g. in order to authenticate and validate your identity so that we know which data in our systems relates to you, and where necessary, to better understand the nature and scope of your request). Such additional information will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request, and of how each request was handled), in accordance with this Privacy Policy.

We may redact from the data which we make available to you, any personal or confidential data related to others.

NRM Communications is the “data controller” of the personal data collected through its Site/ Application. Accordingly, we assume the responsibilities of a data controller (solely to the extent applicable under law), as set forth in this Privacy Policy. 

 

Third Party Websites, Applications and Services

Our Services may include links to third party websites, applications and services, and integrations with third party services. Such websites, application, services and Third Party Services, and any information you process, submit, transmit or otherwise use with or to such websites, applications, services and Third Party Services, are governed by such third party’s terms and privacy practices and policies, and not by this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such websites, applications, services and Third-Party Services. We have no liability or responsibility for the content, activities of such Third Party websites, applications, or services.

 

Age Limitations

To the extent prohibited by applicable law, We do not allow use of our Service and Application by anyone younger than 13 years old, or such other age prescribed by applicable law. We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 13, or such other age prescribed by applicable law, is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by email.

 

Change Of Control

If the ownership of our business changes, we may transfer your information to the new owner so they can continue to operate NRM Communications and provide services. The new owner will be obliged to comply with this Policy, as amended from time to time. 

 

Amendments to this Policy

We may update and amend this Privacy Policy from time to time by posting an amended version on our Site/ Application. The amended version will be effective as of the date it is published. When we make material changes to this Privacy Policy, we will give notice as appropriate under the circumstances, e.g., by displaying a prominent notice on the Site/ Application or by sending an email. Your continued use of the Site/ Application after the changes have been implemented will constitute your acceptance of the changes.

 

Contact Us

You can contact us by email at support@nrmcommunications.com, call +1 602 845 8600, or write to us at 7135 E Camelback Rd Ste 230, Scottsdale, AZ 85251.