Who We Are
Udumbara (“Udumbara,” “our,” “us,” or “we”) gathers and processes your personal information in accordance with this privacy notice. This notice provides you with the necessary information regarding your rights and obligations, and explains how, why, and when we collect, process, and use your personal information.
Information That We Collect
We collect your information in several ways, including: Information we collect from you; Information we collect from when you use our Services; and Information we collect from third parties. When you use our Services (e.g., purchase a subscription or other products, browse our sites, use our apps, complete a survey, etc.), we may request and you may provide your personal information to Udumbara. Udumbara collects, uses and processes your personal information to provide our Sites and Services to you, and to meet our legal, statutory and contractual obligations. The specific information we collect depends upon your use of the Sites and our other Services, as described below.
“Personal information” is information that identifies you as an individual or relates to or is reasonably capable of being associated with an identifiable individual, and includes the data sets referred to below.
The personal information that we may collect includes:
-Your Email (only applicable to account registration and for our newsletter service and subscription);
-Your billing and contact information, such as your name, address, telephone number (only applicable to subscription of certain paid services);
-Your user account information (including email address and access information);
-Your IP address and unique user/device identifiers;
-Your demographic information, such as your age and gender;
-Your payment card or other online payment information;
-Your purchasing history and subscription information;
-Browser type and browsing history;
-Device type and other device information;
-Cookies and tags;
-Your user generated content (such as your comments to our Sites, chat information, and other content that you generate and provide to us);
-Information on user activity/behaviors, interests, and preferences on our Sites and apps; and
-Information from third parties and other databases.
How We Collect Your Information
The personal information is collected in several different ways, including: registration forms to sign up for our online and offline Services, billing, user generated content (e.g., comments), survey, contacting our service center, different cookies and tracking technologies, and other sources.
a. Information You Provide to Us. This includes the information that you provide to Udumbara directly — for instance, when you purchase a subscription or create an account, contact us with a question, applying for a job through our Sites, post comments or other user generated content to our Sites, or otherwise directly interact with us. Please note that information you choose to provide through comments or other user generated content to our Sites may be publicly accessible and viewable to other visitors to the Sites.
b. Information Gathered During the Use of Our Services. This includes among others information automatically gathered through your use of our Sites, such as through cookies.
c. Information Collected after Consent. In some contexts, we may ask for your consent before collecting certain types of information.
d. Data from other sources. We also obtain data from other partners or third parties that help us provide our services to you.
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
Cookies and Ad-Targeting Technologies
Please be advised that if you choose to reject all cookies, then certain areas of the Site might not function properly.
Examples of cookies we use:
First Party Cookies. We use first party cookies, including session cookies and preference cookies, to remember your selections, choices, and preferences for when you interact with our Sites. Session cookies are temporary and are automatically deleted once you close your Internet browser. Preference cookies are first party cookies that remain on your device until you delete them or they are otherwise removed upon expiration.
The third-party partners we use who may utilize cookies or other tracking technologies include:
—Google: to provide Google Analytics (as Analytics Cookies) to analyze behavior of your use of our Sites, apps, and other Services, in order to improve our Services and provide you and other users with a better experience;
—Facebook, Twitter, and other Social Media Partners (Social Media Cookies): to enable the sharing of content through social media sites and otherwise allow you to interact or connect with such sites while using our platforms;
—Advertising partners: Google (Google Ad Manager) and Lotame: to collect information about your activities on our Sites and apps, and serve you personalized advertising.
—Interest-Based Advertising & Analytics: We utilize third parties such as Revcontent to collect information about your activities on our Sites and apps, and serve you interest-based advertising and analyze the activity on our Sites and apps.
Other Technologies: We collect many different types of information from other technologies to improve the quality of our Site and the services we provide. For example, we may collect usage data and other information about the device you use to access our Site, your operating system and/or mobile device type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. We may record the IP address of the device you use to connect to the Internet.
These technologies include web beacons and scripts: Web beacons are pieces of code embedded in a website or e-mail to monitor your activity on the website or your opening of the e-mail, and which can pass along information such as the IP address of the computer or device you use to view the website or open the e-mail, the URL page on which the web beacon is located, the type of web browser that was used to access the website, and previously set cookie values. Web beacons are sometimes used to collect advertising data, such as counting page views, promotion views or advertising responses. Disabling your computer’s, device’s or web browser’s cookies may prevent some web beacons from tracking or recording certain information about your activities. Please be advised that if you disable all such cookies, then certain areas of the Site might not function properly.
Scripts are pieces of code embedded in a website to define how the website behaves in response to certain key or click requests sent by the user. Scripts are sometimes used to collect information about the user’s interactions with the website, such as the links the user clicks on. Scripts are often temporarily downloaded to the user’s computer or device from the website server, active only while the user is connected to the Site and deactivated or deleted when the user disconnects from the website. Please be advised that if you disable any scripts through your web browser or other means, then certain areas of the Site might not function properly.
Software Development Kits (“SDKs”): We may use SDKs on our mobile app to collect analytics regarding the use and functionality of our mobile app. Additionally, we may collect mobile ad identifiers on our mobile app for interest-based or cross-application advertising and analytics. To opt-out of the collection of mobile data for cross-application advertising, please contact us utilizing the information in the “Other Questions” Section below. Additionally, if you access our mobile app utilizing an iPhone, you may turn off cross-application tracking in the Privacy section of your phone settings.
Your Cookie Choices
When it comes to how you want to use or allow cookies to be used on your devices, you are in control. Most internet browsers are initially set to accept cookies. You can set your browser to block or otherwise control what cookies your browser or mobile device accepts via your browser or mobile device settings. Additionally, you can choose to modify your settings and delete cookies that are otherwise stored on your device. Please consult the instructions provided by your browser or your mobile device’s manufacturer to determine how you can limit the placement of and/or remove cookies or other technologies. Please note, however, that limiting or disabling essential cookies and other technologies may impact or adversely affect some portion or functions of our Sites.
Controlling Cookies and Opt Out Choices
You can visit the following sites for comprehensive information on how to manage cookies and how to opt out of cookies used for advertising and marketing purposes:
For individuals in the United States:
-The Digital Advertising Alliance’s Consumer Choice tool at https://www.aboutads.info/choices
-The Digital Advertising Alliance’s AppChoices program at https://www.aboutads.info/appchoices
-The Network Advertising Initiative’s opt-out program at https://www.optout.networkadvertising.org/
For EU/EEA-based individuals:
-The EDAA opt-out program at https://www.youronlinechoices.eu
We partner with third-party sponsors, affiliates, vendors, and other companies who might have links, content, or applications on the Sites. These third parties might also use tracking tools on our Sites or other Sites to collect information about you when you use the Sites. They may collect information about your online activities over time and across different Sites and other online services. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about such a link, content, or application, you should contact the third entity directly. We are not responsible for the content or privacy practices on any websites, applications, tracking tools, or other technology that are not operated by Udumbara, even though our Sites might link to them or they might link to our Sites.
How We Use Your Personal Information
Udumbara takes your privacy very seriously. The purposes and reasons for collecting, processing, and using your personal information are detailed below:
-To provide you with the subscriptions, news, content, other information, and other Services that you seek from us;
-to improve the contents of the Sites and apps to serve you, and make them more suitable to your needs and increase their usability;
-to analyze how you and other users interact with our Sites;
-to provide customer support;
-to communicate with you about your account, your subscription or other transactions;
-to make your navigation more pleasant and personalized, with our products (such as contents) and services personalized to you;
-to facilitate your experience and social sharing;
-to analyze and develop our new products and services for the interest of users;
-to send you newsletters, offers or other communications about our products and services, such as special or promotional events, including services, products, or events, or other materials;
-to detect, investigate, and prevent activities that may violate our Terms of Service or other policies, or which may be fraudulent or illegal;
-in specific cases we will be contractually obligated to share your data with one of our third party partners explained above.
In these instances, we will make it clear that the third party partners, which the data you share will be transferred to, follow applicable privacy and data protection regulations.
Sharing Your Personal Information
We may share or disclose your personal information to help provide our Services to you. For instance, we may share your information with our affiliated companies and service providers to respond to your requests or process your subscriptions. We may also provide your Personal Information to third party service providers who assist us in providing certain services. For example, we may share the information we collect from you with our cloud hosting service providers.
We may also disclose or share your information for the following purposes:
a. To facilitate and improve the quality of our Services.
b. To protect our users and network against fraud and security threats.
c. To comply with a legal obligation.
d. To protect and defend our rights or property.
e. To prevent or investigate possible wrongdoing in connection with the Services.
f. To protect the personal safety of individuals or the public.
g. To protect against legal liability.
h. When there is a good faith belief that such action is necessary to investigate or protect against harmful activities to our guests, visitors, associates, or property (including the Websites), or to others. This may include disclosures to law enforcement to investigate potential criminal activity or other civil violations.
We may share your information with the following types of entities and third parties:
1. our affiliated companies within the Udumbara family;
2. our third-party service providers, such as Google, to analyze how users use our websites and apps, track user interests, trends and patterns in order to serve you personalized content which is relevant to your interests;
In certain situations, we will only share your information with your consent, as noted below.
We may from time to time be required to provide information to law enforcement or other governmental authorities pursuant to a warrant, court order, or other lawful process.
Sharing your Personal Information with Our Advertising and Marketing Partners
Some of the above sharing and use of your information is only done where we have obtained your consent to do so. For example, we may ask your consent to provide your personal information, including IP address information, interest data, unique IDs and other information to certain third parties that help us advertise and market our services. In those instances where we ask your consent, we will only share your information with those third parties where you have given us permission to do so. You can withdraw your consent at any time by contacting us at using the contact information listed in the “Exercising your Privacy Rights” section below.
Udumbara takes your privacy seriously and we take reasonable measures and precautions to protect and secure your personal information. This includes implementing physical, technical, administrative, and other safeguards to protect you and your information from unauthorized access, alteration, disclosure or destruction.
Encryption is our security strategy to ensure the stored personal information can be accessed only by the authorized roles and services with audited access to the encryption keys.
Personal information is encrypted and stored in a private and isolated environment for extended security.
Consequences of Not Providing Your Data
You are not obligated to provide your personal information to Udumbara. However, there may be times where your information is required for us to provide you with our Services, deliver requested products, or provide you with the content, feedback, or other materials that you request from us. In certain situations, we will not be able to offer some or all of our products or Services to you without requesting or collecting your personal information.
How Long We Keep Your Data
Udumbara retains your personal information for as long as necessary for the purpose for which it is collected, to provide you with our Services, such as our Sites and apps.
Our Policy on “Do Not Track” Signals
We do not support “Do Not Track.” Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable “Do Not Track” by visiting the “Preferences” or “Settings” page of your web browser.
We may track users across time and over different websites or platforms.
Your Privacy Rights
Individuals may have certain rights over their personal information under particular laws. Please see the following sections regarding the rights you may have over your information:
1. Your Rights under the EU General Data Protection Regulation (“GDPR”) and United Kingdom General Data Protection Regulation (“UK GPDR”)
—For residents from the United Kingdom (UK), or the European Economic Area (EEA) and Switzerland, this section allows you to exercise your rights under the European Union’s (EU) General Data Protection Regulation (GDPR) and the UK’s version of the GDPR (UK GDPR), as applicable. Although applicable data protection legislation in relevant jurisdictions may afford similar rights, there may be circumstances where some of these rights do not apply under or are modified by, local law. Udumbara takes reasonable steps to allow you to correct, amend, delete or limit the use of your personal information, and exercise other rights available under applicable law. Udumbara therefore informs you that, where applicable under relevant law, you are entitled to the following: Right to Access / Disclosure: The right to have access to your personal data upon simple request – that is, you may receive a copy of such data upon receipt of a verifiable request, along with other information related to the processing.
i. Right to Correction/Rectification: The right to correct your personal data if you find it is inaccurate, incomplete or obsolete.
ii. Right to Erasure / “Right to be Forgotten”: The right to obtain the deletion of your personal data in the situations set forth by applicable data protection law.
iii. Withdrawal of Consent to Processing: The right to withdraw your consent to the data processing without affecting the lawfulness of processing, where your personal data has been collected and processed based on your consent and not any other basis.
iv. Right to Object: The right to object to the processing of your personal data under certain circumstances, in which case we may ask you to justify your request by explaining to us your particular situation.
v. Right to Restrict Processing: The right to request limits to the processing of your data, when allowed by and in circumstances set forth under applicable law, as well as to object to any direct marketing from us.
vi. Right to Restrict Automated Individual Decision-Making (Profiling): The right to not be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you.
vii. Right to Data Portability: The right to have your personal data directly transferred by us to a third-party processor of your choice (where technically feasible; may be limited to situations when processing is based on your consent).
To exercise any of these rights, please contact us at the contact information listed in the “Exercising your Privacy Rights” section below. Note that we may ask you to verify your identity before responding to such requests.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the relevant request; this is to ensure that your data is protected and kept secure.
Please bear in mind that if you exercise such rights, this may affect our ability to provide our products and services.
2. Your Rights Under Australia’s Privacy Act of 1988
We intend to allow Australian residents to exercise their rights under the Privacy Act 1988 and associated Australian Privacy Principles. Although applicable data protection legislation in relevant jurisdictions may afford similar rights, there may be circumstances where some of these rights do not apply under or are modified by, local law. Udumbara takes reasonable steps to allow you to correct and amend your personal information, and exercise other rights available under applicable law. We therefore inform you that, where applicable under relevant law, you are entitled to the following:
a. Right to Access / Disclosure: The right to have access to your personal data upon simple request – that is, you may receive a copy of such data upon receipt of a verifiable request, along with other information related to the processing.
b. Right to Correction/Rectification: The right to correct your personal data if you find it is inaccurate, incomplete or obsolete.
To exercise any of these rights, please contact us at the contact information listed in the “Exercising your Privacy Rights” section below. Note that we may ask you to verify your identity before responding to such requests.
3. Your Rights Under Canada’s Personal Information Protection and Electronic Documents Act
We intend to allow Canadian residents to exercise their rights under the Personal Information Protection and Electronic Documents Act (“PIPEDA”). Although applicable data protection legislation in relevant jurisdictions may afford similar rights, there may be circumstances where some of these rights do not apply under or are modified by, local law. Udumbara takes reasonable steps to allow you to correct, amend, and delete your personal information, and exercise other rights available under applicable law. We therefore inform you that, where applicable under relevant law, you are entitled to the following:
—Right to Access / Disclosure: The right to have access to your personal data upon simple request – that is, you may receive a copy of such data upon receipt of a verifiable request, along with other information related to the processing.
—Right to Correction/Rectification: The right to correct your personal data if you find it is inaccurate, incomplete or obsolete.
—Right to Deletion: The right to obtain the deletion of your personal data in the situations set forth by applicable data protection law.
Your California Privacy Rights Regarding Direct Marketing Information
California law allows California residents once a year to request information regarding our disclosure of your personal information, if any, to third parties for those third parties’ direct marketing purposes during the preceding calendar year. This information includes:
a. The categories of information we disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year;
b. The names and addresses of third parties that received the information; and
c. If the nature of the third party’s business cannot be determined from their name, to obtain examples of the products or services marketed.
Exercising your Privacy Rights
As described above, you may have certain rights to access, delete, or otherwise control the use, collection, and/or disclosure of their information. Once Udumbara receives and confirms a verifiable consumer request, we will work to promptly process such request. The need to verify an individual’s identity is critical to protecting your information, and ensuring that your information is not shared with anyone pretending to be you or someone who is not authorized to act as your agent on your behalf. To that end, we must be able to verify your information in order to process your request.
You may submit a verifiable request via the following:
By email: email@example.com
Please provide sufficient information for us to determine if this applies to you. Please include “Privacy Rights Request” in the Subject line of your email. In the body of your request, please include your full name, year of birth, telephone number, email address and/or user name at Udumbara, complete mailing address (street name and number, city, state, and zip code) so that we can process your request.
We will ask you to provide information about yourself so that we can verify your identity as part of this process. This information may include your name, address, account information, and any other information deemed necessary by Udumbara to reasonably verify your identity, to ensure that your information is not shared with anyone impersonating you. Once we have verified your identity, we will work to fulfill your request in a timely manner. Please note there may be some situations in which we are unable to fulfill your request, such as if we cannot find any information about you within our systems. Additionally, we may not be able to honor a deletion request in some situations, such as if your information is necessary to fulfill the Services you requested or meet a legal obligation. We will inform you whether we can fulfill your rights request.
We may ask for additional information if we have difficulty confirming your identity. We will not share your information or honor other requests in those situations in which we are unable to confirm a request for your information is a “verifiable request.”
Lodging A Complaint
Udumbara only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you are a resident of the UK or the EEA and wish to raise a complaint regarding the processing of your personal information or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with your local supervisory authority.
If you would like to raise an issue or lodge a complaint directly with Udumbara, please contact us using the information below.
If you have other questions, contact us by
sending an email to the following address: firstname.lastname@example.org