Privacy Policy

Effective as of May 1, 2022

Welcome to Universe Software, Inc. (“Universe”, “we”, “us”, “our”) Privacy Policy.

Universe is the parent company of a number of portfolio software companies (each a “Universe Company”). As at the date of this Privacy Policy, the Universe Companies are set out here. Together, we are the “Universe Group”.

This Privacy Policy describes Universe’s privacy practices and how Universe handles personal information that we collect through: 

  • our digital properties that link to this Privacy Policy, including our website (the “Website”);
  • social media;
  • our marketing activities; 
  • Universe Companies; and 
  • other activities described in this Privacy Policy.

We refer to the above, collectively, as the “Service”.  

This Privacy Policy does not apply to: 

  • information that the Universe Group process on behalf of its enterprise customers (meaning, not individual consumers) while providing any Universe Group platform/services to them. Our use of such information, if any, would be governed by our agreements with those enterprise customers. If you have questions regarding personal information that we process on behalf of an enterprise customer, please direct your questions to that enterprise customer; and
  • the privacy practices of Universe Companies. For information on the privacy practices of each Universe Company, please see the privacy policy of the relevant Universe Company here

Universe may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.

You can print this Privacy Policy by selecting the “Print” button in your web browser. 

Index

Personal information we collect

How we use your personal information

How we share your personal information

Your choices

Other sites and services 

Security

International data transfer

Children

Changes to this Privacy Policy

How to contact us

Information for California residents / Your California privacy rights

Notice to European users  

Personal information we collect

Information you provide to us.  Personal information you may provide to us through the Service or otherwise includes:

    Category of personal information collected Examples of what this means
    Biographical Data
  • Your full name.
  • Your email address.
  • Online survey data.
  • Online app store subscription data.
  • Other information you include in your profile.
  • Demographic Data
  • Your city, state, country of residence, and postal code.
  • Your age.
  • Geolocation Data
  • Historical geolocation information.
  • Profile Data
  • Such as the username that you may set to establish an online account.
  • Communications Data
  • Content of emails, chats and other communications based on our exchanges such as when you contact us with questions or feedback.
  • Transactional Data
  • Such as information relating to or needed to complete your orders on or through the Service (including your order numbers and transactional history).
  • User-generated Content Data
  • Profile pictures, photos, images, music, videos, comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata.
  • Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data
  • Health Data
  • Health-related information.
  • Financial Data
  • Card type, billing address.
  • Payment card information.
  • Social Media Data
  • Log-in details
  • Likes
  • Friends
  • Photos
  • Videos
  • Marketing Data
  • Your preferences relating to our promotional emails, and your communication preferences.
  • Technical Data
  • Internet protocol (IP) address, browser type and version, time-zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites or use our services.
  • Pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our marketing emails or clicked links within them
  • Other Data
  • Data not specifically listed here but which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
  • How we use your personal information

    We may use your personal information for the following purposes or as otherwise described at the time of collection: 

    Service delivery. We may use your personal information to:

    • provide, operate and improve the Service and our business;
    • establish and maintain your user profile on the Service;
    • communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
    • understand your needs and interests, and personalize your experience with the Service and our communications; and
    • provide support for the Service, and respond to your requests, questions and feedback.

    Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business.  

    Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

    • Direct marketing. We may send you Universe Group-related or other direct marketing communications as permitted by law.  You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

    Compliance and protection.We may use your personal information to:

    • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
    • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); 
    • audit our internal processes for compliance with legal and contractual requirements or our internal policies; 
    • enforce the terms and conditions that govern the Service; and 
    • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft. 

    With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.  

    To create anonymous, aggregated and/or de-identified data.  may create anonymous, aggregated and/or de-identified data from your personal information and other individuals whose personal information we collect.  We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data identifiable to you.  We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.  

    Retention.We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.  When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

    How we share your personal information

    We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.  

    Affiliates.  Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

    Service providers.  Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, and website analytics). 

    Third parties designated by you. We may share your personal data with third parties where you have instructed us or provided your consent to do so. For example, we may share your personal information with third-party advertisers with whom we are collaborating to offer you additional services such as sweepstakes, raffles and promotions. We will share personal information that is needed for these other companies to provide the services that you have requested. 

    Business and marketing partners. Third parties with whom we collaborate on joint activities (such as co-sponsors of contests and promotions), with whom we have entered into joint marketing relationships or other joint ventures, or who we think may offer you products or services that you may enjoy.

    Professional advisors.  Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

    Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above. 

    Business transferees.  Acquirers and other relevant participants in business transactions (or negotiations and diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Universe Group or our affiliates (including, in connection with a bankruptcy or similar proceedings).  

    Other users and the public.  Your profile and other user-generated content (except for messages) may be visible to other users of the Service and the public. For example, other users of the Service or the public may have access to your information if you chose to make your profile or other personal information available to them through the Service, such as when you provide comments, reviews, survey responses, or share other content.   This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of information.

    We make commercially reasonable efforts to verify that the parties with whom we share personal information provide a level of protection of personal information consistent with the practices described in this Privacy Policy, except that all such parties described above other than service providers and affiliates may, to the extent permitted by law, use personal information as described in their own privacy policies.  

    Your choices 

    You have the following choices with respect to your personal information.

    Opt-out of marketing communications.  You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us.  Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.  

    Do Not Track.  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

    Declining to provide information. We need to collect personal information to provide certain services.  If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

    Delete your content or close your account. You can choose to delete certain content through your account.  If you wish to request to close your account, please contact us.

    Security 

    We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect.  However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

    International data transfer

    We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

    Children

    The Service is not intended for use by children under 16 years of age. If we learn that we have collected personal information through the Service from a child under 16 without the consent of the child’s parent or guardian as required by law, we will delete it. We encourage parents or guardians with concerns to contact us.

    Changes to this Privacy Policy 

    We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the Service.  Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

    How to contact us

    Information for California residents / Your California privacy rights 

    Scope.  This section applies only to California residents.  It describes how we collect, use, and share Personal Information of California residents in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) and their rights with respect to that Personal Information.  For purposes of this section, the term “Personal Information” has the meaning given in the CCPA but does not include information that the CCPA exempts.  In some cases, we may provide a different privacy notice to certain categories of California residents, such as job applicants, in which case that notice will apply instead of this section.

    Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law. 

    • Information.  You can request the following information about how we have collected and used your Personal Information during the past 12 months:
      • The categories of Personal Information that we have collected.
      • The categories of sources from which we collected Personal Information.
      • The business or commercial purpose for collecting and/or selling Personal Information.
      • The categories of third parties with whom we share Personal Information.
      • 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.
    • Access.  You can request a copy of the Personal Information that we have collected about you during the past 12 months. 
    • Deletion. You can ask us to delete the Personal Information that we have collected from you.
    • Opt-out of sales.  You can opt-out any sale of your Personal Information. In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
    • Opt-in.  While the Service is not designed for individuals under the age of 16, if we know that you are 13-15 years of age, we will ask for your affirmative authorization to sell your Personal Information before we do so.
    • Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.  

    Right to information, access and deletion. You may submit requests to exercise your right to information, access or deletion through this webform, calling us toll free at +1 (844) 521-2525, or via email to Privacy@universesoftware.com.  

    Notice of right to opt-out of the “sale” of your Personal Information.  Like many companies, we use services that help deliver interest-based ads to you.  Our use of some of these services may be classified under California law as a “sale” of your Personal Information to the advertising partners that provide the services because they collect information from our users (e.g., device data and online activity data) to help them serve ads more likely to interest you.  You can request to opt-out out of this “sale” of your personal information here: Do Not Sell My Personal Information. 

    We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

    We will need to verify your identity to process your information, access and deletion requests and reserve the right to confirm your California residency.  To verify your identity, we may require government identification, a declaration under penalty of perjury or other information.  Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465.  If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with confirmation that you have given the authorized agent permission to submit the request. 

    Personal information that we collect, use and disclose. The chart below summarizes the Personal Information we collect by reference to the categories of Personal Information specified in the CCPA, and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.

    Statutory category of personal information (PI) (Cal. Civ. Code § 1798.140) PI we collect in this category (See Personal information we collect above for description) Source of PI Business/commercial purpose for collection Categories of third parties to whom we “disclose” PI for a business purpose Categories of third parties to whom we “sell” PI
    Identifiers Biographical data
    Demographic data
    Profile data
    Communications data
    Transactional data
    User-generated content data
    Financial data
    Social Media data
    Marketing data
    Other data
    Data about others
    You
    Third-party sources
    Service delivery
    Research & development
    Marketing & advertising
    Compliance & protection
    Affiliates
    Service providers
    Third parties designated by you
    Professional advisors
    Authorities and others
    Business transferees
    Business and marketing partners
    Other users and the public
    Advertising partners (to facilitate online advertising)
    Business and marketing partners
    California Customer Records (as defined in California Civil Code section 1798.80) Biographical data
    Transactional data
    Financial data
    User-generated content data
    Data about others
    You
    Third-party sources
    Service delivery
    Research & development
    Marketing & advertising
    Compliance & protection
    Affiliates
    Service providers
    Payment processors
    Advertising partners
    Third parties designated by you
    Professional advisors
    Authorities and others
    Business transferees
    Business and marketing partners
    Other users and the public
    Advertising partners (to facilitate online advertising)
    Business and marketing partners
    Commercial Information Transactional data
    Financial data
    Marketing data
    Technical data
    You
    Third-party sources
    Automatic collection
    Service delivery
    Research & development
    Marketing & advertising
    Compliance & protection
    Affiliates
    Service providers
    Payment processors
    Advertising partners
    Third parties designated by you
    Professional advisors
    Authorities and others
    Business transferees
    Business and marketing partners
    Advertising partners (to facilitate online advertising)
    Business and marketing partners
    Financial Information Transactional data
    Financial data
    You
    Third-party sources
    Service delivery
    Research & development
    Marketing & advertising
    Compliance & protection
    Affiliates
    Payment processors
    Professional advisors
    Authorities and others
    Business transferees
    None
    Online Identifiers Biographical data
    Profile data
    Social media data
    Technical data
    You
    Third-party sources
    Automatic collection
    Service delivery
    Research & development
    Marketing & advertising
    Compliance & protection
    Affiliates
    Service providers
    Payment processors
    Advertising partners
    Third parties designated by you
    Professional advisors
    Authorities and others
    Business transferees
    Business and marketing partners
    Other users and the public
    Advertising partners (to facilitate online advertising)
    Business and marketing partners
    Internet or Network Information Marketing data
    Technical data
    You
    Automatic collection
    Service delivery
    Research & development
    Marketing & advertising
    Compliance & protection
    Affiliates
    Service providers
    Payment processors
    Advertising partners
    Third parties designated by you
    Professional advisors
    Authorities and others
    Business transferees
    Business and marketing partners
    Other users and the public
    Advertising partners (to facilitate online advertising)
    Business and marketing partners
    Inferences May be derived from your:
    Biographical data
    Demographic data
    Communications data
    Profile data
    Transactional data
    User-generated content data
    Financial data
    Health data
    Social media data
    Marketing data
    Technical data
    Other data
    N/A Service delivery
    Research & development
    Marketing & advertising
    Compliance & protection
    Affiliates
    Service providers
    Advertising partners
    Authorities and others
    Business transferees
    Business and marketing partners
    Advertising partners (to facilitate online advertising)
    Business and marketing partners
    Protected Classification Characteristics We do not intentionally collect this information but it may be revealed in biographical data or other information we collect N/A N/A N/A No
    Sensory Information Communications data
    User-generated content data
    You Service delivery
    Research & development
    Marketing & advertising
    Compliance & protection
    Affiliates
    Service providers
    Advertising partners
    Third parties designated by you
    Authorities and others
    Business transferees
    Business and marketing partners
    Other users and the public
    No

    Glossary

    Statutory category Definition (categories may overlap)
    Biometric Information An individual’s physiological, biological or behavioral characteristics, including an individual’s deoxyribonucleic acid (DNA), that can be used, singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
    Commercial Information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
    Education Information Personal information from an educational record, which could include: a student’s name, the names of the student’s parent or other family members, the address of a student or student’s family, a student’s personal identifier (e.g., SSN, student number), other indirect identifiers of the student (e.g., date of birth, place of birth, mother’s maiden name), other information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty, or information requested by a person who the educational agency or institution reasonably believes knows the identity of the student to whom the education record relates.
    Financial Information Bank account number, debit or credit card numbers, insurance policy number, and other financial information.
    Geolocation Data Precise location, e.g., derived from GPS coordinates or telemetry data
    Identifiers Real name, alias, postal address, unique personal identifier, customer number, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
    Inferences The derivation of information, data, assumptions, or conclusions from any other category of Personal Information to create a profile about a person reflecting the person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
    Internet or Network Information Browsing history, search history, and information regarding a person’s interaction with an Internet website, application, or advertisement.
    Medical Information Personal information about an individual’s health or healthcare, including health insurance information.
    Online Identifiers An online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers (i.e., the identification of a person or a device to a degree of certainty of more probable than not) that can be used to identify a particular person or device.
    Physical Description An individual’s physical characteristics or description (e.g., hair color, eye color, height, weight).
    Professional or Employment Information This term is not defined in the CCPA, but likely includes any information relating to a person's current, past or prospective employment or professional experience (e.g., job history, performance evaluations).
    Protected Classification Characteristics Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
    Sensory Information Audio, electronic, visual, thermal, olfactory, or similar information.

    Notice to European users

    The information provided in this “Notice to European users” section applies only to individuals in the United Kingdom, Switzerland, and the European Economic Area (“EEA”) (collectively, referred to as “Europe”).

    Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation such as the General Data Protection Regulation 2016/679 (“EU GDPR”) and the EU GDPR as it is incorporated into United Kingdom law by the European Union (Withdrawal) Act 2018 (“UK GDPR”) (together, the “GDPR”). 

    Controller. Universe is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation.  

    Legal bases for processing. 

    In respect of each of the purposes for which we use your personal information, most commonly, we will rely on one of the following legal bases:

    • Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
    • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each purpose we use your personal information for is set out in the table below.
    • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
    • Where we have your specific consent to carry out the processing for the purpose in question (“Consent”). 

    We have set out below, in a table format, the legal bases we rely on in respect of the relevant purposes for which we use your personal information.

    Purpose (Details regarding each processing purpose listed below are provided in the section above titled “How we use your personal information”.) Category(ies) of personal information involved Our legal basis for this use of personal information
    Service delivery Biographical data
    Demographic data
    Profile data
    Geolocation data
    Communications data
    Transactional data
    User-generated content data
    Financial data
    Social Media data
    Marketing data
    Technical data
    Other data
    Contractual Necessity
    Legitimate Interests
    Compliance with Law
    Consent
    Research and development Biographical data
    Demographic data
    Profile data
    Communications data
    Transactional data
    User-generated content data
    Financial data
    Social Media data
    Marketing data
    Technical data
    Other data
    Legitimate Interests
    Consent
    Compliance and protection Biographical data
    Demographic data
    Profile data
    Communications data
    Transactional data
    Health data
    User-generated content data
    Financial data
    Social Media data
    Marketing data
    Technical data
    Other data
    Legitimate Interests
    Compliance with Law
    To create anonymous, aggregated and/or de-identified data Biographical data
    Demographic data
    Profile data
    Communications data
    Transactional data
    User-generated content data
    Financial data
    Social Media data
    Marketing data
    Technical data
    Other data
    Legitimate Interests
    Consent
    With your consent Biographical data
    Demographic data
    Profile data
    Communications data
    Transactional data
    User-generated content data
    Financial data
    Social Media data
    Marketing data
    Technical data
    Other data
    Consent
    Retention Biographical data
    Demographic data
    Profile data
    Communications data
    Transactional data
    User-generated content data
    Financial data
    Social Media data
    Marketing data
    Technical data
    Other data
    Contractual Necessity
    Legitimate Interests
    Compliance with Law
    Consent

    Use for new purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it.  If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis. 

    Sensitive personal information. We may also collect “Special categories of personal data” (as defined by European data protection legislation) about you where you provide it to us, or a Universe Company, with your consent. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

    If you provide us with any sensitive personal information to us when you use the services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our services.

    Your rights. European data protection legislation gives you certain rights regarding your personal information.  If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

    • Request access to your personal information. This enables you to receive a copy of the personal information we hold about you.
    • Request correction of your personal information. This enables you to have any incomplete or inaccurate personal information we hold about you corrected.
    • Request erasure of your personal information. This enables you to ask us to delete or remove personal information. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). 
    • Object to processing of your personal information. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. 
    • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
    • Request the transfer of your personal information.  We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 
    • Withdraw consent. This right only exists where we are relying on consent to process your personal information (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of our Services. We will advise you if this is the case at the time you withdraw your consent.

    You may submit these requests by email to privacy@univeresesoftware.com or our postal address provided above.  To help us process your request as efficiently as possible, please include “Data Subject Request” in the subject line of any email you send us to exercise any such rights. Typically, you will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.

    We may request specific information from you to help us confirm your identity and process your request.  Applicable law may require or permit us to decline your request.  If we decline your request, we will tell you why, subject to legal restrictions.  If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction.  

    • For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en 
    • For users in the UK – the contact information for the UK data protection regulator is below:

    The Information Commissioner’s Office  

    Water Lane, Wycliffe House

    Wilmslow - Cheshire SK9 5AF

    Tel. +44 303 123 1113

    Website: https://ico.org.uk/make-a-complaint/ 

    Cross-border data transfer. We are based in the United States. We may transfer personal information outside of the EEA and/or the United Kingdom (“UK”) to third countries (including the United States) that may not provide the same standard of data protection as the EEA or UK provides.

    Where such data transfers occur within the Universe Group, we have implemented an intra-group agreement which contains appropriate safeguards to allow for such transfers.

    Where personal information is transferred from the EEA and/or UK to a third party, we implement at least one of the following mechanisms: