Last Updated: April 2, 2021

UPWARD (also referred to here as “we”, “us” or “our”) seeks to build a global network that provides executive women with the opportunity to advance professionally through relationships, sponsorship, advice, and other support to reach and succeed in the highest level attainable in their career.

We value your relationship with us and the trust you place in us when you share personal information with us. We value your privacy and understand the importance of taking care of personal information we collect.

This Privacy Policy (this “Policy”) explains how we may collect, store, share, and otherwise use personal information that you may provide to us or that we may collect, including when you visit our UPWARD website at upwardwomen.org, our UPWARD Men website at upwardmen.org or other websites that we operate that link to this Policy (collectively, our “Websites”), or use services that we may provide, including our My UPWARD network at myupward.mn.co (collectively, including our Websites, our “Services”).  

We invite all visitors to our Websites and users of our Services to carefully review this Privacy Policy before continuing to access or use our Services. Please note that we may modify or update this Policy to reflect any changes in our information practices, as described below under “Updates to This Privacy Policy,” and we encourage you to check this Policy periodically for changes.

If you have any questions or comments about our handling of personal information, please contact us at info@upwardwomen.org or as provided in the “Contact Us” section below.

What Personal Information Do We Collect?

Personal Information You Provide to Us. We collect certain personal information directly from you when you decide to provide it, for example when you apply to join UPWARD, communicate with us, register for an event, or otherwise use our Services. This may include the following:

·        Identity and contact information, such as your name, email address, mailing address, phone number, and website

·        Biographical and professional information, such as your company or employer, title, professional role, educational background, and certifications

·        Other information that you may provide to us that is not specifically listed here, for example information in correspondence or that you may submit through our Services, including My UPWARD

Personal Information We Collect Automatically. We may also automatically collect information from you or about your computer or device when you visit our Website or use our other Services, through automated logging or other technical means. This may include the following:

·        Device data, such as IP address, computer or mobile device operating system type and version number, manufacturer and model, browser type, and general location information such as city, state, or geographic area (but not your precise geolocation data)

·        Activity data, such as information about your actions and use of the Website and our Services, including pages or screens you viewed, how long you spent on a page or screen and other activity information, navigation information, and access times

We may use this automatically collected data to better understand overall usage trends of our Website or other Services, and to ensure consistent performance.

Cookies and Pixel Tags. We, our service providers and third-party partners may also use cookies and similar technologies to collect information about you from our Services. Cookies are small files stored directly on the computer or device that you are using that can collect the information described above.  Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of our Services (including email recipients), measure the success of our communications, and compile statistics about usage of the Services and response rates.

Personal Information from Other Sources.  We may also collect or receive personal information about you from other sources, such as:

·        Publicly available sources, including social media platforms

·        Partner and affiliated organizations, such as sponsors of UPWARD programs or events, and businesses or organizations who work with us to advance UPWARD’s mission

We may combine the personal information we obtain from other sources with the personal information you provide to us or that we collect automatically.

How Do We Use Your Personal Information?

We use your personal information in order to advance UPWARD’s mission to build a global network that provides executive women with the opportunity to advance professionally and succeed in the highest level attainable in their career. This mission depends on using personal information of, and often making connections between, our members and other individuals who want to further this mission.

This includes using your information for the following purposes:

·        Providing our Services. We use personal information to provide you with our Services, such as to:

o   Operate and improve our Website and other Services;

o   Communicate with you about our Services, such as sending you announcements, updates, and support and administrative information; or

o   Respond to your requests, questions, and feedback.

·        Research and development. We may use personal information to develop and improve the Services we offer, and we may also conduct research that advances UPWARD’s mission. (Our research efforts will be anonymized as appropriate, as discussed below.)

·        Marketing. We may send you announcements or other marketing communications as permitted by law.

·        Compliance with law. We may use and share your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

·        Safety, defense of rights, and prevention of fraud.  We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (i) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (ii) enforce the terms and conditions that govern our Services; and (iii) 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 or aggregate data. We may create aggregated, de-identified or other anonymous data from your and others’ personal information, for example by removing information that makes the data personally identifiable to you, or by combining information to perform statistical analysis. We may use this anonymous data and share it with partners and associated organizations in order to further or promote UPWARD’s mission.

When Do We Share Your Personal Information?

In furtherance of UPWARD’s mission, we may share your personal information with third parties with your consent or in the following circumstances:

·        UPWARD members and users of our Services. Certain of our Services, such as My UPWARD, may allow you to post personal information or otherwise make your information available to UPWARD members or other users of our Services. UPWARD will accommodate your choices to make your information available through our Services. However, we cannot necessarily control how that information may be used by other individuals.

·        Third-party service providers. We may contract with and provide personal information to third parties to perform services for UPWARD, for example to host and maintain our Website and other Services, send email communications, and provide other services that support UPWARD’s operations. We will endeavor to share only that personal information that is necessary to enable the third party to provide the relevant services, that will be used only to provide the relevant services. In particular, our My UPWARD network at myupward.mn.co uses the platform Mighty Networks; please review the Mighty Networks privacy policy at https://www.mightynetworks.com/privacy-policy.  

·        Partners and affiliated organizations. We may share personal information with partner organizations and other associated organizations, as part of our efforts to further UPWARD’s mission or as part of the education and advancement of professional women. For example, we may share personal information for the limited purpose of offering professionally relevant events, programs, or other services to UPWARD members. Or if you attend an UPWARD event and give consent to be contacted by a sponsor of the event, the sponsor may communicate directly with you after the event regarding professional networking and other engagements specific to that sponsor’s organization.

·        Professional advisors. We may disclose personal information to professional advisors, such as attorneys, auditors, and insurers, where necessary in the course of the professional services that those advisers provide to us.

·        As required by law or necessary for safety. We may also share personal information when disclosure is required by law or when we believe it is necessary to prevent fraud, to protect individual or public safety, or to protect the legal interests of UPWARD, UPWARD members, and any relevant third parties.

How Long Will We Keep Your Personal Information?

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for (for example, to provide you with our Services or benefits of being an UPWARD member), and as long as we have a legitimate ongoing organizational need to retain your personal information.

We will periodically delete or anonymize personal information of individuals who are no longer UPWARD members, though we may retain personal information for ongoing organizational needs. For example, we may retain enough personal information to ensure that we do not send UPWARD communications to individuals who have opted out those communications.

Your Choices

Declining to provide personal information. You may choose not to submit personal information to UPWARD or through our Services, but doing so may prevent you from using our Services or receiving members-only information about UPWARD programs and other benefits available to UPWARD members.

Opt-out of marketing emails. You may unsubscribe from our marketing emails by clicking the unsubscribe link or by following other instructions included in those emails. After unsubscribing from marketing emails, you may still receive email messages about the status of your membership or for other administrative purposes.

Cookies. Internet browsers may be configured to reject or disable cookies, as described in documentation for your browser. Please understand, however, that rejecting or disabling cookies may affect your experience of our Website or interfere with your ability to access our Services.

“Do not track” signals. Our Website and Services do not respond to “do not track” settings or signals in browsers.

(Residents of the European Union (EU) have additional rights relating to their Personal Information. Please see “Your EU Privacy Rights” below for more information.)

Security

The security of your personal information is important to us, and we have put in place reasonable security measures designed to protect personal information against unauthorized access, misuse, alteration, and destruction.

However, no data transmission over the internet or electronic data storage can be guaranteed to be 100% secure. While we strive to appropriately protect your personal information, we cannot completely ensure or warrant that personal information in our control will remain free of unauthorized access, misuse, alteration, or destruction.

Links to Third-Party Sites and Services

This Privacy Policy applies solely to the collection and use of personal information by UPWARD.

However, our Website or other Services may contain links to websites or services of unaffiliated third parties, that UPWARD does not operate or control. UPWARD is not responsible for and cannot control how these other websites or services may protect your online privacy. We encourage you to review the privacy policy of any website you visit, particularly one that requests personally identifiable information from you.

Children’s Privacy

Our Website and other Services are not intended for use by children under 13 years of age, and we do not knowingly collect information online from under children under 13 years of age. In addition, if we learn that we have collected or received personal information from a child under 13 years of age, we will delete that information.

If you are the parent or legal guardian of a child under 13 who has provided personal information to UPWARD, or if you believe we may have otherwise inadvertently collected personal information about a child, please contact us by email at info@upwardwomen.org or as provided in the “Contact Us” section below.

International Transfers of Personal Information

UPWARD is based in the United States, and we maintain offices and facilities in the United States. As such, your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country. We will take reasonable steps to ensure that your personal information will be provided the same level of protection in the recipient country or jurisdiction.

Updates to This Privacy Policy

This Privacy Policy may be amended or updated to reflect changes in our information practices or to ensure continuing compliance with all applicable data protection laws and regulations. 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 our Website. 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 our Services.

Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting).

Contact Us

If you wish to request changes to any personal information you have provided to us, or to exercise any privacy rights that you may have under applicable law, or if you have any questions or comments regarding this Privacy Policy, please contact us at info@upwardwomen.org or by mail at [ADDRESS OF PO BOX].

Your California Privacy Rights

If you reside in California, you may request information about our disclosures of your personal information to third parties for their direct marketing purposes. Such requests must be submitted to us by email at info@upwardwomen.org.

Within 30 days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for direct marketing purposes (if any) during the immediately preceding calendar year, along with the names and addresses of such third parties. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted other than as specified in the above paragraph.

Information for Residents of Europe

The information in this section applies only to individuals in the European Union, the European Economic Area, the United Kingdom and other locations subject to the data protection laws of the European Union and United Kingdom (collectively, “Europe”).

Personal information. Except as otherwise specified, references to “personal information” in this section are equivalent to “personal data” governed by European data protection legislation.

Controller. The controller of your personal information for purposes of European data protection legislation is UPWARD, with its mailing address at 19630 Allendale Ave #2156, Saratoga, California 95070.

Lawful bases for processing.  We process personal information subject to European data protection legislation on one or more of the following legal bases:

·        Contractual obligation, to perform our obligations under a contract we have entered into with you, including to provide you with our Services

·        Legal obligation, to fulfill our obligations under applicable law

·        Legitimate Interest, of UPWARD or a third party, for example to provide and monitor the usage of our Services, to protect our rights, or to further UPWARD’s mission, in each case provided that your fundamental rights and interests do not override the interests of UPWARD or any third party

·        Consent, although when processing of personal information is based solely on your consent, you may withdraw your consent to further processing at any time (without affecting the lawfulness of processing based on consent before that consent is withdrawn)

European privacy rights. Residents of Europe have certain rights provided under the EU General Data Protection Regulation ((EU) 2016/679) (“GDPR”) or other applicable law, subject to certain exceptions which may include the following:

·        Rights to access, to provide you with information about the processing of your personal information or to provide you with access to or a copy of your personal information that we control,

·        Rights to rectification, to update or correct inaccuracies in your personal information,

·        Rights to erasure, to request that we delete personal information that we control about you (though this may result in the termination of your UPWARD membership, as we must use your personal information to provide our Services),

·        Right to restrict processing, to restrict or object to our processing of your personal information in certain circumstances, and

·        Right to data portability, to receive your personal information in a structured, commonly used format and to transmit that personal information to another controller.

If you are a resident of Europe and wish to exercise any rights that you have under applicable law, please, contact us at info@upwardwomen.org or as provided in the “Contact Us” section in this Privacy Policy. We may need to request additional information from you in order to confirm your identity before fulfilling any requests.

Typically, you will not have to pay a fee to access your personal data. However, we may charge a fee or refuse to comply with your request if your request is clearly unfounded, repetitive or excessive, as permitted by law. We try to respond to all legitimate requests within one month. It may take us longer to respond to your request if your request is particularly complex or you have made multiple requests, in which case we will notify you and keep you updated.

Transfers of personal information outside of Europe. If we transfer your personal information from Europe to a country outside of Europe in a manner where we are required to apply additional safeguards to your personal information under European data protection laws, we will do so. We may do so by, for example, implementing the standard contractual clauses adopted by the European Commission or via other safeguards recognized by the European Commission.  For further information about any such transfers or the specific safeguards applied, please contact us at info@upwardwomen.org or as provided in the “Contact Us” section in this Privacy Policy.