Privacy Policy

Effective: December 6, 2019

This Privacy Policy (the “Privacy Policy”) serves to inform you of our policies and procedures regarding the collection, use and disclosure of the information we receive when you access and use all websites (the “Sites”), services, software, mobile applications, content, and all other products and services (all of the foregoing collectively, the “Services”) owned, controlled or offered, directly or indirectly, by Universal Product Company, Inc. (together with its affiliates, “UPC”, “we,” “our” or “us”). UPC believes that the privacy of its users is paramount and strives to use Personal Information (as defined below) only in ways outlined in this Privacy Policy. The Privacy Policy is incorporated by reference into our Terms of Service, currently available at [URL] (the “Terms of Service”). Any terms used herein and not defined will have the meanings given to them in the Terms of Service. By using the Services, you hereby warrant and represent that you have read, understand and agree to this Privacy Policy and the Terms of Service and that you are over 18 years of age. Please do not use, install or access the services if you do not agree to this privacy policy.

1. What We Mean by Personal Information

For purposes of this Privacy Policy, “Personal Information” means any information from or about a person that either identifies that person directly or that makes that person identifiable when it is combined with other information from or about that person from any source.

2. Information We Collect
Information You Provide To Us

When you use Services or otherwise communicate with us, we collect information that you provide to us directly. For example, we collect information in the following circumstances: you (i) use our mobile apps or visit the Sites, (ii) register for Services or create an account or profile or accept the creation of an account or profile on your behalf (an “Account”), (iii) access the Services through social networking sites or third party services, (iv) subscribe to newsletters, (v) purchase a product or Services on the Sites or in our mobile apps (“in-app purchase”), (vi) invite your friends to join the Services, “share” the Services social networking sites or perform other similar features, (vii) request technical support or otherwise communicate with us, and (viii) otherwise use our mobile apps or online Services where Personal Information is required for such use and/or participation. You can choose not to provide information that is requested of you by us; however, this may limit your ability to use or access the Services.

The information you provide to us directly may include, without limitation, the following information that may, alone or in combination with other data, constitute Personal Information:

  • Information that you provide to us when you register for an account as a Retailer or Supplier, including your name, email, phone number, contact information, job title, financial information and any other information you decide to provide;
  • Information you provide when you contact UPC, including your name, e-mail, inquiry, and any other information you decide to provide;
  • Information you provide in order to subscribe to our newsletters and updates, including your email address, the topic for which you wish to receive updates, or any other information you decide to provide us with. You may always unsubscribe from these emails by following the instructions included;
  • Information you provide when submitting or responding to an Inventory request, include your name, company, title, e-mail address, telephone number, and address;
  • Transaction and limited (non-PCI) payment data; and
  • Other information you may want to share with us.

Additionally, if another User refers you to us by providing us with your email address, we may send you a message. However, we will use your e-mail address only to send such other User’s message unless you otherwise affirmatively provide your information to us.

Automatically Collected Information

Most of the data we collect in and through the Sites and the Services is technical in nature and is collected and processed automatically through so-called application programming interfaces, software development kits, cookies and similar software-based technologies. Alone or in combination with other data, such automatically collected data may constitute Personal Information. The data we may collect by automated means may include, without limitation:

  • Device data: including, but not limited to, data on device advertising ID's and similar hardware qualifiers, and precise location data.
  • Network and internet information: including, but not limited to, URLs, Internet Protocol addresses, bounce rates, use of spoofing, active (TCP/IP) ports, number of sessions initiated, click streams, location information and network/Wi-Fi access points.
  • Information we collect on the use of the Sites via cookies. Please see the section “How Do We Use Cookies” below for more information.

We may use, depending on the Services, (i) location based on the IP address presented by you, (ii) network-based geo-location data based on proximity of network towers or the location of Wi-Fi networks, and/or (iii) geo-location data based on coordinates obtained from a mobile device’s GPS radio and location services. Your GPS geo-location is accessed in accordance with your device settings. If location services are enabled on your mobile device and/or a mobile application in connection with the Services, certain of the Services will passively and automatically send location information to UPC in order to for us to deliver location-specific information on your device and compile your individualized timeline. Please note that disabling location service will not anonymize data already collected and uploaded to our servers.

Google Analytics is an element of the Sites. By using cookies, Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the Sites, the Internet Protocol address, and the type of operating system used in the devices used to access the Website. By using a browser plugin available at provided by Google, you can opt out of Google Analytics.

Information You Post on the Services

When you create an account, you provide Personal Information, including contact information, such as your name, address and email address. If you are a Retailer, UPC may share your Personal Information with Suppliers that that have listed Inventory on the UPC Platform that you have indicated an interest in purchasing, and if you are a Supplier, UPC may share your Personal Information with Retailers that have indicated interest in purchasing Inventory that you have listed on the UPC Platform. You should exercise caution when deciding what Personal Information you disclose through the Service. We strongly recommend that you do not post any information through the Services that you otherwise do not want to share with the other Users.

Information You Share on Third Party Websites or through Social Media Services

The Services may include links to third-party websites and social media services where. Your use of these third-party websites and social media services may result in the collection or sharing of information about you by these third-party websites and social media services. We encourage you to review the privacy policies and settings on the third-party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third party websites and social media services.

3. Use of Collected Information

We use the information you provide to us for the following purposes: (i) to further our legitimate interests in providing the Services, including without limitation to collect and remit payment for paid features, (ii) to administer your use of the Services and any Accounts you may have with us, (iii) to personalize your experience, (iv) to provide to you Service announcements or inform you of new releases and features, (v) to facilitate communication between Users, (vi) to perform tasks on behalf of and according to instructions of a third party, such as payment processors or third party-service providers, (vii) to enforce our Terms of Service, (viii) to resolve any disputes between users of the Site or between such users and us, (ix) comply with a legal requirement or process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures; (x) to further our legitimate interest in protecting our rights, property, or safety and the rights, property and safety of the Services, our users or the public; and (xi) to contact you to obtain feedback from you regarding the Sites and the Services.

We use the information collected automatically for the following purposes: (i) to further our legitimate interests in monitoring and analyzing the use of the Services and for the technical administration of the Sites, (ii) to improve the Sites and the Services, (iii) to generate and derive useful data and information concerning the interests, characteristics and website use behavior of our users, (iv) to verify that users of the Services meet the criteria required to process their requests, and (v) to prevent fraudulent activities.

4. Third Parties We Share Personal Information With

We may disclose Personal Information you provide to us or that we collect automatically on the Sites and in and through the Services with the following categories of third parties:

  • Service providers, such as payment processors, web hosting and data storage service providers, and helping us deliver and develop the Services. data storage service providers, marketing service providers, and communications service providers
  • Public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties; and
  • Our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of the Sites and/or the Services and their advisors in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our stock and/or assets, or in connection with bankruptcy proceedings, or other corporate reorganization, in accordance with this Privacy Policy.
5. Links to Other Websites

We frequently make content or services from other websites available to you from links located on the Sites. We may present links in a format that enables us to keep track of whether these links have been followed. In addition, you may opt to link your Account to your social media account or other accounts, such as LinkedIn, in accordance with your Account settings (which you may change at any time) and respective policies of these third parties. This Privacy Policy applies only to the Sites and the Services. We do not exercise control over third party services or other websites that provide information. Your interactions with these third-party services are governed by the privacy policy of the company providing it. These other sites and services may place their own cookies or other files on your computer’s browser, collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the Personal Information that you submit, and the collection and use of such information and access of any third-party websites are subject to such third party’s privacy policy. We encourage you to read the privacy policies and other terms of such third parties before using their services.

6. Security

We understand the importance of privacy and security of Personal Information to our users and have made them a priority. UPC uses a variety of industry-standard security technologies and procedures to help protect Personal Information about you from unauthorized access, use, or disclosure and trains UPC employees on privacy and security issues. However, we cannot guarantee that unauthorized third parties will never be able to overcome those measures or use your Personal Information for improper purposes, and we do not promise that Personal Information about you or private communications will be protected from unauthorized disclosure or use.

7. Do Not Track

UPC does not track its customers over time and across third-party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals.

8. Managing Your Privacy

We keep your data on your behalf and for your benefit. You can correct your account information or terminate your account [by following the instructions on the Services or] by e-mail at, which you may also access for further assistance and questions regarding the Privacy Policy or for a copy of your account data. If you terminate your account or request us to delete your information, UPC will limit its access to Personal Information to perform what is requested by you and will delete information accessible to UPC within seven business days.

9. Your Rights

We take steps to help ensure that you are able to exercise your rights regarding Personal Information about you in accordance with applicable law. If you would like to access, review, erase, withdraw your consent, or object to, or restrict the processing of Personal Data we collect about you, you may submit a request to We will promptly review all such requests in accordance with applicable laws. Depending on where you live, you may also have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Information about you. We encourage you to first reach out to us at, so we have an opportunity to address your concerns directly before you do so.

10. California Residents

California Civil Code Section 1798.83 requires certain businesses that share customer personal information with third parties for the third parties’ direct marketing purposes to respond to requests from California customers asking about the businesses’ practices related to such information-sharing. We currently do not share or disclose your Personal Information to third parties for the third parties’ direct marketing purposes. If we change our practices in the future, we will implement an opt-out policy as required under California laws.

11. International Transfers of Personal Information

UPC is based in the United States. As a result, Personal Information that we collect in and through the Services and on the Sites may be transferred to our U.S. offices. In addition, we may work with third-party service providers in the U.S. and in other countries to support our business activities. Thus, Personal Information may be transferred to, stored on servers in, and accessed from the United States and countries other than the country in which the Personal Information was initially collected. In all such instances, we use, transfer, and disclose Personal Information solely for the purposes described in this Privacy Notice and in compliance with applicable laws.

12. Data Retention

We keep Personal Information related to your Account for as long as it is needed to fulfill the purposes for which it was collected, to provide our Services, to deal with possible legal claims, to comply with our business interests and/or to abide by all applicable laws. Thereafter, we either delete Personal Information about you or de-identify it. Please note that even if you request the deletion of Personal Information about you, we may be required (by law or otherwise) to retain the Personal Information and not delete it. However, once those requirements are removed, we will delete Personal Information about you in accordance with your request.

13. Changes to the Privacy Policy

Our security and Privacy Policy are periodically reviewed and enhanced as necessary. This Privacy Policy might change as we update and expand the Services. You can tell when this Privacy Policy was last updated by reviewing the Last Updated-legend on top of this page. We will endeavor to notify you of these changes by email, but will not be liable for any failure to do so. We also encourage you to review this Privacy Policy periodically. If you do not understand any of the terms or conditions of any of our policies, you may inquire regarding the same via email at Your continued use of the Services after any change in this Privacy Policy will constitute your acceptance of such change.

14. Contacting Us

If you have any concerns or questions about this Privacy Policy, please contact us at