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Privacy Policy

Your privacy is important to UCOBO. This Privacy Policy explains how UCOBO collects, uses, discloses and retains personal information, including personal information collected by UCOBO through its website, mobile app and telephone calls and when providing products or services.

1. Your Consent

By providing UCOBO with your personal information, you consent to the collection, use, disclosure and retention of that information by UCOBO in accordance with this Privacy Policy and as otherwise permitted by applicable law. You may withdraw your consent at any time, subject to legal or contractual restrictions and on reasonable notice to UCOBO, but then you might not be able to proceed with your intended interactionsor transactions with UCOBO or otherwise receive the full benefit of UCOBO’s products and services.

2. Personal Information

In this Privacy Policy, “personal information” means information about an identifiable individual (e.g. an individual’s name, postal address, telephone number and email address) but does not include (to the extent permitted by law) information that is publicly available in a telephone directory or that is business contact information that enables an individual to be contacted at a place of business.

3. Information That UCOBO Collects

  • Information You Provide

    You may be asked to voluntarily give your personal information to UCOBO when you interact with UCOBO, including when you apply for an account, subscribe to a newsletter, request information or use a product or service (including the mobile app) provided by UCOBO. In those circumstances, you can choose not to provide certain requested personal information, but then you might not be able to proceed with your intended interaction or transaction with UCOBO or otherwise receive the full benefit of the desired product or service.

    If you give UCOBO the personal information of another individual in connection with your use of UCOBO’s products or services, then you are solely responsible for complying with all applicable laws, including obtaining the individual’s valid consent, regarding your collection and disclosure of the personal information to UCOBO and to UCOBO’s use, disclosure and retention of the personal information.

  • Automated Collection

    UCOBO may automatically collect certain information regarding your use of UCOBO’s website or mobile app, such as the dates and times that you use the website or mobile app, the browsers, operating systems, software and devices that you use to use the website or mobile app and details of your use of the website or mobile app.

    If you install UCOBO’s mobile app on your mobile device, then the settings of the device may permit the automatic transmission to UCOBO of diagnostic information and other information (including location data, discussed in section 3.(c)) regarding your mobile device and your use of the mobile app.

    UCOBO’s websites, mobile app, email messages and advertisements may use technologies(e.g. cookies, web beacons, tokens, pixels or tags) to collect information that assists UCOBO to improve UCOBO’s products, services, customer communications and advertising and to prevent fraud. UCOBO may use information collected through technological means to recognize you as a user of UCOBO’s mobile app, to facilitate and improve your use of UCOBO’s mobile app, to confirm that messages have been delivered to and opened by you and to provide you with targeted advertisements.

    You may choose to decline or disable cookies if your web browser or device permits, but doing so may affect your ability to access or use certain features of the website or mobile app.

    Some of the information automatically collected by technological means is non-personal information (because the information does not identify you), and UCOBO will deal with that non-personal information as explained below in this Privacy Policy unless applicable law requires otherwise.

  • Location Data

    UCOBO’s mobile app installed on a mobile device may be configured to automatically collect precise location data, including the real-time geographic location of the mobile device, using various available technologies (including GPS, Bluetooth, Wi-Fi access points and cell tower locations), and transmit that data (either in real time or later when the device has required connectivity) to UCOBO for use and disclosure as set out in this Privacy Policy.

    If you do not want a UCOBO mobile app to access your device’s location data, then you might be able to use your devices settings to disable the transmission of location data but doing so might be a breach of the applicable terms of service or other agreements with UCOBO and you might not be able to proceed with your intended interactions with UCOBO or otherwise receive the full benefit of UCOBO’s products and services.

    If the location data includes personal information, then UCOBO will treat the location data as personal information in accordance with this Privacy Policy. If the location data does not include personal information or is depersonalized by UCOBO, then UCOBO will treat the location data as non-personal information in accordance with this Privacy Policy.

  • Information Regarding Referred Transactions

    If UCOBO refers you to an independent business (e.g. a tax advisor or insurance provider) for a proposed product or service (e.g. tax advisory services or insurance), then UCOBO may collect information from that independent business regarding the transaction.

4. How UCOBO Uses Personal Information

  • General

    UCOBO uses your personal information collected by UCOBO for purposes relating to or arising from your relationship and transactions with UCOBO and as otherwise set out in this Privacy Policy or permitted by applicable law, including

    • to administer your relationship with UCOBO, including to create and manage a confidential profile about you and your contract(s) with us,and to contact and correspond with you regarding those matters
    • to provide products and services to you
    • to facilitate your interactions and transactions with UCOBO, including to process your applications, requests, orders and transactions and send notifications to you
    • to process and respond to your inquiries, requests and other communications
    • to provide you with information (including by email and other electronic messages) regarding UCOBO and its products and services and related products and services offered by other businesses, to the extent permitted by applicable law
    • to administer and facilitate your participation in contests and promotions related to UCOBO
    • to improve UCOBO’s products and services and to develop new products and services
    • to protect and enforce UCOBO’s legal rights, interests and remedies and to protect the businesses, operations and customers of UCOBO or other persons; and
    • to enable and assist UCOBO to collect, use, disclose and retain your personal information in accordance with this Privacy Policy

    UCOBO may combine your personal information collected by UCOBO through various sources (including information collected through its mobile app).

  • UCOBO

    UCOBO may develop, maintain and share a confidential profile for you for to provide information, products and services to you, to facilitate your dealings with UCOBO and as otherwise set out in this Privacy Policy.
  • Information Regarding Referred Transactions

    If UCOBO refers you to an independent business (e.g. a tax advisor or insurance provider) for a proposed product or service (e.g. tax advisory services or insurance), then UCOBO may collect information from that independent business regarding the transaction to administer your relationship with UCOBO, including to create and manage a confidential profile about you, and to provide products and services to you, as set out in this Privacy Policy.

How UCOBO Discloses Personal Information

  • General

    UCOBO discloses your personal information for purposes relating to or arising from your relationship and transactions with UCOBO and as otherwise set out in this Privacy Policy or permitted by applicable law.

  • Specific Consents

    UCOBO may disclose your personal information in accordance with express or implied consents that you give during your interactions and transactions with UCOBO.

  • Referred Transactions

    If UCOBO refers you to an independent business (e.g. a tax advisor or insurance provider) for a proposed product or service (e.g. tax advisory services or insurance), then UCOBO may disclosure your personal information to the independent business to facilitate the proposed transaction, and in those circumstances UCOBO has no control over, or responsibility or liability for, the use, disclosure or retention of your personal information by the independent business, and the use, disclosure and retention of the disclosed information by the independent business is not subject to this Privacy Policy.

  • Suppliers and Service Providers

    UCOBO may disclose your personal information to UCOBO’s suppliers and service providers (including mobile app developers) to assist UCOBO in the provision of information, products and services to you, to provide services to UCOBO, to assist UCOBO to use your personal information as set out in this Privacy Policy and as otherwise permitted by applicable law.

  • Law Enforcement/Legal Disclosures

    UCOBO may disclose your personal information as required or authorized by applicable law, including to comply with a subpoena, warrant or court or arbitral order or litigation disclosure obligation. UCOBO may disclose your personal information to law enforcement agencies or other independent organizations if UCOBO reasonably believes the disclosure is necessary or appropriate in connection with national security, law enforcement or other issues of public importance, or if UCOBO reasonably believes the disclosure is necessary or appropriate to protect and enforce the UCOBO’s legal rights, interests and remedies or to protect the rights, interests,business, operationsor customers of UCOBO or other persons (including to detect and prevent fraud and other illegal activities, enforce any of the terms of use, terms of service or other agreements that govern access to or use of any of the UCOBO’s products or services). UCOBO has no control over, or responsibility or liability for, the use, disclosure or retention of your personal information by the agencies, independent organizations or other persons to whom UCOBO discloses the information in the foregoing circumstances, and the use, disclosure and retention of the disclosed information by those agencies, independent organizations or other persons is not subject to this Privacy Policy.

  • Business Transactions

    UCOBO may disclose your personal information in connection with a proposed or actual business transaction in which UCOBO is involved (e.g.a corporate amalgamation, reorganization, merger or acquisition, or the sale or transfer of some or all of UCOBO’s business or assets), but UCOBO will require the information recipient to agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy and applicable law.

6.Location of Personal Information

UCOBO and its service providers may process, store and use your personal information at facilities in various countries, including Canada, the United States of America and one or more countries in Europe or Asia. The personal information protection laws of those other countries might be different from the laws of the jurisdiction in which you reside, and might permit courts, government, law enforcement agencies, regulatory agencies and security authorities to access your personal information without notice. By providing your personal information to UCOBO, you consent to the transfer of the personal information to facilities located in other countries and the processing and storage of the personal information at those facilities.

7. Retention of Personal Information

UCOBO retains your personal information for the period reasonably necessary for the purposes set out or referenced in this Privacy Policy and to comply with UCOBO’s legal obligations or enforce or protect UCOBO’s legal rights, or a longer period required or permitted by applicable law. UCOBO will delete or dispose of your personal information, or depersonalize the information, when UCOBO is no longer reasonably required to retain the personal information for the purposes set out or referenced in this Privacy Policy.

8. Protection of Personal Information

UCOBO uses reasonable safeguards – including administrative, physical and technical security and safeguarding measures– appropriate to the sensitivity of the personal information in UCOBO’s possession or under UCOBO’s control to help protect the information from unauthorized access, collection, use, disclosure, deletion or similar risks. Nevertheless, security risks cannot be eliminated and UCOBO cannot guarantee that your personal information will not be accessed, used, disclosed or deleted in ways not otherwise described in this Privacy Policy.

9. Accuracy and Access to Personal Information

UCOBO will rely on you to ensure that the personal information that you provide to UCOBO is as accurate, complete and up to date as necessary for the purposes for which UCOBO uses the personal information. You will promptly notify UCOBO of any changes to the personal information that you provide to UCOBO using the procedures made available for that purpose by UCOBO or by contacting UCOBO’s Privacy Officer by email to info@ucobo.com, by phone at (954) 704-6010 or by mail to Privacy Officer, UCOBO, 50 Carroll St, Toronto, ON M4M 3G3 Canada.

You may reasonably request access to your personal information collected by UCOBO and information about UCOBO’s use, disclosure and retention of that personal information by submitting a written request to UCOBO’s Privacy Officer using the contact information noted above and at the end of this Privacy Policy. Subject to applicable exceptions and limitations prescribed by applicable law, you will be given reasonable access to your personal information and you will be entitled to verify the accuracy and completeness of your personal information and to have the information revised as appropriate. You may be required to pay a reasonable fee for access to your personal information. UCOBO may decline to process a request that is unreasonably repetitive, frivolous, vexatious or impracticable, that infringes or jeopardizes the privacy of other persons, or for other reasons permitted by applicable law.

10. Non-Personal Information

UCOBO creates and collects non-personal information (information that is not about an identifiable individual), including personal information that has been aggregated or otherwise depersonalized so that the information no longer relates to an identifiable individual. UCOBO may use, disclose, transfer and retain non-personal information for any purpose and in any manner whatsoever.If non-personal information is combined with personal information, then UCOBO will treat the combined non-personal information as personal information for the purposes of this Privacy Policy for as long as the non-personal information is combined with personal information.

11. Other Websites and Businesses

UCOBO’s website and correspondence (including emails, messages and social media posts) may include advertisements for products and services offered by independent businesses or links to websites operated by independent businesses. UCOBO has no responsibility or liability for, or control over, those other websites, online services or businesses, their products or services, or their collection, use, disclosure or retention of your personal information. This Privacy Policy does not apply to the collection, use, disclosure and retention of your personal information by those websites, online services and independent businesses. If you have questions about how those websites, online services or independent businesses collect, use, disclose or retain personal information, please contact the owner or operator of the website, service or business.

12. Other Matters

  • App Store Operators:

    If you wish to obtain a copy of UCOBO’s mobile app from an online app store operated by an unaffiliated third party (such as Apple and Google), then you will be required to disclose your personal information to the app store operator in order to download a copy of the mobile app. UCOBO has no control over, or responsibility or liability for, the collection, use, disclosure,retention and deletion of your personal information by any app store operator. Each app store operator’s use, disclosure, retention and deletion of your personal information are governed by the app store operator’s own privacy policy (not this Privacy Policy).

  • Disclaimers, Liability Exclusions/Limitations and Disputes:

    The agreements (including any application formor terms of service or use) that you accept when you apply, register for, order or use UCOBO’s products or services contain important provisions, including provisions disclaiming, limiting or excluding the liability of UCOBO and other persons (including service providers) and provisions determining the applicable law and jurisdiction for the resolution of disputes. To the extent permitted by applicable law, each of those provisions applies to any dispute that may arise in relation to this Privacy Policy or UCOBO’s collection, use, disclosure and retention of your personal information, and are of the same force and effect as if they were reproduced directly in this Privacy Policy. Nothing in this Privacy Policy amends any of those other agreements.

  • Changes to this Policy:

    UCOBO may change this Privacy Policy as it applies to UCOBO from time to time by posting a new version of this Privacy Policy on UCOBO’s website. UCOBO’s collection, use, disclosure and retention of your personal information will be governed by the version of this Privacy Policy in effect at that time. Your continued dealings with UCOBO after any change to this Privacy Policy will signify your consent to the collection, use, disclosure and retention of your personal information as set out in the changed Privacy Policy. Accordingly, you should check the “Last Updated” date of this Privacy Policy (at the top of this Privacy Policy) and review any changes since the last version.

  • English Language:

    You and UCOBO have each expressly requested and required that this Privacy Policy and all other related documents be drawn up in the English language. Les parties conviennent etexigent expressement quecette Politiquede Confidentialité ettousles documents quis’y rapportent soient rédigés en anglais.

  • Contacting UCOBO’s Chief Privacy Officer:

    If you have any comments or questions about this Privacy Policy or how UCOBO deals with your personal information, please contact UCOBO’s Privacy Officer by email to info@UCOBO.COM, by phone at (954) 704-6010 or by mail to Privacy 50 Carroll St, Toronto, ON M4M 3G3 Canada.

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