Privacy Policy

Urban Partners, Inc, operating through its affiliates and representative offices located throughout the world (collectively, the “Company”) is strongly committed to protecting your privacy and has implemented the below to ensure all the personally identifiable information you provide is protected.

This Privacy Policy applies to all personally identifiable information (PII) that is collected for and on behalf of the Company through our website. The Privacy Policy describes how we collect, use, share and protect PII. By using our website, you consent to the data collection and use practices that are described within this Privacy Policy. If you have any questions about this Privacy Policy or the protection of your information, please contact the Company at info@UPIUrbanPartners.com

Information Collection and Use

While using the various features provided on our website, the Company may collect PII, which is information that identifies an individual or relates to an identifiable individual. PII may include, but is not limited to your name, telephone number, physical address, email address, Company affiliation and associated interests.

The Company may also collect other information through your interaction with and use of the website and its features, which does not reveal your specific identity or does not directly related to an individual. This other information may include, but is not limited to, browser and devise information, data collected through automated electronic interactions, application usage data, demographic information, geographic or geo-location information, statistical and aggregated information.

Statistical and aggregated information does not directly identify a person, but is may be derived from PII. For example, such information may be used to calculate the percentage of users in a particular zip code. Or the PII may be combined with other information, such as combining a precise geographic location with your name. If PII is combined with other information, the combined information shall be treated as PII.

The Company collects information in a variety of ways that fit broadly into the following general categories:

Log Data

When you access our website, the Company collects information that your browser sends to us, referred to as Log Data. This Log Data may include but is not limited to, your computer’s Internet Protocol (“IP”) address, browser version, those website pages you visited, the time and date of your visit, the time spent on those pages, and other information.

Cookies and log files

We receive IP addresses in the normal course of the operation of our Website. An IP address is a number assigned to you by your Internet service provider, so you can access the Internet. We, as well as third parties that provide content, advertising, or other functionality on our website, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the website. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device”) that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices.

Cookies: A cookie is a piece of data or file that a website can send to your browser, which may then store it on your computer system. Most browsers allow you to block and delete cookies. However, if you do that, the website may not work properly, or you may not be able to receive personalized content. We may use cookies on our website to:

1). provide access to our content: for example, allow you to personalize your experience by keeping you logged in, accessing information, products, and services relevant to your areas of interest;

2). show content & advertising that are more relevant to you: for example, with your consent, we use tracking technologies to remember content that has interested you and remember content that has interested you. Cookies will also help limit the number of times that you see an ad, measure the effectiveness of advertising campaigns and help us and others track whether ads have been properly displayed so we can pay for this. We may also allow other organizations to use tracking technologies for these advertising purposes;

3). analyze and improve your browsing experience: for example, to track your session within our website, so we can learn what content has interested you. We may also use cookies to understand general information about users, such as areas of interest. We also check for bugs and glitches in the content; and

4). prevent duplication: for example, when voting or participating in surveys.

Pixel tags/Web beacons: A pixel tag (also known as a web beacon) is a piece of code embedded on the website that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

Social Media Features: Our website may include social media integrations such as the Facebook “Like” button and LinkedIn (that might include widgets such as the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the Company providing it.

Service Providers

The Company may employ third-party entities for purposes of providing their information technology (IT) expertise and services in the support and operation of the Company’s website and its functional capability. In the performance of those IT services, the third-party entities may have access to your PII. The Company requires each third-party entity to agree to obligations whereby the PII is protected as confidential, comply with applicable laws, to not reproduce the PII and if used, such use shall be limited to and solely for the performance of the tasks assigned.

Notwithstanding, the Company cannot guarantee that any third party will maintain the privacy of your information.

The Company may be obligated to cooperate with various law enforcement inquiries related to the disclosure of your PII. The Company reserves the right to share or transfer your PII to comply with a legal requirement, disclose any activities or information about you to law enforcement or other government officials, at the sole discretion of the Company and as determined necessary or appropriate in connection with an investigation of any activity that is illegal or may expose the Company or you to legal liability. The Company may also release the information if it necessary to prevent the death or serious injury of an individual.

If the Company transfers a business unit or an asset to another Company, we may transfer the PII collected to the relevant third party.

1). Disclosure to Third Parties – EU Individuals Only

European Union (EU) individuals, by your access to the website and its features, you consent to the data collection and use practices that are described within this Privacy Policy. The PII collected may be transferred by the Company to a service provider(s) or a “processor(s)”. The Company, in all such cases, will make sure that (i) it diligently chooses relevant service provider(s), (ii) the service provider(s) is/are certified and compliant with the applicable laws and regulations, (iii) the service provider(s) shall only handle your information in accordance with the Company’s instructions, (iv) the service provider(s) adopts adequate technical and organizational measures to protect your personal data, and, (v) the service provider does not retain your personal data upon completion of its services. Details of service providers and the countries in which they are based are available from the Company by contacting info@UPIUrbanPartners.com.

To the extent that your personal data is shared with service providers, Company affiliates or other third parties processing PII on the Company’s behalf which are located outside your country of residence, the Company requires each to implement and comply with the data protection requirements imposed by your country’s data protection laws.

2). Sharing of Non-Identifiable Information

Information the Company collects that is not PII or PII that has been converted to information which cannot be used to identify you is not limited in any way by this Privacy Policy and can be used and disclosed by the Company in any manner and for any purpose.

3). Security

The Company recognizes the importance of securing your PII and values the trust you extend in providing your PII. The Company uses commercially reasonable physical, electronic and administrative safeguards designed to protect your PII from loss, misuse or unauthorized access, disclosure, alteration or destruction. Regardless of our efforts and the device you may use, it is still possible that third parties may unlawfully intercept or access transmissions or private communications over the internet, or, our means of electronic storage. In the event that your PII is acquired, or is reasonably believed to have been acquired, by an unauthorized person and applicable law requires notification, the Company will notify you by e-mail or U.S. mail. The Company will give you notice promptly, consistent with the reasonable needs of law enforcement and/or the Company to determine the scope of the breach and to investigate and restore the integrity of the data system.

4). Links to Other Sites

The Company website may contain links to or the ability to connect with other websites, social networks or applications (“third-party sites”). Clicking on a third-party link or enable connection may allow the third-party site to collect or share information about you. Note that these external sites are not operated by or under the control of the Company. Therefore, you are encouraged to review the privacy policies and terms of use of any third-party sites before providing your PII.

5). Privacy Choices

You may elect not to have your PII either (a) disclosed to a third party, or (b) used for any purpose materially different from the third parties or purpose(s) stated within this Privacy Policy. In the event you wish to restrict your PII from any such disclosure or use, please contact the Company at info@UPIUrbanPartners.com to review your request.

You may have an opportunity to elect to receive recurring informational/promotional e-mail from the Company. The Company’s email correspondence will include instructions on how to update certain personal information and how to unsubscribe from the emails. Please follow the instructions in the emails to opt-out of an email. The Company will unsubscribe you from that newsletter or other programs within thirty (30) business days from receipt of such request.

You can always contact the Company at info@UPIUrbanPartners.com in order to change your preferences with respect to marketing contacts.

7).Children’s Privacy

The Company is committed to protecting the privacy of children. For that reason, the Company does not knowingly collect personal identifiable information from any person we actually knowis under the age of 13. Our website and its features are not structured to attract anyone under the age of 13.

8). Retention and Deletion

The Company will retain your PII for as long as your account is active; as needed to provide you services; as needed for the purposes outlined in this Privacy Policy or at the time of collection; as

necessary to comply with the Company’s legal obligations (e.g., to honor opt-outs), resolve disputes and enforce our agreements; or to the extent permitted by law. At the end of the retention period, the Company will delete your PII in a manner designed to ensure that it cannot be reconstructed or read.

9). Changes to This Privacy Policy

The Company may update this Privacy Policy from time to time. When changes to the Privacy Policy are posted, correspondingly the date of the Privacy Policy is revised to reflect the “last updated” date. If there are material changes to the Privacy Policy, you will be notified by means of a notice on our website home page. Thus, you are encouraged to review this page periodically to be informed of how we are using your information and to be aware of any changes. Changes that are made to the Privacy Policy are effective immediately after they are posted by the Company. Your continued use of the website and its features after the posting of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. If you have any questions or suggestions about our Privacy Policy or Terms and conditions, do not hesitate to contact our Data Protection Officer at info@UPIUrbanPartners.com

The Company operates this Website to provide online access to information about the Company and the products, services, and opportunities we provide. Your access and use of this website are subject to the following terms and conditions and constitutes acceptance of these terms (“Terms of Use”).

The Company reserves the right to modify these Terms of Use at any time without giving you prior notice. Your use of the website following any such modification constitutes your agreement to follow and be bound by the Terms of Use as modified.

License and Access

You may use the website, and the information, writings, images and/or other works that you see, hear or otherwise experience on the website (singly or collectively, the “Content”) solely for your non-commercial, personal purposes and/or to learn about the Company’s products and services. No right, title or interest in any content is transferred to you, whether as a result of downloading such content or otherwise. The Company reserves complete title and full intellectual property rights in all content. Except as expressly authorized by these Terms of Use, you may not use, alter, copy, distribute, transmit, or derive another work from any content obtained from the website, except as expressly permitted by these Terms of Use.

The Company, its suppliers or the original creator of the content own all copyrights to content on the website and all other intellectual property rights related to the website. To the extent that the Company has the right to do so without compensation to third parties and except for content specifically provided under other terms, the Company grants you permission to copy content on the Website solely for your non-commercial use in support of the Company products and services. You agree that any copies of the content shall retain all copyright and other proprietary notices in the same form and manner as the original. You may not, without the Company’s permission, “mirror” any content contained on the website or any other server. Except as specified above, nothing contained herein shall be construed as conferring by implication, estoppel or otherwise any license or right under any trademark, patent, copyright, or any other intellectual property right of the Company or any third party.

Trademarks

The trademarks, logos, service marks, brand identities, title, characters, trade names, graphics, designs, and other properties (collectively the “Trademarks”) displayed on the the Company website are protected intellectual properties that are registered and unregistered trademarks of the Company, it’s affiliates and others. Nothing contained on the Company website should be construed as granting, by implication, or otherwise, any license or right to use any Trademark displayed on this website without the written permission of the Company or such third party that may own the Trademark displayed on the Company’s website. Your misuse of the Trademarks displayed on the Company’s website, or any other content on the Company’s website, except as provided herein, is strictly prohibited.

Privacy Information Provided to the Company

The Company does not want you to, and you should not, send any confidential or proprietary information to the Company via the website. Any submission by you to the Company, including but not limited to questions, comments, suggestions or the like shall be deemed to be non-

confidential and shall become the property of the Company. Furthermore, by your submission you grant the Company an unrestricted, irrevocable license to use, reproduce, display, perform, modify, transmit, and distribute such information. The Company shall be free to use any ideas, concepts, know-how or techniques contained in such information for any purpose whatsoever, including but not limited to developing, manufacturing, and marketing products incorporating such information.

Electronic Communications

When you visit or send e-mail to us, you are communicating with us electronically. Accordingly, you explicitly consent to receive communications from us electronically. We will communicate with you by e-mail or by posting notices on this website. You agree that all agreements, notices, disclosures, and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing.

Disclaimer of Warranties

THE COMPANY MAKES NO EXPRESS OR IMPLIED WARRANTIES, REPRESENTATIONS OR ENDORSEMENTS WHATSOEVER WITH RESPECT TO THE WEBSITE OR THE CONTENT. THE COMPANY EXPRESSLY DISCLAIMS ALL WARRANTIES OF ANY KIND, EXPRESS, IMPLIED, STATUTORY OR OTHERWISE, INCLUDING, BUT NOT LIMITED TO, IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE AND NON-INFRINGEMENT, WITH REGARD TO THE WEBSITE, THE CONTENT, AND ANY PRODUCT OR SERVICE FURNISHED OR TO BE FURNISHED VIA THE WEBSITE. THE COMPANY DOES NOT WARRANT THAT THE FUNCTIONS PERFORMED BY THE WEBSITE WILL BE UNINTERRUPTED, TIMELY, SECURE OR ERROR-FREE, OR THAT DEFECTS IN THE WEBSITE WILL BE CORRECTED. THE COMPANY DOES NOT WARRANT THE ACCURACY OR COMPLETENESS OF THE CONTENT, OR THAT ANY ERRORS IN THE CONTENT WILL BE CORRECTED. THE WEBSITE AND THE CONTENT ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS.

Limitation of Liability

IN NO EVENT WILL THE COMPANY BE LIABLE FOR ANY DAMAGES WHATSOEVER, INCLUDING, BUT NOT LIMITED TO ANY DIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, EXEMPLARY OR OTHER INDIRECT DAMAGES ARISING OUT OF (I) THE USE OF OR INABILITY TO USE THE WEBSITE OR THE CONTENT, (II) ANY TRANSACTION CONDUCTED THROUGH OR FACILITATED

BY THE WEBSITE; (III) ANY CLAIM ATTRIBUTABLE TO ERRORS, OMISSIONS, OR OTHER INACCURACIES IN THE WEBSITE, THE SERVICE AND/OR THE CONTENT, (IV) UNAUTHORIZED ACCESS TO OR ALTERATION OF YOUR TRANSMISSIONS OR DATA, OR (V) ANY OTHER MATTER RELATING TO THE WEBSITE, OR THE CONTENT, EVEN IF THE COMPANY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. IF YOU ARE DISSATISFIED WITH THE WEBSITE, THE CONTENT, OR WITH THE TERMS OF USE, YOUR SOLE AND EXCLUSIVE REMEDY IS TO DISCONTINUE USING THE WEBSITE.

BECAUSE SOME STATES DO NOT ALLOW THE EXCLUSION OR LIMITATION OF LIABILITY FOR CONSEQUENTIAL OR INCIDENTAL DAMAGES, SOME OF THE ABOVE LIMITATIONS MAY NOT APPLY TO YOU. IN SUCH STATES, THE COMPANY’S LIABILITY IS LIMITED, AND WARRANTIES ARE EXCLUDED TO THE GREATEST EXTENT PERMITTED BY LAW, BUT SHALL, IN NO EVENT, EXCEED $100.00.

Digital Millennium Copyright Act

The Company is committed to complying with U.S. copyright law and to responding to claims of copyright infringement. The Company will promptly process and investigate notices of alleged infringement and will take appropriate actions under the Digital Millennium Copyright Act, Title 17, United States Code, Section 512(c) (“DMCA”).

Pursuant to Title 17, United States Code, Section 512(c)(2), notifications of claimed copyright infringement should be sent to the Company’s Data Protection Officer at info@UPIUrbanPartners.com

Urban Partners, Inc. Website Privacy Policy

Feb 19, 2021