Privacy Policy

Utorify’s Privacy Policy is effective as of June 27, 2024.

At Utorify, we value our community. We believe in transparency and are committed to being upfront about our privacy practices.

In this Utorify Privacy Policy (this “Policy”), we describe what information we gather about you, what we use that information for, and who we share that information with, when you visit or use the Utorify website located at www.utorify.com, our online services, and the software provided on our website or in connection with our services (collectively the “Site”). All features of the Site are hosted or provided by Polymath Inc. (together with its subsidiaries, “Polymath”, the “Company,” “we” or “us”), and this Policy describes the privacy practices of the Company. Among the reasons that the Company collects personal information from people who visit or use the Site is to provide better services to all users of the Site.

This Policy is designed to assist you in understanding and making informed decisions when using the Site, about how personal information about you may be obtained, used, shared, and disclosed to third parties by the Company. This Policy also describes how you can opt out of some uses of your personal information.

This Policy, together with the Utorify Terms of Use posted on the Site, sets forth the general rules and policies governing your use of the Site. Depending on your activities when visiting the Site, you may be required to agree to additional terms and conditions.

IF YOU ARE A RESIDENT OF CALIFORNIA, COLORADO, CONNECTICUT, DELAWARE, INDIANA, IOWA, MONTANA, NEW HAMPSHIRE, NEW JERSEY, OREGON, TENNESSEE, TEXAS, UTAH OR VIRGINIA, THEN THERE ARE SPECIAL PROVISIONS OF THIS WEBSITE PRIVACY POLICY THAT APPLY TO YOU. THESE SPECIAL PROVISIONS ARE CONTAINED IN THE “SUPPLEMENTAL PRIVACY POLICY AND NOTICE FOR RESIDENTS OF CALIFORNIA, COLORADO, CONNECTICUT, DELAWARE, INDIANA, IOWA, MONTANA, NEW HAMPSHIRE, NEW JERSEY, OREGON, TENNESSEE, TEXAS, UTAH AND VIRGINIA,” ATTACHED AS EXHIBIT 1 BELOW.

WHEN YOU ACCESS THE SITE, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, OR TO ANY CHANGES THAT MAY BE SUBSEQUENTLY MADE TO THIS PRIVACY POLICY, YOU SHOULD IMMEDIATELY STOP ACCESSING THE SITE.

1. CHANGES TO THIS PRIVACY POLICY

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time in our sole discretion. To let you know when we make changes to this Policy, we will amend the Effective Date. The new modified or amended Policy will apply from that new Effective Date, so please be sure to check back periodically. Your continued use of the Site after any change to this Policy will constitute your acceptance of the changes. The Company will not use your personally identifiable information, in a manner that is materially different than what was stated at the time it was collected, without your consent.

2. THE TYPE OF INFORMATION WE COLLECT AND HOW IT IS USED

“Personal information” is information that may be used to specifically identify or contact you, such as your name, postal address, email address, and telephone number, among other things. When you visit the Site, personal information about you is not collected unless you voluntarily provide it. If you provide personal information to us, the Company might receive additional information about you from other sources and combine that additional information with the personal information that you have provided. If you communicate through the Site, the content of your communications, and your e-mail address, along with any responses from the Site, may be retained.

In certain circumstances, the Company may request, or may allow or otherwise provide you an opportunity to submit, your personally identifiable information in connection with a feature, program, promotion or some other aspect of the Site. For example, you may: (i) provide your name, mailing/shipping address, email address, and phone number when registering with the Site or using services offered through the Site; (ii) provide personal information when you post a product or services rating or recommendation on the Site; (iii) submit your payment information when making a purchase through the Site; (iv) provide demographic information when participating in a survey or poll on the Site; (v) provide your social media profile information when connecting your social media accounts to the Site; (vi) upload a profile picture or other images for your user profile; (vii) provide your location data when using location-based services or features; (viii) submit content, such as comments, reviews, or multimedia files, as part of user-generated content features; (ix) participate in contests, sweepstakes, or other promotions that require personal information for entry or notification purposes; (x) provide information during customer service interactions, including through chat, email, or phone communications; (xi) submit educational or employment background information when applying for a job through the Site; (xii) provide your preferences and interests when creating wish lists or using other personalization features; (xiii) provide family or household information when using family account features; (xiv) provide your travel details when booking travel-related services; (xv) submit any other type of personal information that may be required for specific activities or services offered through the Site; or (xvi) provide account details created on third-party services such as Stripe when making transactions through the Site. Certain information may not be personally identifiable when standing alone (e.g., your age), but may become so when combined with other information (e.g., your age and name). Whether or not you provide this information is your choice; however, in many instances this type of information may be required to participate in a particular activity, realize a benefit that the Site may offer, or gain access to certain content on the Site.

The personally identifiable information that you submit to the Company is generally used to carry out your requests, respond to your inquiries, or better serve you, or is used in other ways naturally associated with the circumstances in which you provided the information. The Company may use this information to contact you later for a variety of reasons, such as for customer service, to provide you with information or services, or to process transactions that you have requested or agreed to receive. We may use this information to provide you with marketing or promotional information for products or services of the Company or of the Company’s parent company, subsidiaries or other affiliated companies. We may use this information to communicate with you about content or other information that you have posted or shared with the Company via the Site, or with other users of the Site, or with service providers who use the Site. We may use this information with regard to your use of the Site and, in the discretion of the Company, with regard to changes to the Site or Site policies. We may also use this information for internal business purposes, or for purposes disclosed at the time you provide your information, or as otherwise set forth in this Policy. The following is a nonexhaustive list of certain purposes for which we may use your personal information:

1. Marketing and Promotions: Providing you with marketing or promotional information for products or services of the Company, its parent company, subsidiaries, or other affiliated companies.
2. Content Communication: Communicating with you about content or other information that you have posted or shared with the Company via the Site, with other users of the Site, or with service providers who use the Site.
3. Site Use and Policy Updates: Informing you about your use of the Site and any changes to the Site or Site policies.
4. Internal Business Purposes: Utilizing the information for internal business purposes, or for purposes disclosed at the time you provide your information, or as otherwise set forth in this Policy.
5. Improving User Experience: Enhancing the functionality, performance, and quality of the Site and services to provide a more seamless and enjoyable experience for users.
6. Personalizing Content Recommendations: Tailoring content and suggestions based on your preferences, behavior, and teractions to make your experience more relevant and engaging.
7. Fine-tuning AI Models: Utilizing the data to train, improve, and validate machine learning and artificial intelligence models that power various features and services offered by the Site.
8. Facilitating Targeted Marketing and Advertising: Delivering personalized advertisements and marketing communications that are likely to be of interest to you based on your data and interactions.
9. Aggregated Analytics: Analyzing data in aggregated form to understand trends, usage patterns, and user behavior, which helps us in making informed business decisions.
10. De-identified Datasets: Creating de-identified or anonymized datasets for research, analysis, and product development without compromising individual privacy.
11. Service Development and Enhancement: Informing the development of new products, services, and features, as well as enhancing existing ones based on user feedback and data analysis.
12. Security and Fraud Prevention: Monitoring, detecting, and preventing fraudulent activities and ensuring the security of our systems and users.
13. Compliance with Legal Obligations: Ensuring compliance with applicable laws, regulations, and legal processes, including responding to legal requests and investigations.
14. Customer Support and Service Improvement: Providing better customer support, resolving issues more effectively, and improving overall service quality based on user interactions and feedback.

The collected data includes both raw data and processed forms, such as aggregated analytics and de-identified datasets, to ensure that we can continually improve and evolve our offerings while protecting your privacy.

You may opt out from receiving future promotional information from the Company, or direct that the Company not share your information in the future with any affiliated companies or third parties for their direct marketing purposes. To opt out of receiving promotional offers simply unsubscribe via the email sent for that purpose.

In certain instances the Company may also share your personally identifiable information with its third-party vendors who use the Site or who are performing functions on behalf of the Company, or on behalf of affiliated companies of the Company (e.g., vendors that process credit card orders, deliver merchandise, administer promotions, provide marketing or promotional assistance, analyze data, assist with customer service, and the like). In addition, the Company may share your personally identifiable information with participating sponsors of a program or promotion, and with third parties who assist the Company in using the content or other information that you have posted or shared with the Company via the Site. Further, the Company may share your personally identifiable information with third parties such as promotional partners of the Company, and persons or companies with whom the Company has marketing or other relationships, among others.

“Non-personal information” is information about you or your activities through which you cannot be personally identified. When you visit the Site, we may collect such information. Examples include the type of browser and operating system you are using, the type of device you are using, the domain name of your Internet service provider, the pages you visit on the Site and how long you spend on each page, and the unique number assigned to your computer or Internet connection. This type of information can include certain personally identifiable information that has been de-identified (i.e., information that has been rendered anonymous). The Company does not re-identify de-identified data. The Company and its third-party service providers may obtain non-personal information about you from information that you provide, either separately or together with your personally identifiable information. This type of information may be used for a variety of purposes, including monitoring use of and improving the Site, as well as for internal analysis.

The Site may utilize a standard technology called “cookies,” described in more detail below, to provide the Site’s personalization feature, and web server logs to collect information about how the Site is used. Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, time spent at the Site, and other websites visited just before your visit to the Site. This information may be collected on an aggregate basis. None of this information may be associated with you as an individual.

Non-personal information is used in a variety of ways, including to help analyze Site traffic, to understand customer needs and trends, to carry out targeted promotional activities, and to improve the services provided by the Company. The Company may use your non-personal information by itself, or we may aggregate it with information that the Company has obtained from others. The Company may share your non-personal information with its affiliated companies and third parties to achieve these objectives and others; however, this information is anonymous information that does not personally identify you. The Company may provide data analyses and certain non-personal information to third parties (who may in turn use this information to provide advertisements tailored to your interests), but this will not involve disclosing any of your personally identifiable information.

3. INFORMATION YOU PROVIDE ABOUT THIRD PARTIES

If you send another Site user or someone else a communication from the Site, as when you send Site content to a business, supplier, service provider, friend, or other person, the information you provide (names, email addresses, etc.) may be used to facilitate the communication and may not be used for any other marketing purpose unless the Company obtains consent from that person or the Company explicitly states otherwise. Please be aware that when you use any “send to” functionality on the Site, your email address may be included in the communication sent.

4. INFORMATION FROM THIRD PARTIES ABOUT YOU

The Company also may, from time to time, supplement the information we collect with outside records from third parties in order to enhance our ability to serve you, to tailor our content to you, and to offer you opportunities to purchase products or services that we believe may be of interest to you. Additionally, data may be obtained from third-party sources such as payment services, analytics providers, or advertising partners. The Company may combine the information we receive from those other sources with information we collect through the Site. In those cases, the Company will apply this Policy to any personally identifiable information received, unless otherwise specifically disclosed by the Company at the time you provide your personally identifiable information.

The Company is affiliated with other businesses and works closely with them. These businesses may offer promotions, or may sell items or services to you through the Company’s services. The Company may also provide services or sell products jointly with affiliated businesses. Due to the nature of our business model, when an affiliated business is associated with your transaction, we may share information that is related to such a transaction with that affiliated business. The Company may share aggregated demographic information with business partners.

5. INFORMATION ABOUT SITE USE

In addition to any personally identifiable information or other information that you choose to provide to the Company via the Site, the Company and its third-party service providers may use a variety of technologies, now and hereafter devised, that automatically collect certain Site usage information whenever you visit or interact with the Site. This information may include your browser type, your operating system, the page served, the time, the source of a request, the preceding pages viewed by you, and other similar information. The Company may use this usage information for a variety of purposes, including to enhance or otherwise improve the Site. In addition, the Company may also collect your IP address or some other unique identifier for the particular device you use to access the Internet, as applicable (collectively, referred to herein as a “Device Identifier”). A Device Identifier is a number that is automatically assigned to your computer, and the Company may identify your device by its Device Identifier. When analyzed, usage information helps the Company determine how the Site is used, such as what types of visitors arrive at the Site, what type of content is most popular, what type of content you may find most relevant, and what types of visitors are interested in particular kinds of content and advertising. The Company may associate your Device Identifier or Site usage information with the personally identifiable information you provide, and may treat the combined information as personally identifiable information. Site usage information may be collected using various methods, such as web beacons, cookies, mobile device identifiers, and embedded scripts, among other methods.

A. COOKIES—IN GENERAL

We use cookies and other tracking mechanisms to track information about your use of our Site and our products and services. We may combine this information with other personal information we collect from you. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive or SSD storage device through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and our products and services, while others are used to enable a faster log-in process or to allow us to track your activities with respect to our Site and our products and services. Some cookies are used to enable certain functions of the Site, and some are used to store your preferences. We may use cookies to remember information that changes the way the Site or our services behave or look. Some of the cookies we use are necessary to enable you to move around the Site and use its features, including accessing secure areas that may contain content for registered users. We may use accounts-related cookies to authenticate users and prevent fraudulent use of user accounts. We may use analytics cookies to track information about how the Site and our products and services are used so that we can make improvements. We may also use analytics cookies to test new advertisements, pages, or features, or new functionality of the Site and our services, to see how our users react to them. In addition, we may use web beacons or tracking pixels to count visitor numbers, and performance cookies to track how many individual users access the Site, and how often. This information is used for statistical purposes only and it is not our intention to use such information to personally identify any user. However, if you have registered and signed into the Site, we may combine such sign-in information with information from our web analytic services and cookies to analyze in more detail how you use the Site. In addition to our own cookies, we may also use various third-party cookies to report usage statistics for the Site and our products and services, to deliver advertisements on and through the Site, and so forth. Cookies may be used to create profiles of our users, based on the user information we collect, and cookies may enable users' identification across multiple websites. You can find more detailed information about cookies and how they work at http://www.aboutcookies.org/. Cookies may include session cookies and persistent cookies.

B. SESSION COOKIES

Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session, or while you are logged into the Site. This allows us to process your online transactions and requests and to verify your identity, after you have logged in, as you move through our Site.

C. PERSISTENT COOKIES

Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.

D. DISABLING COOKIES

Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The “Help” or “Options” portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you visit our Site and disable cookies, you will be able to browse certain areas of the Site, but some features may not function, you may not be able to store your preferences, and some of our pages may not display properly. Be aware that any preferences you have set will be lost if you delete all cookies, including your preference to opt out from cookies, as this itself requires an opt-out cookie to have been set.

E. YOUR CONSENT TO THE USE OF COOKIES

By using the Site or purchasing or using any of our products or services, and by consenting to the terms of this Policy, you consent to our use of cookies.

6. CHOICE AND CONTROL

We know that members of our community value having control over their own information, and therefore the Company gives you the choice of providing, editing or removing certain information. You may change or correct your Utorify account information. For various reasons, we may contact you about our services or your activity.

A. DATA AND ACCOUNT DELETION AVAILABLE TO ALL USERS

Any Utorify user, regardless of location, account type, or method used to register or sign in, including Facebook, may request deletion of their account and personal information.

If you can access your account, sign in to Utorify, open Account Settings, go to the Danger Zone, select “Delete account,” complete the identity verification steps, and confirm deletion.

If you cannot access your account, or do not have a registered account but believe we hold personal information about you, email us at support@utorify.com with the subject “Data Deletion Request.” Include the email address used with Utorify and, if applicable, indicate that you used Facebook to sign in. Do not send us your password. We may request additional information reasonably necessary to verify your identity.

Following verification, we will delete or de-identify the personal information associated with your request, including personal information received from Meta, unless limited retention is required by law or reasonably necessary for security, fraud prevention, dispute resolution, transaction records, or fulfillment of existing customer purchases. Retained information will be restricted to those purposes and removed when it is no longer required. We will notify you when the request has been completed.

7. INFORMATION SHARING AND DISCLOSURE

The Company will share personal information with companies, organizations or individuals outside of the Company if we have a good-faith belief that access, use, preservation or disclosure of such personal information is reasonably necessary to: (i) meet any applicable law, regulation, legal process or enforceable governmental request; (ii) enforce applicable provisions of the Utorify Terms of Use posted on the Site, including investigation of potential violations; (iii) detect, prevent, or otherwise address fraud, security or technical issues; and (iv) protect against harm to the rights, property or safety of the Company, Site users, or the public as required or permitted by law.

It is not our policy to sell or rent your personal information to unaffiliated third parties. Your personal information may be shared by us with unrelated third parties, including contractors that provide services to the Site. When we share your personal information with a third party with whom we have a contractual relationship, we use reasonable efforts to include clauses in our contract with such third party that require them to comply with the privacy laws and regulations relevant to that information, and to restrict the use to the purposes for which it was provided to them.

8. COMMUNITY

Utorify offers several features that allow Site users to connect and communicate in semi-public forums. When you publish content or information, it means that you are allowing everyone to access and use that information, and to associate it with you. Please use common sense and good judgment when posting in these forums or sharing your personal information with others on the Site. Be aware that any personal information that you submit there can be read, collected, or used by others, and could be used to send you unsolicited messages. The Company generally does not remove content from community spaces, and your posts may remain public after your account is closed. You are responsible for the personal information you choose to post in community spaces on the Site.

Other Utorify members may follow your activities on the Site; for example, to receive updates about your activities. You may choose to make certain activities and communications private on the Site.

9. OTHER USES

For security reasons, the Company does not recommend that you send non-public personally identifiable information, such as passwords, social security numbers or bank account information, to us by email. The Company may communicate with you by email in the following circumstances: (a) when you request a particular service or sign up for a feature that involves email communications; (b) when our email to you relates to requests you have made from or through the Company (e.g., product/services updates, customer support, etc.); (c) when the Company is sending you information about products and services; (d) when you have consented to being contacted by email for a particular purpose; (e) when you send the Company an e-mail, post information on the Site, or otherwise submit information to the Company electronically, where the Company may email you to follow up or otherwise communicate with you with respect thereto; (f) when we provide you with legal notices or notices with respect to your use of the Site; or (g) when we are otherwise attempting to facilitate a transaction between you and the Company, or between you and someone else. In certain instances, the Company may provide you with tools on the Site that will allow you to set your preferences for receiving email communications from the Company or other persons, where such tools allow you to agree to some communications but not others. You may opt out of receiving future commercial email communications from the Company by sending an email to the Company opting out of future promotional email communications; provided, however, that the Company reserves the right to send you transactional emails, such as customer service communications and auto-renewal billing notices.

10. DO-NOT-TRACK DISCLOSURE

Currently, our systems do not recognize browser “do-not-track” requests.

11. EXCEPTIONS TO THIS PRIVACY POLICY

This Policy applies to all of the services the Company offers, excluding any services that have separate privacy policies that do not incorporate this Policy. Furthermore, it does not apply to services offered by other companies or individuals, including products, services, or sites that may be displayed to you on the Site, or other websites linked from the Site. This Policy does not cover the information practices of other companies and organizations who advertise on or provide services through the Site, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

Regarding the Site’s links to other websites, neither the Company nor any third parties that help us operate the Site are responsible for the information collection or privacy practices of such other websites. You should consult the privacy policies of other websites before you visit those websites or provide any personal information to those websites. The Company or third parties that help us operate the Site may provide information at the Site about programs and events that are sponsored by or co-sponsored by other firms or organizations. If you register for any of these programs or events, then the Company and third parties that help us operate the Site may have no control over the use of your personal information by such other firms or organizations.

Third-party applications may be available via the Site. The owners of these applications (“Third-Party Owners”) may collect personally identifiable information from you, and may have their own policies and practices. The Company is not responsible for how Third-Party Owners or their applications use your personally identifiable information. Such Third-Party Owners may have their own terms of service, privacy policies or other policies, and may ask you to agree to the same. The Company is not responsible for those policies or for the practices of Third-Party Owners. Be sure to review any available policies before submitting any personally identifiable information to a third-party application, or otherwise interacting with it.

The Company and third parties that help us operate the Site reserve the right to disclose your personal information: (i) if it is believed that the Site is being used to commit unlawful acts; (ii) if disclosure of your personal information is required to comply with applicable laws or regulations or with a court or administrative order, or will help to enforce any applicable terms of use; and (iii) to protect your safety and security, including the safety and security of property that belongs to you, or to protect the safety and security of the Site or of third parties.

12. SECURITY

Although the Site employs security measures that are reasonably appropriate to protect your personal information, neither the Company nor any third party that helps us operate the Site guarantees that such security precautions will protect against the loss or misuse of your personal information. Similarly, neither the Company nor any third party that helps us operate the Site guarantees the privacy of personal information that you transmit over the Internet or that may be collected in transit by others, including contractors that provide services to the Company or to third parties that help us operate the Site. Our data is stored in secure data centers provided by cloud services providers such as DigitalOcean and AWS.

By using the Site, you agree that you understand the foregoing provisions of this section, and you consent to the transfer of your personal information across national borders, and to the storage and processing of your information in a country that may not provide the same level of privacy protection that your country provides.

13. CHILDREN'S PRIVACY

The Company does not intend the Site or our products or services to be used by individuals under the age of 18 without the supervision of a parent or guardian. The Company relies upon parents or guardians 18 years of age or older to determine if the Site and our products and services are appropriate for viewing, access, or participation by individuals under the age of 18. If an individual under the age of 18 uses the Site or any of our products or services, such individual may only do so under the supervision of a parent or guardian who is 18 years of age or older.

We do not seek or knowingly collect any personal information about children under 13 years of age. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make commercially reasonable efforts to delete such information from our database.

14. CONTACT US

If you have any questions regarding this Policy you may send an email to contact@utorify.com or write to:

Attn.: Privacy Policy
Polymath Inc.
2939 Crockett St. Apt 538S
Fort Worth, TX 76107

Exhibit 1: Supplemental Privacy Policy and Notice for Residents of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah and Virginia

This Supplemental Privacy Policy and Notice (“Supplemental Policy”) applies to information collected about persons residing in California, Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah or Virginia, and supplements the information contained in the Utorify Privacy Policy. It provides information required under:

• the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”),
• the Colorado Privacy Act of 2021 (the “CPA”),
• the Connecticut Data Privacy Act of 2022 (“CDPA”),
• the Delaware Personal Data Privacy Act (DPDPA),
• the Indiana Data Privacy Law (“Indiana DPL”),
• the Iowa Data Privacy Law (“Iowa DPL”),
• the Montana Consumer Data Privacy Act (MCDPA),
• the New Hampshire Act Relative to the Expectation of Privacy (NHAREP),
• the New Jersey Privacy Act (NJPA),
• the Oregon Consumer Data Privacy Act (OCDPA),
• the Tennessee Information Protection Act (TIPA),
• the Texas Data Privacy and Security Act (TDPSA),
• the Utah Consumer Privacy Act of 2022 (the “UCPA”),
• the Virginia Consumer Data Protection Act of 2021 (the “VCDPA”);

and any and all regulations arising therefrom. In this Supplemental Policy the CCPA, CPA, CDPA, DPDPA, Indiana DBR, Iowa DBR, MCDPA, NHAREP, NJPA, OCDPA, TIPA, TDPSA, UCPA, and VCDPA are referred to collectively as the “State Privacy Laws.”

This Supplemental Policy is incorporated into and is a part of the Utorify Privacy Policy.

This Supplemental Policy describes the practices of the Company regarding the collection, use, and disclosure of Personal Information and provides instructions for submitting data subject requests. Some portions of this Supplemental Policy apply only to consumers of particular states, and we have indicated where those portions are state-specific.

If you are unable to review or access this Supplemental Policy due to a disability, you may contact us at contact@utorify.com to access this Supplemental Policy in an alternative format.

1. DEFINITIONS SPECIFIC TO THIS SUPPLEMENTAL POLICY

“Consumer” means a natural person who resides in California, Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah or Virginia and to whom we offer information, goods, or services. For purposes of this Supplemental Policy, this term includes natural persons who reside in California and engage with us (i) as part of business-to-business transactions, or (ii) as employees, job applicants, officers, directors, or independent contractors. Under certain of the State Privacy Laws the term does not include an individual acting in a commercial or employment context.

“Disclosed for a Business Purpose” means, with respect to a Consumer’s Personal Information, that the Personal Information is disclosed by us to a Third Party or Vendor, for our operational purposes, or for the operational purposes of the Third Party or Vendor, where such operational purposes may include data auditing, data security, debugging, nonpersonalized advertising, research for technological development, improving and upgrading our services, maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of our business.

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household. Personal Information includes “personal data” as that term is defined in the State Privacy Laws. Personal Information also includes “Sensitive Personal Information,” as defined below. Personal Information includes pseudonymous data when the data is applied with other information that reasonably links the data to an identified or identifiable individual. “Pseudonymous data” means any information that cannot be attributed to a specific individual without the use of additional information, provided that the additional information is kept separately and is subject to appropriate technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable individual.

“Sensitive Personal Information” means Personal Information that reveals a Consumer’s: (1) social security, driver’s license, state identification card, or passport number; (2) account log-in name or number, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to the individual’s account; (3) precise geolocation; (4) racial or ethnic origin; (5) religious beliefs; (6) union membership; (7) contents of email or text messages, unless we are the intended recipient; (8) genetic data; (9) biometric information used to uniquely identify the Consumer, (10) citizenship or immigration status, (11) health, sex life, or sexual orientation, (12) transgender or non-binary status, or (13) status as a victim of crime. Sensitive Personal Information also includes “sensitive data” as that term is defined in the State Privacy Laws.

“Shared” means, with respect to a Consumer’s Personal Information, that the Personal Information is shared, rented, released, disclosed, disseminated, made available, transferred, or otherwise communicated orally, in writing, or by electronic or other means, by us to a Third Party for cross-context behavioral advertising.

“Third Party” means a person or organization which is not a Consumer, Vendor, or an entity owned or controlled by us and as defined by the State Privacy Laws.

“Vendor” means a “contractor,” “processor,” or “service provider,” which collects, stores, or otherwise handles data for us, as those terms are defined in the State Privacy Laws.

Other terms used in this Supplemental Policy may be defined under the State Privacy Laws, and they shall have the meanings described in those statutes. If there are variations between such definitions in different laws, you will be covered by the definition that applies in your state. For example, if you are a Virginia consumer, terms defined in the VCDPA shall apply to you if they are used in this Supplemental Policy.

2. THE PERSONAL INFORMATION WE COLLECT AND DISCLOSE

The chart below shows the categories of Personal Information that we have collected about Consumers in the preceding 12 months; examples of Personal Information in each category; the types of sources from which each category of Personal Information is collected; the Business Purposes for which each category of Personal Information is collected and Disclosed; and the types of Vendors or Third parties to or with whom each category of Personal Information is Disclosed for a Business Purpose.

As this chart shows, we may Disclose certain Personal Information to Third Parties or Vendors for Business Purposes. We do not sell or Share (as defined in Section 1 above) your Personal Information with Third Parties.

A. SENSITIVE PERSONAL INFORMATION WE COLLECT AND DISCLOSE

We will not collect any category of Personal Information (including Sensitive Personal Information) that is not listed above, or use or Disclose any Personal Information (including Sensitive Personal Information) for a Business Purpose not listed above, without first providing you with notice.

3. RETENTION OF DATA

We intend to retain each category of Personal Information described above only for as long as necessary to fulfill the purpose for which it was collected, or a related and compatible purpose consistent with the average Consumer’s expectations, and to comply with applicable laws and regulations. We consider the following criteria when determining how long to retain Personal Information: why we collected the Personal Information; the nature of the Personal Information; the sensitivity of the Personal Information; our legal obligations related to the Personal Information; and risks associated with retaining the Personal Information.

4. YOUR RIGHTS TO YOUR PERSONAL INFORMATION

California, Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah and Virginia Consumers have certain rights with respect to the collection and use of their Personal Information. Those rights vary by state. As required by the CCPA, we provide detailed information below regarding the data subject rights available to California Consumers. Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah and Virginia Consumers have similar rights and can find more detail by referencing the CPA, CDPA, DPDPA, Indiana DBR, Iowa DBR, MCDPA, NHAREP, NJPA, OCDPA, TIPA, TDPSA, UCPA, or VCDPA, as applicable.

You have the right to request certain information regarding the Personal Information we have collected about you. You may make such a request up to twice in a 12-month span. Please note that there are circumstances in which we may not be able to comply with your request, including when we cannot verify your request or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following submission of your request, if this is the case.

A. RIGHT TO RECEIVE INFORMATION ON PRIVACY PRACTICES

You have the right to receive the following information at or before the point of collection:

• The categories of Personal Information to be collected;
• The purposes for which the categories of Personal Information are collected or used;
• Whether or not that Personal Information is sold or shared with Third Parties or disclosed to Vendors;
• If the Company collects Sensitive Personal Information, the categories of Sensitive Personal Information to be collected, the purposes for which it is collected or used, and whether that information is sold or Shared;
• The length of time the Company intends to retain each category of Personal Information, or if it is not possible to provide the exact period, then the criteria used to determine that period;
• Confirmation that we are or are not processing your Personal Information;

We have provided such information in this Supplemental Policy, and you may request further information about our privacy practices by info@utorify.com as at the contact information provided below.

B. RIGHT TO KNOW AND RIGHT TO ACCESS

You have the right to request certain information we have collected about you. You have the right to request:

• Specific pieces and categories of Personal Information we collected about you;
• The categories of sources from which Personal Information was collected;
• The purposes for which Personal Information was collected, Shared, sold, or processed;
• The categories of Personal Information we Shared, sold or Disclosed for a Business Purpose; and
• The categories of Vendors or Third Parties with whom we Shared or sold Personal Information or Disclosed Personal Information for a Business Purpose.

C. RIGHT TO DELETE

You have the right to request that we delete certain Personal Information that we have collected.

D. RIGHT TO CORRECT

You have a right to request that we correct any inaccurate Personal Information we may retain about you.

E. RIGHT TO OPT OUT OF THE SALE AND SHARING OF YOUR PERSONAL INFORMATION

You have the right to opt out of the sale and Sharing of your Personal Information with Third Parties, and the right to opt out of the processing of Personal Information for targeted advertising purposes, as defined in the State Privacy Laws.

As mentioned above, we do not sell or Share (as defined in Section 1 above) your Personal Information with Third Parties. We also do not have actual knowledge that we sell or Share Personal Information of Consumers under 16 years of age. However, this section allows you to record your preference that we not sell or Share your Personal Information with Third Parties in the future.

If you would like to request that we do not share your Personal Information pursuant to the requirements of the CCPA, click here. The link will take you to an interactive webform that you can complete and submit to make a request to opt out.

If you use an authorized agent to submit your request to opt out, we will request that the agent provide us with proof that he, she, or it has been authorized by you to act on your behalf. The CCPA requires you to provide the authorized agent written permission to exercise your rights under the CCPA.

If you opt out of the sharing of your Personal Information, we will wait at least 12 months before asking you if we may share your Personal Information. You have the right to opt in to the sharing of your Personal Information after you have opted out. If you would like to opt in to the sharing of your Personal Information, please email us at contact@utorify.com. Opting in is a two-step process in which you will first clearly request to opt in, and then separately confirm that choice.

Global Privacy Control (“GPC”) is a setting that you can enable in your web browser to communicate your privacy preference for not having certain information about your webpage visits collected across websites. For more details, including a description of how to turn on GPC, visit https://globalprivacycontrol.org/. Our Site recognizes and responds to GPC signals.

F. RIGHT TO LIMIT THE USE OF YOUR SENSITIVE PERSONAL INFORMATION

You have the right to instruct us to limit the use and disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods reasonably expected by an average Consumer or for specific business purposes defined by applicable law. However, we do not use Sensitive Personal Information for purposes beyond those authorized by the CCPA. We will not process your Sensitive Personal Information without your prior affirmative consent, which you may then revoke at any time.

G. RIGHT TO NON-DISCRIMINATION

You have a right to exercise the above rights, and we will not discriminate against you for exercising these rights. If you are an employee, job applicant, or independent contractor of the Company, we will not retaliate against you for exercising your rights under the CCPA. Please note that a legitimate denial of a request to access, delete, or opt out is not discriminatory, nor is charging a fee for excessive or repetitive requests, as permitted by the CCPA.

H. HOW TO EXERCISE YOUR RIGHTS

If you would like to make any of the data subject requests listed above, please email us at support@utorify.com. When you submit a request to exercise your data subject rights, we may ask you to provide information that will enable us to verify your identity. Please see Section 5 (“Verification Process”) below. The level of verification will depend on the request being submitted. Subject to Section 5 (“Verification Process”) below, you may designate an authorized agent to exercise your data subject rights on your behalf.

I. RIGHT TO APPEAL

If the Company denies any of the data subject requests listed above for any reason, we will explain the justification for the denial. You have the right to appeal our decisions about your data subject requests. If you would like to appeal a decision regarding your data subject requests, please email us at support@utorify.com. Please state that your request is an “Appeal,” and describe the date and nature of your original request. Following such an appeal, we will promptly inform you of any action taken or not taken in response to the appeal.

5. VERIFICATION PROCESS

When you submit a request to exercise your data subject rights, we may ask you to provide information that will enable us to verify your identity.

You may designate an authorized agent to exercise your data subject rights on your behalf. If your authorized agent does not have a power of attorney pursuant to state law in your state of residence, then we may require your authorized agent to provide proof that you have given the agent signed permission to submit the request, and we may also require you to either: (i) verify your own identity directly with us, or (ii) directly confirm with us that you have provided the authorized agent permission to submit the request.

We may deny a request from an authorized agent on your behalf if the authorized agent does not submit proof that he, she, or it has been authorized by you to act on your behalf if we request such proof.

6. ADDITIONAL CALIFORNIA PRIVACY RIGHTS

Residents of the State of California, under certain provisions of the California Civil Code, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed certain personally identifiable information, as defined under California law, during the preceding year for third-party direct marketing purposes. You are limited to one request per calendar year. In your request, please attest to the fact that you are a California resident, and provide a current California address for our response. You may request the information in writing at:

Attn.: Privacy Policy
Polymath Inc.
2939 Crockett St. Apt 538S
Fort Worth, TX 76107

7. CHANGES TO OUR SUPPLEMENTAL POLICY

This Supplemental Policy is current as of the Effective Date set forth in the Utorify Privacy Policy. We may change this Supplemental Policy from time to time at our sole discretion. To let you know when we make changes to this Supplemental Policy, we will amend the Effective Date. The new modified or amended Supplemental Policy will apply from that new Effective Date, so please be sure to check back periodically. Your continued use of the Site after any change to this Supplemental Policy will constitute your acceptance of the changes. The Company will not use your personally identifiable information, in a manner that is materially different from what was stated at the time it was collected, without your consent.

8. CONTACT US

If you have any questions regarding this Supplemental Policy, or our practices regarding the collection, use, disclosure, sale, sharing, and retention of Personal Information, you may send an email to contact@utorify.com or write to:

Attn.: Privacy Policy
Polymath Inc.
2939 Crockett St. Apt 538S
Fort Worth, TX 76107

Last Updated: June 27, 2024.