Last updated on 13 June 2022
This website, https://upstart-entrepreneur.com (referred to as “Site” or “Website”) is operated by Upstart Entrepreneur Inc, and includes all sub-domains of the website.
Throughout the site, the terms “we”, “us” and “our” refer to Upstart Entrepreneur Inc (hereunto known as Upstart Entrepreneur).
We have a robust and effective data protection program in place which complies with existing laws and abides by the data protection guidelines therein, as well as ensuring that we comply with the demands relating to GDPR, POPI, CalPOPPA and PCI (as relevant) in the countries we operate in.
When accessing the Website, the Company will learn certain information about you, both automatically and through voluntary actions you may take, during your visit. This policy applies to information we collect on the Website and in email, text, or other electronic communications between you and us and/or the Website.
Section 1: Our Commitment
We are strongly committed to protecting your privacy and complying with your choices. Both personal and non-personal collected is safeguarded according to the highest privacy and data protection standards adopted worldwide.
As such, we are committed to the following:
- Your personal information will not be shared, rented, or sold to any third party. Shared information will only include, where applicable, minimal information required, and only be shared with a 3rd party where such 3rd party is providing an outsourced or contracted service to us, such as, but not limited to, software plugins, addons and/or integrations that require certain information in order to ensure we are able to provide you with world-class service we offer on our Website and ensure our legal compliances (e.g. financial reporting, deliveries, affiliate programs, marketing campaigns, etc).
- We will process your personal information in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, to the best of our ability, using appropriately capable technologies and organizational measures, and commit to ensuring that such security measures are regularly updated as required by law.
- We will give you the possibility to check the information you have shared with us by providing “opt-out” functionality. You may delete your profile at any time, with all personal information, and the only information we are required by law to keep will be held for the periods as defined by laws governing Upstart Entrepreneur.
- We will process any personal information you provide in a lawful, fair, and transparent manner.
- We will only collect your personal information for specified, explicit and legitimate purposes, and it will not be further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific, marketing or historical research purposes or statistical and legal purposes shall not be considered to be incompatible with our initial purposes.
- All information we collect will be adequate, relevant, and limited to what is necessary in relation to the services we provide for which it is processed.
- We will always strive to keep information in a form which permits identification of data for no longer than is necessary for the purposes for which the personal data is processed. Personal information may be stored for longer periods insofar as the personal information will be processed solely for archiving purposes in the public interest, scientific, marketing or historical research purposes or for legal or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR, POPI and PCI acts in the relevant countries in order to safeguard your rights and freedoms.
- We will ensure to the best of our ability that all online transactions on our Website follow the latest security measures and technologies, and that Secure Sockets Layer (SSL) technology, one of the safest methods of passing information over the Internet, will be employed when you place online orders or transmit sensitive information.
Section 2: Personal Information We Collect
When you access the Website, we will learn certain information about you during your visit.
Information You Provide To Us. The Website provides various places for users to provide information. We collect information that users provide by filling out forms on the Website, communicating with us via contact forms, responding to surveys, search queries on our search feature, providing comments or other feedback, and providing information when ordering a product or service via the Website. We refer to this information as "Personal Details"
Additionally, when you make a purchase or attempt to make a purchase through the Website, we collect certain information from you, including your name, billing address, shipping address, payment information, email address, and phone number. We refer to this information as “Order Information.”
We use information you provide for us to deliver the requested product and/or service, to improve our overall performance, and to provide you with offers, promotions, and information.
Information We Collect Through Automatic Data Collection Technology. As you navigate through our Website, we may use automatic data collection technologies, including but not limited to Google Analytics, to collect certain information about your equipment, browsing actions, and patterns. This will generally include information about your location, your traffic pattern through our website, and any communications between your computer and our Website. Among other things, we will collect data about the type of computer you use, your Internet connection, your IP address, your operating system, and your browser type.
Additionally, as you browse the Website, we collect information about the individual web pages or products that you view, what websites or search terms refer you to the Website, and information about how you interact with the Website. We refer to this automatically collected information as “Device Information”.
We collect Device Information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the Website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.
The information we collect automatically is used for statistical data and will not include personal information. We use this data to improve our Website and our service offerings. To the extent that you voluntarily provide personal information to us, our systems will associate the automatically collected information with your personal information.
Similar to other commercial websites, our website utilizes a standard technology called “cookies” and server logs to collect information about how our site is used.
Information gathered through cookies and server logs may include the date and time of visits, the pages viewed, time spent at our site, and the websites visited just before and just after our own, as well as your IP address.
A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites.
We reserve the right to use technological equivalents of cookies, including social media pixels. These pixels allow social media sites to track visitors to outside websites so as to tailor advertising messages users see while visiting that social media website. The Company reserves the right to use these pixels in compliance with the policies of the various social media sites.
Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers.
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 (behavioural) 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.
Section 5: How And Why We Collect Information
We collect your information in order to record and support your participation in the activities you select.
If you register to download a book or resources, sign up for our newsletter, curse, or masterclass, and/or purchase a product or Service from us, we collect your information.
We use this information to track your preferences and to keep you informed about the products and services you have selected to receive and any related products and/or services.
As a visitor to this Website, you can engage in most activities without providing any personal information. It is only when you seek to download/access resources and Services and/or register for Services that you are required to provide information.
If you are outside the European Union and opt to receive any free resources, participate in any free training programs, register for a webinar, register for a live event, register for a seminar, or purchase any Services sold by us on this Website, we will automatically enrol you to receive our free email newsletter.
If you are in the European Union and opt to receive any free resources, participate in any free training programs, register for a webinar, register for a live event, register for a seminar, or purchase any Services sold by the Company on this Website, we will only enrol you to receive our free email newsletter if you affirmatively consent to it.
If you do not wish to receive the relevant newsletter or emails, you can unsubscribe anytime. We include an “unsubscribe” link at the bottom of every email we send. If you ever have trouble unsubscribing, you can send an email to email@example.com requesting to unsubscribe from future emails.
Section 6: How Do We Use Your Personal Information
We use your Personal Information to:
- Provide you with information relevant to your actions or preferences on the Website.
- Provide you with offers and/or subscriptions to current and other products and Services.
- Provide you with information about any of your subscriptions, account information and Services.
- Fulfil any contract between you and us.
- Administering our business activities and legal compliance.
- Provide proper customer services and support to you.
- Fulfil any orders placed, directly or through the Site, including processing your payment information, arranging delivery/shipping, providing you with order confirmations, invoices, payment receipts, and/or refunds.
- Communicate with you via email, messages, online video/voice calls, social media and/or phone.
- Screen any orders for potential risk or fraud.
- Subject to your subscription preferences, provide you with information or advertising relating to our products or services.
We use your Device Information to:
- Help us screen for potential risk and fraud (in particular, your IP address).
- Improve and optimize our Site (for example, by generating analytics about how customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns.
- Provide additional customer experience and services, subject to the options you have permitted or data your have provided when signing up or activated/submitted after, such as but not limited to, location.
From time-to-time, we may use the information you provide to us to make you offers to purchase products and services provided by third parties in exchange for a commission to be paid to us by such third parties. Should you opt to take part in such promotions, the third parties will receive your information.
From time-to-time, we may use the information you provide to us to display advertisements to you that are tailored to your personal characteristics, interests, and activities.
Section 7: Where Do We Share Your Personal Information
As a general rule, we do not sell, rent, lease or otherwise transfer any information collected whether automatically or through your voluntary action.
We may disclose your personal information to our subsidiaries, affiliates, and service providers for the purpose of providing our services to you.
We may disclose your personal information to a third party, including a lawyer or collection agency, when necessary to enforce our terms of service or any other agreement between you and the Company.
We may provide your information to any successor in interest in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s asserts and/or business.
We share certain aspects of your Personal Information with third parties to help us use provide you the services and features you have accessed/joined the Website for, as well as for backend management.
- We use Kartra to power our funnels, website and membership areas.
- We use Google Analytics to help us understand how our customers use our Website.
- We use Kartra to provide our members with an Affiliate program to earn commission and/or points.
- We use Kartra for our contact management, member management, email marketing and communications.
- We use Instagram, LinkedIn, Facebook, Twitter, Google to advertise to our members on these social platforms.
- We use Calendly to manage our calendars and any bookings and appointments you make on the Site.
- We use Zoom to manage, send invites, and host video meetings / webinars with members and/or guests of our Website.
- We use QuickBooks to manage our financials and provide financial reporting for management, legal and tax purposes.
- We use Stripe and PayPal to process any online transactions on our Website.
- We use Dropbox for secure document storage.
- We use domain hosting on our own dedicated shared server to host emails, etc.
Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights or when we in good faith believe that the law requires it or for protection of our legal rights.
It is important to note that only the minimum required information will ever be shared, if required, to provide you with the service and access to features you expect.
Section 8: How Do We Protect Information And Secure Information Transmissions
We employ commercially reasonable methods to ensure the security of the information you provide to us and the information we collect automatically.
This includes using standard security protocols and working only with reputable third-party vendors.
Email is not recognized as a secure medium of communication. For this reason, we request that you do not send private information to us by email. However, doing so is allowed, but at your own risk.
Some of the information you may enter on our Website may be transmitted securely via a secure medium known as Secure Sockets Layer, or SSL.
Your Credit Card information and other sensitive information is never transmitted via email.
Your Credit Card information is never stored or visible to us, but is securely collected and retained (where applicable) on our Payment Gateway Provider (e.g. Stripe and/or PayPal) and protected as per their privacy, security and data retention policies when you complete a purchase.
We may use software programs to create summary statistics, which are used for such purposes as assessing the number of visitors to the different sections of our site, what information is of most and least interest, determining technical design specifications, and identifying system performance or problem areas.
For site security purposes and to ensure that this service remains available to all users, we use software programs to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage.
The Website contains links to and from web sites of third parties (referred to as Linked Websites) however we are not responsible for the actions of these third parties, including their privacy practices and any content posted on their web sites or system.
We encourage you to review their privacy policies to learn more about what, why and how they collect and use personal information.
We adhere to industry recognized standards to secure any personal information in our possession, and to secure it from unauthorized access and tampering.
We use third-party advertising companies to serve our ads on the Website. Please review Section 2 for more details. These third-party advertising companies employ cookie and 1x1 pixel, gifs or web beacons to measure and improve the effectiveness of ads for their clients. To do so, these companies may use anonymous information about your visits to our website and other websites but will not collect any information which can personally identify you or can be linked to you.
This information may include:
- Date/time of banner ad shown.
- The banner ad that was shown.
- Their cookie.
- The IP addresses.
This information can also be used for online preference marketing purposes.
If you want to prevent a third-party advertiser from collecting data, currently you may either visit each ad network's web site individually and opt out or visit the NAI gateway opt-out site to opt-out of all network advertising cookies. Details are listed in the Behavioural Advertising section of this policy.
Section 10: Behavioural Advertising
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you.
You can opt out of targeted advertising by opting out as follows:
- Access you profile on our Website and opt out of any marketing service.
- Click the unsubscribe / opt-out link at the bottom of any marketing email we send you.
- Disable targeted advertising in Facebook at https://www.facebook.com/settings/?tab=ads.
- Disable targeted advertising in Google at https://www.google.com/settings/ads/anonymous.
- Disable targeted advertising in Bing at https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads.
If you are using another platform not listed above that displays ads, please see their relevant help sections on how to disable targeted advertising.
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at http://optout.aboutads.info/.
It is important to note that when opting out of targeted advertising or tracking on social media or search platforms, that it does not stop all advertising but rather stop tracking your likes or dislikes resulting in you receiving ads on those platforms that might not be applicable to you. Targeted advertising and tracking ensures that you only receive information relevant to your likes and interests, thereby eliminating most irrelevant information being presented to you on those platforms.
Section 11: Email Information
If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses.
We provide the same protection for those electronic communications that we employ in the maintenance of information received online, mail, and telephone.
This also applies when you register on our Website, sign up through any of our forms using your email address or make a purchase on this site. For further information, see the email policies below.
We are committed to keeping your e-mail address confidential. We do not sell, rent, or lease our subscription lists to third parties, and will not disclose your email address to any third parties except as allowed in the section titled Disclosure of Your Information.
We will maintain the information you send via e-mail in accordance with applicable federal law.
In compliance with the CAN-SPAM Act, all e-mails sent from our organization will clearly state who the e-mail is from and provide clear information on how to contact the sender.
In addition, all e-mail messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further e-mail communication from us.
Our emails provide users the opportunity to opt-out of receiving communications from us and our partners by reading the unsubscribe instructions located at the bottom of any e-mail they receive from us at anytime.
Users who no longer wish to receive our newsletter or promotional materials may opt-out of receiving these communications by clicking on the unsubscribe link in the e-mail.
Section 12: Do Not Track
Please note that we do not alter our Website’s data collection and use practices when we see a “Do Not Track” signal from your browser.
Section 13: Consent
When you provide your personal information, you consent that it can be used for the purposes specified in this policy and that you are an authorized holder of such information.
If you choose not to register or provide personal information, you can still use our website, but you will not be able to receive additional services or access certain areas or features that require such personal information or registration on the Website.
In each communication from us you will have the opportunity to unsubscribe from further communications, alternatively, you may contact us to express your choices at firstname.lastname@example.org.
Section 14: Courses, Programs And Associated Materials
You are entitled to review the personal information you have provided us and ensure that it is accurate and current at all times.
To review or update this information simply send us an email to email@example.com and we will provide you with an extract of your personal information.
Section 15: Your GDPR/POPI Rights
If you are a European or South African resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted, as well as the right to restrict and object to certain processing of your information.
Additionally, if you are a European or South African resident we note that we are processing your information in order to fulfil contracts we might have with you (for example if you make an order through the Website), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe and South Africa.
We will retain the any information you choose to provide to us until the earlier of:
- you asking us to delete the information;
- our decision to cease using our existing data providers, or;
- we decide that the value in retaining the data is outweighed by the costs of retaining it.
You have the right to:
- request access to your data that Upstart Entrepreneur stores and the rights to either rectify or erase your personal data.
- seek restrictions on the processing of your data.
- object to the processing of your data and the right to the portability of your data.
- the extent that you provided consent to the Company’s processing of your personal data, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based upon consent that occurred prior to your withdrawal of consent.
- lodge a complaint with a supervisory authority that has jurisdiction over issues related to the General Data Protection Regulation.
We require only the information that is reasonably required to enter into a contract with you or is required by law to be retained for the period defined by law. We will not require you to provide consent for any unnecessary processing as a condition of entering into a contract with us.
If you would like to exercise these rights, please contact us through the contact information listed on our Website.
Section 16: Your Responsibility
It is important that you understand that you have a significant role in protecting your information. As such it is important that you keep your username and password secret and not share that with anyone, as well as ensuring that you have the necessary secure connection to the internet, and that your device is clean and clear of viruses, trojans, malware, spyware, etc.
Section 17: Data Retention
We retain information as long as it is necessary to provide the services requested by you and others, subject to any legal obligations to further retain such information.
Information associated with your account will generally be kept until it is no longer necessary to provide the services or until you ask us to delete it or your account is deleted whichever comes first.
Your data could also be stored for sales statistical purposes.
Section 18: Minors
Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website.
We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use.
If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information.
If you believe we might have any information from or about a child under 16, please contact us at firstname.lastname@example.org.
If we make material changes to how we treat our users' personal information, we may, at our discretion, notify you by email to the email address specified in your account and/or through a notice on the Website home page.
Section 20: Enforcement Of This Policy
If for some reason you believe that we are not adhering to the principals we have outlined in this policy, please notify us and we will do our best to promptly make corrections where possible.
Section 21: Compliance By Law
We are committed to adhering to the laws relating to privacy of personal information of our members/customers in the countries they reside, and will ensure that this policy is always updated to reflect any significant changes that affect the way with how we deal with personal information.
Section 22: Limitation Of Liability
If any of your Personal Information is accessed unlawfully by a 3rd Party due to no negligence by us and having kept within the standards as required by law, we can then not be held liable for such a data breach.
We are however committed to ensure that we always have the best security measures and firewalls in place to prevent such breaches, as much as is possible and required by law.
Section 23: Severability
Section 24: Governing Law And Jurisdiction
Section 25: Titles And Subtitles
The titles and sub-titles used in our policies are used for convenience only and are not considered in construing or interpreting this policy.
Section 26: Contact Us
Section 27: References And Related Policies
We look forward to building a strong and long term business relationship with you.