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Privacy Policy

Last updated March 31, 2021 ‍ ‍

 

Thank you for choosing to be part of our community at Framework,Inc., doing business as Framework (“Framework”, “we”, “us”, or “our”). In this Privacy Policy, we seek to explain to you in the clearest way possible what Personal Information (defined below) we collect, how we use it and what rights you have in relation to it. ‍ This Privacy Policy applies when you visit our websites, http://www.framework.so and https://www.getupliftnow.com (collectively, the “Site”), download and use our mobile application (the “App”), and use our platform for health and wellness organizations and professionals, which may be used to build and facilitate community-based health and wellness programs (including via the Site or App or any related services, sales, marketing or events, and together with the Site and the App, the “Services”). We hope you take some time to read through it carefully, as it is important. If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of our Sites or Apps and the Services. Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your Personal Information with us. If you have any questions or concerns about our policy, or our practices with regards to your Personal Information, please contact us at contact@upliftgroups.com. This Privacy Policy is incorporated into and forms part of our Terms of Service.

 

TABLE OF CONTENTS

  • WHAT INFORMATION DO WE COLLECT?
  • HOW DO WE USE YOUR INFORMATION?
  • DISCLAIMER WILL YOUR INFORMATION BE SHARED WITH ANYONE?
  • WHO WILL YOUR INFORMATION BE SHARED WITH?
  • DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  • IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
  • HOW LONG DO WE KEEP YOUR INFORMATION?
  • HOW DO WE KEEP YOUR INFORMATION SAFE?
  • DO WE COLLECT INFORMATION FROM MINORS?
  • WHAT ARE YOUR PRIVACY RIGHTS?
  • DATA BREACH CONTROLS FOR DO-NOT-TRACK FEATURES DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  • DO WE MAKE UPDATES TO THIS POLICY?
  • HOW CAN YOU CONTACT US ABOUT THIS POLICY?

 

1. WHAT INFORMATION DO WE COLLECT? We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Information”) as follows: ‍Personal.Information you provide to us. In Short: We collect Personal Information that you provide to us such as name, address, contact information, passwords and security data, and payment information. We collect Personal Information that you voluntarily provide to us when registering at the Services or Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or Apps (such as posting messages in our online forums or entering competitions, contests or giveaways) or otherwise contacting us. The Personal Information that we collect depends on the context of your interactions with us and the Services or Apps, the choices you make and the products and features you use. The Personal Information we collect can include the following: Contact Information. We collect first name, maiden name, last name, and nickname; email addresses; and other similar data. Credentials. We collect passwords, password hints, and similar security information used for authentication and account access. Automatically Collected Information. We automatically collect certain information relating to your use of the Service, as described further below. Payment Data. Our payment processor, Stripe, Inc. (“Stripe”) will collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Stripe; we store only a tokenized version of such information and do not maintain payment card information on our servers. You may find Stripe’s privacy policy here: https://stripe.com/privacy. All Personal Information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such Personal Information. ‍Information automatically collected ‍In Short: Some information — such as IP address and/or browser and device characteristics — is collected automatically when you visit our Services or Apps. We automatically collect certain information when you visit, use or navigate the Services or Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services or Apps and other technical information. This information is primarily needed to maintain the security and operation of our Services or Apps, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site. Advertising networks may use cookies to collect Personal Information. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources and follow the opt-out instructions there. If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings. ‍Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this information, click here. ‍Email Open/Click Information. We may use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email. Information collected through our Apps ‍In Short: We may collect information regarding your geo-location, mobile device, push notifications, when you use our apps. If you use our Apps, we may also collect the following information: Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device's settings. Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's calendar, camera, contacts, microphone, reminders, SMS messages, storage, sensors, social media accounts, and other features. If you wish to change our access or permissions, you may do so in your device's settings. Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address. Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.

 

2. HOW DO WE USE YOUR INFORMATION? In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent. We use Personal Information collected via our Services or Apps for a variety of business purposes described below. We process your Personal Information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below. We use the information we collect or receive: To facilitate account creation and logon process. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract. To send communicate with you. We may use your Personal Information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies. To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user's consent. To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and Contractual. To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond. To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order. To deliver Services to the user. We may use your information to provide you with the requested service. To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services. To analyze how you interact with our Service. To develop new products and services. To prevent fraud, criminal activity, or misuses of our Services, and to ensure the security of our IT systems, architecture, and networks. For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services or Apps, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include Personal Information within the scope of this Privacy Policy. Marketing and. Communications. We may use your Personal Information to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email [or telephone number], we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. You can also control the marketing emails [and/or text messages] you receive by updating your settings through your account. In addition, if at any time you do not wish to receive future marketing communications, you may contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests.

 

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE? In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations. We may process or share data based on the following legal basis: Consent: We may process your data if you have given us specific consent to use your Personal Information for a specific purpose. Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests. Performance of a Contract: Where we have entered into a contract with you, we may process your Personal Information to fulfill the terms of our contract. Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved. More specifically, we may need to process your data or share your Personal Information in the following situations: Vendors, Consultants and Other Third-Party Service Providers. We may share your Personal Information with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: our service providers and partners, payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. Pursuant to our instructions, these parties will access, process, or store Personal Information in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your Personal Information. Business Transfers. We may share or transfer your information in connection with, or during diligence or negotiations of, any merger, sale of company assets, financing, reorganization, bankruptcy, receivership, dissolution or acquisition of all or a portion of our business to another company (collectively, a “Transaction”). This information may be shared with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as a part of or following that Transaction alone or along with other assets. Business and Referral Partners. We may share your information with our business partners to offer you certain products, services or promotions. In addition, if you are referred to or otherwise join a particular group or organization within the Service, we may share your information with theadmin(s) of the group that you joined. If the admin(s) or managers of a particular group or organization within the service decides to discontinue using the Service, we may provide them with an export of certain data associated with users in the applicable group or organization. Other Users. If you choose to do so, your Personal Information may be made available to other users of the Service. For example, you have the choice to elect the name that will be visible to other Users. ‍Affiliates: We may share Personal Information with our current and future affiliates, meaning an entity that controls, is controlled by, or is under common control with Framework. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Policy.

 

4. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY? In Short: We may transfer, store, and process your information in countries other than your own. Our servers are located in the USA. If you are accessing our Services or Apps from outside the USA, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your Personal Information (see "WILL YOUR INFORMATION BE SHARED WITH ANYONE?" above), in the USA, and other countries.

 

5. HOW LONG DO WE KEEP YOUR INFORMATION? In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, while we have a business need to do so, or otherwise required by law, whichever is longer. We will only keep your Personal Information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your Personal Information for longer than the period of time in which users have an account with us. When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information.

 

6. HOW DO WE KEEP YOUR INFORMATION SAFE? In Short: We aim to protect your Personal Information through a system of organizational and technical security measures, but no security measures are 100% secure. We have implemented commercially reasonable technical and organizational security measures designed to protect the security of any Personal Information we process. However, please remember that we cannot guarantee that the internet itself is 100% secure. Although we will use commercially reasonable efforts to protect your Personal Information, transmission of Personal Information to and from our Services or Apps is at your own risk. You should only access the services within a secure environment.

 

7. THIRD-PARTY SERVICES In Short: This Privacy Policy does not govern information you provide to Third Party Services you visit through the Service. The Service may contain links to other websites or services not operated or controlled by Company, including social media services (“Third Party Services”). The information that you share with Third Party Services will be governed by the specific privacy policies and terms of service of the Third Party Services and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Services directly for information on their privacy practices and policies.

 

8. DO WE COLLECT INFORMATION FROM MINORS? In Short: We do not knowingly collect data from or market to children under 16 years of age. We do not knowingly solicit data from or market to children under 18 years of age. By using the Services or Apps, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services or Apps. If we learn that Personal Information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at privacy@upliftgroups.com.

 

10. WHAT ARE YOUR PRIVACY RIGHTS? In Short: In some regions, such as the European Economic Area, you may have rights that allow you greater access to and control over your Personal Information. You may review, change, or terminate your account at any time. In some regions (like the European Economic Area), you may have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your Personal Information, (ii) to request rectification or erasure; (iii) to restrict the processing of your Personal Information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your Personal Information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws. If we are relying on your consent to process your Personal Information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal. If you are resident in the European Economic Area and you believe we are unlawfully processing your Personal Information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/dataprotection/bodies/authorities/index_en.htm. If you have questions or comments about your privacy rights, you may email us at privacy@upliftgroups.com.

 

11. WHAT ARE YOUR CHOICES? In certain circumstances providing Personal Information is optional. However, if you choose not to provide Personal Information that is needed to use some features of our Service, you may be unable to use those features. If you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact information provided. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

 

12. ONLINE TRACKING AND DO-NOT-TRACK SIGNALS We and our third party service providers may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site and use that information to send targeted advertisements. Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.

 

13. DO WE MAKE UPDATES TO THIS POLICY? In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws. We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information. 14.

 

 

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Rush Sadiwala, by email at rush@upliftgroups.com, or by post to: Framework Rush Sadiwala 800 Avenue of the Americas, Apt 21C New York, NY 10001 United States

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