Privacy

Effective Date: 2020 
Last Revised on: 2020

This Privacy Policy (“Privacy Policy”) is designed to help you understand generally how Ulupono Initiative collects, uses and discloses certain information about you in connection with the website on which this Privacy Policy is posted (the “Site”). 

The Site is intended for individuals 18 years of age or older. By using or accessing the Site, you represent and warrant that you are at least 18 years of age. If you are not at least 18 years of age or do not agree with the terms of this Agreement, do not use or access the Site. 

By using or accessing the Site, you expressly consent to our collection, use and disclosure of information in accordance with this Privacy Policy. 

Information We Collect

Personal Information. “Personal Information” means information that personally identifies you, such as your name, phone number, mailing address or email address. 

Except as disclosed in this Privacy Policy, we do not collect any identifiable information about visitors to the Site.

Submitted Information. Ulupono Initiative may collect Personal Information about you when you submit such information to Ulupono Initiative through the Site (“Submitted Information”). For example, Ulupono Initiative may collect Personal Information such as your email address to send out periodic updates regarding Ulupono Initiative. Ulupono Initiative may, in the future, include other requests for Personal Information from you to help Ulupono Initiative tailor the Site for you and deliver personalized information to you. You may request changes to or the removal of your Submitted Information by contacting Ulupono Initiative’s communications team at communications@ulupono.com. If Ulupono Initiative agrees to remove such Submitted Information, you acknowledge and agree that Ulupono Initiative may continue to retain such Submitted Information in its archives and backup locations, until such archives or backups are destroyed or overwritten. You agree not to submit Personal Information about others without our prior written consent. 

Browsing Information.
 When you use the Site, Ulupono Initiative or Ulupono Initiative’s servers (which may be hosted by a third party service provider) collect information automatically about your activities while using the Site (“Browsing Information”). Browsing Information may include the web pages you view, the times you view them, the search terms you use, your location, information about the browser you are using as well as your IP address. An IP address is a number that identifies your computer’s location on the Internet and may be automatically assigned to your computer when you use the Internet. Ulupono Initiative may also use “cookies” or other tracking mechanisms in connection with the collection of Browsing Information. A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer’s hard drive. Ulupono Initiative may, in the future, collect other Browsing Information from you to help us tailor the Site for you and deliver personalized information to you. Browsing Information is collected on an aggregate, anonymous basis, which means that no Personal Information is associated with the data. We do not share Browsing Information with other organizations for their independent use.

Use of Information

Ulupono Initiative may use your Submitted Information and Browsing Information to send you emails that you have requested and for general administrative, technical, marketing, human resource, legal and other purposes related to our operations.

Ulupono Initiative uses a third-party vendor to help us manage some of our email communications with you. While we do supply this vendor with email addresses of those we wish them to contact, your email address is never used for any purpose other than to communicate with you on our behalf. When you click on a link in an email, you may temporarily be redirected through one of the vendor's servers (although this process will be invisible to you) which will register that you've clicked on that link, and have visited our Website. Ulupono Initiative never shares any information, other than your email address, with our third-party email vendor, who does not share these email addresses with anyone else for their independent use. 

Even if you have given us permission to send emails to you, you may revoke that permission at any time by following the “unsubscribe” information at the bottom of the email.

Disclosure of Personal Information

Except as otherwise noted below, we do not disclose Personal Information to non-affiliated third parties. We may disclose Personal Information to non-affiliated third parties: (i) to fulfill specific requests that you have submitted; (ii) to provide, maintain, enhance, or add to the functionality of the Site; (iii) when required by law or under the good-faith belief that such disclosure is necessary in order to conform to applicable law, comply with subpoenas, court orders or legal process served on Ulupono Initiative; or (iv) to establish or exercise Ulupono Initiative’s legal rights or defend against legal claims, and to protect personal or public safety, or the property or interests of Ulupono Initiative, its agents and employees, or portfolio companies. Under certain circumstances, Ulupono Initiative may be prohibited by law, court order or other legal process from providing notice of the disclosure, and Ulupono Initiative reserves the right to not provide such notice in its sole discretion. 

Ulupono Initiative cannot ensure that your Personal Information will not be disclosed to non-affiliated third parties due to reasons beyond its reasonable control. 

We may disclose Personal Information to affiliates and we may disclose Browsing Information and/or aggregated information that does not include individual Personal Information to third parties. 

Ulupono Initiative will transfer Personal Information and Browsing Information if Ulupono Initiative is acquired by or merged with a third party. In this event, Ulupono Initiative will provide notice on the Site prior to such transfer of Personal Information and Browsing Information.

Updates to Privacy Policy

We may update this Privacy Policy from time to time as the Site changes. If we make material changes to this Privacy Policy, we will post a notice of the changes to the Privacy Policy on the Site. Unless otherwise provided, the revised terms will take effect as of the Effective Date printed at the beginning the Privacy Policy. We encourage you to periodically reread this Privacy Policy to see if there have been any changes that may affect you. Once such changes become effective, your continued use of the Site will signify your acceptance of the new Privacy Policy. If you do not agree to the terms of this Privacy Policy, or any revised Privacy Policy, your sole and exclusive remedy is to discontinue using the Site.

Third-Party Information, Services and Tools

The Site contains information, services and tools provided by third parties, whether through embedded modules, links or other technologies. Use of such information, services and tools may be governed by the privacy policies of such third parties and Ulupono Initiative. Please refer to such third parties for their privacy policy to determine how they collect, use and disclose your information.

Do Not Track

Currently, various browsers offer a “do not track” or “DNT” option that sends a signal to websites visited by the user about the user’s browser DNT preference setting. Ulupono Initiative does not currently commit to supporting the DNT browser setting, in part because no common industry standard for DNT has been adopted by industry groups, technology companies, or regulators.

Questions

If you have questions about this Privacy Policy, please contact Ulupono Initiative’s communications team at communications@ulupono.com.