UPC Co., Ltd (the “Company” or “we”) is committed to protecting and
respecting your privacy.
we will process and use any personal data we collect from you, or that you
provide to us. Please read the following carefully to understand our views
and practices regarding your personal data and how we will handle it. By
visiting http://upower.io, you accept and consent to the practices
described in this policy.
The data controller is UPC Co., Ltd, a company incorporated in the Cayman
Islands. We have appointed a data protection officer who is responsible for
your legal rights, please contact our data protection officer by email at
the Contact information set out below.
How we use your data
When you register an account with us or apply for our whitelist:
We will use your personal information to process your registration or
application and to carry out our obligations arising from any contracts
entered into between you and us. Information about you that we collect
from you may include your name, address, e-mail address, phone number,
ETH wallet public address, and a copy of your passport or National ID.
We may also share your personal information with our affiliates, and
selected third parties including business partners, suppliers and
sub-contractors for the performance of any contract we enter into with
them or you, including the conduct of relevant Know Your Client checks,
Anti-Money Laundering checks, and Combating of Financing of Terrorism
We need to process your personal information in this way to allow you
to register an account with us or join the whitelist, and to carry out
our obligations arising from any contracts entered into between you and
Where you have expressed an interest in receiving communications from us:
This section applies if you have opted in to receive communications
regarding our project from us, including your participation in our
activities or events.
We will handle your personal information (such as your name and email
address) to provide you with communications regarding our project.
When we send you emails regarding our project because you have opted-in
to receive them, we rely on your consent to contact you.
Every email we send to you regarding our project will also contain
instructions on how to unsubscribe from receiving them.
You can tell us that you do not want your personal information to be
processed in this way at any time by contacting us at the Contact
Information set out below or, where relevant, by following the
unsubscribe link shown in every email you receive from us.
To make our website better:
We share your aggregated, anonymous data with third party analytics and
search engine providers that assist us in the improvement and
optimisation of our website.
We will also use your personal information for the purposes of making
our site more secure, and to administer our site and for internal
operations, including troubleshooting, data analysis, testing,
research, statistical and survey purposes.
We process your data for this reason because we have a legitimate
interest to provide you with the best experience we can, and to ensure
that our site is kept secure.
You can prevent us from using your personal information in this way by
using the 'do not track' functionality in your internet browser. If you
enable do not track functionality, our site may be less tailored to
your needs and preferences.
If our business is sold:
We will transfer your personal information to a third party in the
event that (i) we sell or buy any business or assets, in which case we
will disclose your personal data to the prospective seller or buyer of
such business or assets and/or (ii) if the Company or substantially all
of its assets are acquired by a third party, in which case personal
data held by it about its customers will be part of the assets
transferred to such third party.
We process your personal information for this purpose because we have a
legitimate interest to ensure our business can be continued by the
buyer. If you object to our use of your personal information in this
way, the relevant seller or buyer of our business may not be able to
provide services to you.
In order to comply with any legal obligation:
In some circumstances we may also need to share your personal
information if we are under a duty to disclose or share it to comply
with any legal obligation, or in order to enforce or apply our Terms of
Use or other agreements; or to protect the rights, property, or safety
of the Company, our customers, or others. This includes exchanging
information with other companies and organisations for the purposes of
fraud protection and credit risk reduction.
Technical information and analytics
Information we collect about you: When you visit our site, we will
automatically collect the following information:
technical Information relating to of each of your visits to our site
including the Internet protocol (IP) address used to connect your
computer to the Internet, browser type and version, time zone setting,
browser plug-in types and versions, operating system and platform),
information about your visit, including the full Uniform Resource
Locators (URL), page response times, download errors, length of visits
to certain pages and methods used to browse away from the page.
Information we receive from other sources: We are also working closely
with third party analytics providers, hosting providers and search
information providers from whom we may also receive general aggregated
anonymous information about you.
We will combine the information you provide to us with information we
collect about you.
website. This helps us to provide you with a good experience when you
browse our website and also allows us to improve our website. By continuing
A cookie is a small file of letters and numbers that we store on your
browser or the hard drive of your computer. We only use (and store)
non-essential cookies on your computer's browser or hard drive if you
provide your consent.
Strictly necessary cookies
These cookies are necessary for the website to function
These cookies enable us to collect and analyse information
about how users access the website, including identifying a
third party website which directed a user to our website.
Site performance cookies
These cookies enable us to enhance the operation of the
website and the services offered.
Third party Advertising cookies
These cookies enable third parties to show you relevant
advertisements when you access the Website. We do not
attempt to create profiles of users for the purposes of
Please note that third parties (including, for example, advertising
networks and providers of external services like web traffic analysis
These cookies are likely to be analytical/performance cookies or targeting
You can block cookies by activating the setting on your browser that allows
you to refuse the setting of all or some cookies. However, if you use your
browser settings to block all cookies (including essential cookies) you may
not be able to access all or parts of our website.
Cookies may be erased when you exit the website or close the browser.
Others are saved on your device for your next visit. You can delete all
cookies on your computer.
Where we store your personal data
We engage commercial cloud storage providers to store the data that we
collect from you. Therefore, your data may be transferred to and stored in
different jurisdictions and may also be processed by staff operating within
the various countries who work for us or for one of our contractors. By
submitting your personal data, you agree to this transfer, storing or
processing. We will take commercially reasonable steps to ensure that your
relevant privacy laws.
Where we have given you (or where you have chosen) a password which enables
you to access certain parts of our site, you are responsible for keeping
this password confidential. We ask you not to share the password with
anyone. Unfortunately, the transmission of information via the internet is
not completely secure. Although we will do our best to protect your
personal data, we cannot guarantee the security of your data transmitted to
our site; any transmission is at your own risk. Once we have received your
information, we will take all commercially reasonable efforts to prevent
How long do we retain your data for
We will only retain your personal information for as long as necessary to
fulfil the purposes we collected it for, including for the purposes of
satisfying any accounting or legal requirements.
To determine the appropriate retention period for the personal information
we hold, we consider the amount, nature and sensitivity of the personal
information, the risk of harm from unauthorised use or disclosure of your
personal information, the reasons why we handle your personal information
and whether we can achieve those purposes through other means, and the
applicable legal requirements.
In some circumstances, we may anonymise your personal data so that it can
no longer be associated with you for research or statistical purposes, in
which case we may use this information indefinitely without further notice
You have various rights under the data protection laws, which you can
exercise by contacting us. The easiest way to do this is by email at the
Contact Information set out below.
Right to object
You have the right to object to us handling your personal information when:
we are handling your personal information based on our legitimate
interests (as described in the “How we use your data” section above).
If you ask us to stop handling your personal information in this way,
we will stop unless we can show you that we have compelling grounds as
to why our use of your personal information should continue; or
for marketing purposes. If you ask us to stop handling your personal
information on this basis, we will stop.
Right of access
You have the right to access your personal information which we are
handling, and to receive confirmation as to whether your personal
information is being processed by us, as well as various other information
relating to our use of your personal information.
Right to rectification
You have the right to require us to rectify any inaccurate personal
information we hold about you. You also have the right to have incomplete
personal information we hold about you completed, by providing a
supplementary statement to us.
Right to restriction
You can restrict our processing of your personal information where:
you think we hold inaccurate personal information about you;
our handling of your personal information breaks the law, but you do
not want us to delete it;
we no longer need to process your personal information, but you want us
to keep it for legal reasons; or
where we are handling your personal information because we have a
legitimate interest (as described in the “How we use your data” section
above, and are in the process of objecting to this use of your personal
Where you exercise your right to restrict us from using your personal
information, we will then only process your personal information when you
agree, except for storage purposes and to handle legal claims. We will
inform you before any restriction of processing is lifted.
Right to data portability
You have the right to receive your personal information in a structured,
standard machine readable format and to send this to another organisation
controlling your personal information.
This right only applies to your personal information we are handling
because you consented to us using it or because there is a contract in
place between us.
Right to erasure
You have the right to require us to erase your personal information which
we are handling in the following circumstances:
where we no longer need to use your personal information for the
reasons we told you we collected it for;
where we needed your consent to use your personal information, you have
withdrawn your consent and there is no other lawful way we can continue
to use your personal information;
when you object to our use of your personal information and we have no
compelling reason to carry on handling it;
if our handling of your personal information has broken the law; and
when we must erase your personal information to comply with a law we
are subject to.
Our site may, from time to time, contain links to and from the websites of
our partner networks, advertisers and affiliates. If you follow a link to
any of these websites, please note that these websites have their own
privacy policies and that we do not accept any responsibility or liability
for your access of these websites. Please check their individual privacy
policies for more information on how your personal data will be handled by
and, where appropriate, notified to you by e-mail. You agree that it is
your responsibility to check periodically for any updates or changes to our
We welcome any questions, comments and requests regarding this privacy
policy. Please address them to our data protection officer at [INSERT