Urality Privacy Policy

Last modified: January 16, 2019

Introduction

Urality LLC (“Company” or ”We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you use our website at urality.com or any of our services, such as the Urality mobile application, along with any related software or Company servers (collectively, the “Urality Platform”) and outlines our practices for collecting, using, maintaining, protecting, and disclosing that information. We want to be transparent about the information we collect, how we use it, whom we share it with, and the controls we give you to access, update, and delete your information. After reading this privacy policy, if you still have questions, please contact us at https://urality.com/contact.

This policy applies to information we collect:
- Within the Urality Platform.
- In email, text, and other electronic messages between you and Company.
- When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by: (i) us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or (ii) any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Urality Platform.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Urality Platform. By accessing or using the Urality Platform, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Urality Platform after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 13

The Urality Platform is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Urality Platform. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Urality Platform or on or through any of its features/register on the Urality Platform, make any purchases through the Urality Platform, use any of the interactive or public comment features of the Urality Platform or provide any information about yourself to us, including your name, email address, telephone number, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at https://urality.com/contact.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of the Urality Platform, including information:
- by which you may be personally identified, such as name, email address, telephone number, location history, or ANY OTHER INFORMATION THE URALITY PLATFORM COLLECTS THAT IS DEFINED AS PERSONAL OR PERSONALLY IDENTIFIABLE INFORMATION UNDER AN APPLICABLE LAW (“personal information”);
- that is required for payment of services used in the Urality Platform;
- that is about you but individually does not identify you, such as aggregated location information and personal interests; and/or about your internet connection, the equipment you use to access the Urality Platform and usage details.
We collect this information:
- Directly from you when you provide it to us.
- Automatically as you navigate through the Urality Platform. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
- From third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through the Urality Platform may include:
- Information that you provide by filling in forms on the Urality Platform. This includes information provided at the time of registering to use the Urality Platform, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with the Urality Platform.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
- Details of transactions you carry out through the Urality Platform and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the Urality Platform.
- Your search queries on the Urality Platform.
- Views of posts within the Urality Platform, and types of content you view and attach to posts within the Urality Platform.

PLEASE NOTE THAT USE OF MANY FEATURES AND FUNCTIONALITIES OF THE URALITY PLATFORM, PARTICULARLY WITH RESPECT TO OUR MOBILE APPLICATION, WILL REQUIRE COMPANY TO HAVE ACCESS TO YOUR CAMERA AND GEOLOCATION DATA COLLECTED VIA YOUR DEVICE’S GPS FUNCTION, WIRELESS NETWORKS, CELL TOWERS, WI-FI ACCESS POINTS, AND OTHER SENSORS, SUCH AS GYROSCOPES, ACCELEROMETERS, AND COMPASSES.
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Urality Platform, or transmitted to other users of the Urality Platform or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Urality Platform with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with the Urality Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: (i) details of your visits to the Urality Platform, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Urality Platform; and (ii) 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, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve the Urality Platform 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 the Urality Platform according to your individual interests.
- Speed up your searches.
- Recognize you when you return to the Urality Platform.

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 the Urality Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Urality Platform.
- Web Beacons. Pages or other portions of the Urality Platform and our emails 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).
We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

Third-Party Use of Cookies (and Other Tracking Technologies)

Some content or applications, including advertisements, in the Urality Platform 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 the Urality Platform. 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 (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For 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, and our authorized third party service providers, may use information that we collect about you or that you provide to us, including any personal information:
- To present the Urality Platform and its contents to you.
- To provide you with information, products, or services that you request from us.
- To notify you about changes to the Urality Platform or any products or services we offer or provide through it or other products or services which may be of interest to you.
- To analyze trends and conduct research about improving the Urality Platform.
- To correlate information with other commercially available information to identify demographics and preferences to assist us in marketing efforts.
- To contact users for research, informational or marketing purposes.
- To learn about our users’ needs.
- To track traffic patterns and usage of the Urality Platform, including customizing our recommendations and promotions to you based on your information.
- To address information security and/or privacy practices control, network functioning, engineering, and troubleshooting issues. `
- To investigate claims and/or legal actions, violations of law or agreements, and compliance with relevant applicable laws and legal process.
- To comply with law, or based on our good-faith belief that it is necessary to conform or comply with the law, or otherwise to disclose information to prevent fraud and reduce credit risks, to cooperate with police and other governmental authorities, or to protect the rights, property or safety of visitors to the Urality Platform or the public.
- To process or engage in a sale of all or part of our business, or if we go through a reorganization or merger.
- To fulfill 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 entered into between you and us, including for processing credit cards, billing and collection.
- To allow you to participate in interactive features on the Urality Platform.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you and to display advertisements to our advertisers’ target audiences. For more information about steps you can take to control how your information is used, see Choices About How We Use and Disclose Your Information.

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.
- To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- 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 of Urality LLC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Urality LLC about the Urality Platform users is among the assets transferred.
- To third parties to market their products or services to you. 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.
- To fulfill the purpose for which you provide it. (e.g. payment processing)
- 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.
- To enforce or apply our terms of use (https://urality.com/tou) 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 Urality LLC, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
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 the Urality Platform may then be inaccessible or not function properly.
- Promotional Offers from the Company. If you do not wish to have your email address used by the Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the account registration form or at any other time by logging into the Urality Platform 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 [support@urality.com](mailto:support@urality.com). If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.
- Targeted Advertising. We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving certain targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website found at http://optout.networkadvertising.org/ or a successor site.
- Camera and Location Data. You can adjust our ability to access information from your device’s camera and about your location by adjusting the settings and permissions on your mobile device. Please note that limiting such permissions may limit or remove your ability to utilize the Urality mobile application and other elements of the Urality Platform. 
Accessing and Correcting Your Information

You can review and change certain elements of the personal information provided to Company by logging into the Urality Platform and visiting your account profile page.

You may also send us an email at [support@urality.com](mailto:support@urality.com) to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. 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.

If you delete your User Contributions from the Urality Platform, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Urality Platform users. Proper access and use of information provided on the Urality Platform, including User Contributions, is governed by our terms of use (https://urality.com/tou).

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of the Urality Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [support@urality.com](mailto:support@urality.com) or write us at: Urality LLC, The Yard: Center City 21 S 11th Street Floor 2 Philadelphia, PA 19107.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

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 the Urality Platform, 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 Urality Platform. The information you share in public areas may be viewed by any user.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we can neither guarantee the security of your personal information transmitted to the Urality Platform nor can we guarantee that such information will not become publicly available. 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 Urality Platform. You can reduce these risks by using common-sense security practices such as choosing a strong password, using different passwords for different services, and using up-to-date antivirus software on your electronic devices.

Users Outside of the United States

If you are visiting the Urality Platform from a location outside of the United States, your connection will be through and to servers located in the United States. All information you receive from the Urality Platform may be created on servers located in the United States, and all information you provide may be maintained on web servers and systems located within the United States. The data protection laws in the United States and other countries might not be the same as those in your country. By using the Urality Platform or submitting information to us, you specifically consent to the transfer of your information to the United States and to the facilities and servers we use, and to those with whom we may share your information.

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 Urality Platform. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account and through a notice on the Urality Platform home page. The date the privacy policy was last revised is identified 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 the Urality Platform and this privacy policy to check for any changes. your continued use of the Sites after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, send an email to [support@urality.com](mailto:support@urality.com) or write us at: Urality LLC, The Yard: Center City 21 S 11th Street Floor 2 Philadelphia, PA 19107.