“This document has been prepared in English and has been translated into Spanish, French and Portuguese solely for the convenience of the reader. In the event of any conflict between this document and the English version, the English version shall prevail”.

Last modified: [08/07/2024]

INTRODUCTION

Ugami Inc. (“Company”, “We” or “Our”) respect your privacy and are committed to protecting it by complying with this policy.

This policy describes:

How we collect, use, disclose, and protect the personal information of our customers and website users (“you”).

Describes the types of information we may collect from you or that you may provide when you visit the website www.ugami.com use of our mobile applications, feature, widget, messaging app such as WhatsApp and Discord or other online service that is owned or controlled by us that posts a link to this Privacy Policy and by Ugami offline. (Our “Website”)

Our practices for collecting, using, maintaining, protecting, and disclosing that information.

Privacy laws generally define “personal information” or “personal data” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. This policy applies to information we collect, use, or disclose about you:

On this Website.

In email, text, and other electronic messages between you and this Website.

Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.

When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.

When you communicate with us via messaging apps such as WhatsApp, Discord, Telegram, Facebook Messenger, iMessage etc.

The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.

This policy DOES NOT apply to information that:

We collect offline or through any other means, including on any other Company or third-party website.

You provide to or is collected by any third party, through any application or content (including advertising) that may link to or be accessible from the Website.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates. 

INFORMATION WE COLLECT ABOUT YOU

We collect and use several types of information from and about you, including:

Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, gender, date of birth, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, billing and account information, in-game purchase information, including transaction types and use of virtual items, game achievements, statistics and information on bugs and malfunctions (“Gameplay Data”).and any other identifier we may use to contact you (“personal information”). 

Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as in-app purchases or subscription renewals, demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. 

Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.

Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.

HOW WE COLLECT INFORMATION ABOUT YOU

We use different methods to collect your information, including through:

Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise. 

User contributions. You may also provide information for us to publish or display on public Website areas or transmit to other Website users or third parties.

Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Third parties or publicly available sources, for example, our business partners.

Through messaging apps, for example, WhatsApp, Discord, Telegram, Facebook Messenger, iMessage etc.

Information You Provide to Us 

The information we collect directly from you on or through Our Website may include:

Information that you provide by filling in forms on Our Website. This includes information provided at the time of registering to use Our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.

Records and copies of your correspondence (including email addresses), if you contact us.

Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

Your search queries on the Website.

Your communications with us via third party messaging apps for example, WhatsApp, Discord, Telegram, Facebook Messenger, iMessage etc.

You may also provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages/you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.

Information We Collect Through Cookies and Other Automatic Data Collection Technologies  

As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.

Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical data and does not include personal information, and we may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.

Store information about your preferences, allowing us to customize our Website according to your individual interests.

Speed up your searches.

Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. 

Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.

Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). 

Third Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Website, including advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content. 

We do not control these third parties’ tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

To present our Website and its contents to you.

To provide you with information, products, or services that you request from us.

To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.

To provide you with notices about your account/subscription, including expiration and renewal notices.

To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.

To notify you about changes to our Website or any products or services we offer or provide though it.

To improve our Website, products or services, marketing, or customer relationships and experiences.

To allow you to participate in interactive features, social media, or similar features on our Website.

To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.

To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.

Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in our competitions.

To track third party app installations (conversions) to award points, offer rewards to Users based on their active usage of Affiliate applications and enable in-app gift card redemption.

To present relevant offers, challenges, through messaging apps

In any other way we may describe when you provide the information.

For any other purpose with your consent.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

To our subsidiaries and affiliates.

In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all Ugami’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Ugami Inc. about our customers and users is among the assets transferred.

To advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others. 

To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.

To contractors, service providers, and other third parties such as messaging apps that we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

To Scrip and Loyalty Reward Programs. Scrip programs (allow you to instruct us to divert a percentage of the amount you spend on purchases to participating schools and other non-profit organizations) or third-party loyalty programs (which allow you to earn “points” on purchases through Our Website and use the points toward certain rewards offered by the loyalty program). In such case, the information we will share with that program administrator may include your name, payment information, the date and amount of your purchase, and other information. Please note that once we disclose this information, the scrip or loyalty company may use and share it with others in accordance with its own privacy policy. We do not control the privacy practices of third parties and you should review the privacy policy of any scrip or loyalty partner or other cobranded partner before participating.

To fulfill the purpose for which you provide it. 

For any other purpose disclosed by us when you provide the information.

With your consent.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.

To enforce or apply our terms of use [https://ugami.com/terms-of-use/] and other agreements, including for billing and collection purposes.

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Ugami Inc., Our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

TRANSFERRING YOUR PERSONAL INFORMATION

We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing. Ugami is a United States company. Please be aware that information we collect will be transferred to and processed in the United States and other countries. By using Our Website or providing us with any information, you fully understand and unambiguously consent to this transfer, processing, and storage of your information in the United States and other jurisdictions, for which the privacy laws may not be as comprehensive as those in other countries or jurisdictions. As a result, this information may be subject to access requests from governments, courts, or law enforcement in the United States and other countries according to laws in those jurisdictions.

PERSONAL DATA USE AND PROCESSING GROUNDS (EEA, SWITZERLAND AND UK USERS)

This section describes our lawful bases for processing your personal data.  The “How We Use Your Information” section above explains how we use your personal data. 

We will only process your personal data if we have a lawful basis for doing so.  Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

Contractual Necessity:  We process the following categories of personal data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you the Services.  When we process data due to contractual necessity, failure to provide such personal data will result in your inability to use some or all portions of the Services that require such data. 

Certain Contact Data (name, email address)

Certain Device/IP Data

Legitimate Interest:  We process the following categories of personal data when we believe it furthers the legitimate interest of us or third parties: 

Certain Contact Data

Web Analytics

Social Network Data

Geolocation Data

Other identifying information that you voluntarily choose to provide

           Examples of these legitimate interest include (as described in more detail above): 

Providing, customizing and improving the Services.

Marketing the Services

Corresponding with you.

Meeting legal requirements and enforcing legal terms.

Completing corporate transactions.

Other Processing Grounds:  From time to time, we may also need to process personal data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest. 

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information: 

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this Website may not be accessible or may not function properly. For more information about tracking technologies, see Information We Collect Through Cookies and Other Automatic Data Collection Technologies. 

Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish to have your email address/contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to [email protected]. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email. This opt-out does not apply to information provided to the Company as part of a product purchase, warranty registration, product service experience, or other transactions.

DATA SECURITY

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. 

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.  We urge you to be careful about giving out information in public areas of the Website like message boards, which any Website visitor can view.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. 

DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent. 

INTERNATIONAL DATA TRANSFERS

Your personal information may be transferred to, and processed in, countries other than the country in which you reside.  These countries may have data protection laws that are different to the laws of your country.  Our Website servers are located in the United States (“U.S.”) and our third party service providers and partners operate around the world but with our data stored in the U.S.  By using the services you acknowledge that any personal data about you, regardless of whether provided by you or obtained from a third party, is being provided to us in the United States and hosted on services located in the U.S., and you authorize us to transfer, store or process your information to and in the U.S., and possibly other countries. 

CHILDREN UNDER THE AGE OF 16: Our Website is not intended for children under 16 years of age. No one under age 16  may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16 , do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at [email protected]

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at [email protected] to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may charge you a fee to access your personal information, however, we will notify you of any fee in advance.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If you are concerned about our response or would like to correct the information provided, you may contact Our Privacy Officer at [email protected]

WITHDRAWING YOUR CONSENT

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at [email protected]. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision. 

CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page [with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. 

We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

CONTACT INFORMATION 

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at: 

Ugami Inc.

200 Crandon Boulevard

|Suite 314

Key Biscayne, FL 33149

United States

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact us r using the contact information listed above.

ANNEX A: REGION-SPECIFIC NOTICES  

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal data about residents of certain countries, regions or states.

California

If you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with a Service, you have the right to request removal of unwanted data that you publicly post on the Our Website. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on Our Website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

Categories of personal information collected

We have collected the following categories of personal information in the past twelve (12) months:

Category Example Collected

A. Identifiers. Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name. 

B. Personal information categories listed in the California Customer Records statute. Name, contact information, education, employment, employment history and financial information. 

C. Protected classification characteristics under California or federal law. Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name. YES

D. Commercial information. Transaction information, purchase history, financial details and payment information. YES

E. Biometric information. Fingerprints and voiceprints. NO

F. Internet or other similar network activity. Browsing history, search history, online behavior, interest data, and interactions with our and other tracked websites, applications, systems, and advertisements. NO

G. Geolocation data. Device location. NO

H. Audio, electronic, visual, thermal, olfactory, or similar information. Images and audio, video or call recordings created in connection with our business activities. NO

I. Professional or employment-related information. Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us. NO

J. Education Information. Student records and directory information. NO

K. Inferences drawn from other personal information. Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics. YES

We may also collect other personal information outside of these categories in instances where you interact with us in-person, online, or by phone or mail in the context of:

Receiving help through our customer support via Our Website;

Participation in customer surveys or contests; and

Facilitation in the delivery of our Website and to respond to your inquiries.

How we use and share your personal information

More information about our data collection and sharing practices can be found in this Privacy Policy. You may contact us by email at [email protected], by visiting https://Ugami.com, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Disclosure of Personal Information

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data.

Ugami has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Ugami will not sell personal information in the future belonging to website visitors, users and other consumers.

Your rights with respect to your personal data

You have the right to request that we disclose to you what Personal Information (as defined in the CCPA) we collect, use, disclose, and sell, including the right to request that we provide to you the specific pieces of Personal Information we have collected about you in the prior 12 months (“Right to Know”) and you have the right to ask us to delete the Personal Information we collect about you (“Right to Delete”), subject to exceptions set forth in the CCPA. You also have the right to opt-out from the sale of your Personal Information. These rights are subject to some limitations, such as when we are retaining data to comply with our own legal obligations. You will not be required to create an account with us in order to submit a request. More information on each of these rights is below.

Right to be informed – Request to know

Depending on the circumstances, you have a right to know:

Whether we collect and use your personal information;

The categories of personal information that we collect;

The purposes for which the collected personal information is used;

Whether we sell your personal information to third parties;

The categories of personal information that we sold or disclosed for a business purpose;

The categories of third parties to whom the personal information was sold or disclosed for a business purpose; and

The business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to request deletion of the data – Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.

Other privacy rights

You may object to the processing of your personal data.

You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data.

If you would like to authorize an agent to act on your behalf in submitting a request to know, request to delete, or request to opt-out of the sale of your Personal Information, you may do so by submitting to us a declaration for the agent to make a request on your behalf. The written permission must state the full legal name of the agent, be clear about the permission, and be signed by you. Alternatively, if you have provided your authorized agent with a power of attorney under Probate Code sections 4000-4465, your agent may submit a copy of the power of attorney. Your agent’s identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request. We may deny a request from an authorized agent that does not submit proof that such agent has been validly authorized to act on your behalf in accordance with the CCPA.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. Depending on what you have used to interact with Our Website and to what you are requesting access, we may also request one or more of the following in order to verify your identity: e.g., phone number and mailing address. We may also use other verification methods as the circumstances dictate. We will also require a signed declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request before providing specific pieces of personal information.

If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to provide the requested information.

We will only use personal information provided in your request to verify your identity or authority to make the request. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

To exercise these rights, you can contact us by email at [email protected], by visiting https://Ugami.com, or by referring to the contact details listed in the CONTACT INFORMATION  section. You must put the statement “My California Privacy Rights” in the subject field of your email or in the address line of your envelope..

We will provide the requested information free of charge up to two (2) times in a twelve- (12-) month period, but please note that where we receive unfounded, excessive, or repetitive requests, we may elect to decline the request. Note also that we will not retain for purposes of data enquiries, information we do not ordinarily retain in the course of our regular business practices.

Response Timing

When you request access to the Personal Information we have collected or deletion of your Personal Information, we will typically provide the requested information within forty-five- (45-) days, and we will notify you within that time period if we need additional time to process your request.

ANNEX B:  EUROPEAN ECONOMIC AREA (EEA), UNITED KINGDOM, AND SWISS DATA SUBJECT RIGHTS 

If you are in the EEA, Switzerland or the UK, your rights in in relation to your personal data processed by us as a controller specifically include:

Right to access and/or portability:  You have the right to access any personal data that we hold about you and, in some circumstances, have that provided to you so that you can provide or “port” that data to another provider;

Right to erasure: In certain circumstances, you have the right to the erasure of personal that we hold about you (for example, if it is no longer necessary for the purposes for which it was originally collected);

Right to object to processing: In certain circumstances, you have the right to request that we stop processing your personal data and/or stop sending you marketing communications;

Right to rectification: You have the right to require us to correct any inaccurate or incomplete personal data; 

Right to restrict processing:  You have the right to request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about is not accurate or lawfully held). 

Withdraw consent.  If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You also have the right to lodge a complaint with a supervisory authority.  In the UK, the supervisory authority is the Information Commission Office (ICO) and in the EEA, this depends on the Member State (country). 

How to Exercise These Rights

To exercise these rights, you can contact us by email at [email protected], by visiting https://ugami.com, or by referring to the contact details listed in the CONTACT INFORMATION section. Please put the statement “My Privacy Rights” in the subject field of your email or in the address line of your envelope. 

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.