Privacy Policy

1. Purpose and Scope of this Privacy Notice

This Privacy Notice (the "Notice") outlines the manner in which ULPO.co.in, also referred to as "ULPO," "we," "our," "us," or "Human Compass LLP," collects, uses, discloses, and otherwise processes personal data concerning individual users of our website www.ULPO.co.in (the "Website"), mobile applications (the "App"), and those accessing our services through APIs and third-party platforms (collectively, the "Services"). This includes, but is not limited to, Website Users, Buyers, and Professionals (whether prospective, current, or past), as well as individuals applying to work with us (collectively, "you"). This Notice does not pertain to data that is not subject to applicable data protection laws, such as deidentified or publicly available information. Furthermore, this Notice does not constitute a contract and does not create any legal rights or obligations beyond those provided by law. It is essential that you read this Notice to understand our handling of your personal data.

2. Data Protection Responsibilities

For the purposes of this Notice, "personal data" refers to any information that relates to an identifiable natural person. Examples of personal data include, but are not limited to, your name, address, and contact details, if they serve to identify you. The term "process" encompasses any activity related to personal data, including collection, storage, use, and transmission. As a controller of your personal data, ULPO.co.in makes decisions regarding how and why your personal data is processed and is responsible for ensuring compliance with applicable data protection laws. This Notice describes our privacy practices in our capacity as a controller of personal data. However, it does not address how our Professionals may process personal data in the course of providing their services.

3. Types of Personal Data Collected and Sources

If you are reviewing this Notice, you likely fall into one or more of the following categories of individuals whose personal data we process:

• Buyers: Prospective, current, or past customers of ULPO.co.in who register an account and/or place a buyer request (known as a "ULPO Request").
• Professionals: Current or past individuals or businesses registered as Professionals on ULPO.co.in to provide services to Buyers, or businesses identified as being of interest to our Buyers and potentially contacted with business opportunities.
• Website Users: Individuals accessing our Website.

We collect and process different types of personal data depending on the relevant category.

4. Categories of Personal Data

Pursuant to our data collection practices, we gather various types of personal data about you based on your interaction with our Website and Services. This data may include, but is not limited to, your name, contact details, business information, correspondence with us, transaction records, and usage patterns of our Services. The collection of this data is necessary for the provision of our Services to you.

We and our trusted third-party partners may also collect personal data automatically through technologies such as cookies, beacons, pixels, scripts, and SDKs. This includes information about the devices and computers you use when interacting with our Website, App, and other Services, such as browser type, device type, language, operating system, referring web page, pages visited, and hyperlinks clicked (collectively, “Usage Information”). Additionally, we may utilize third-party tools to collect Usage Information, monitor and record mouse movements, scrolling, clicks, and keystroke activity on the Service, as well as other browsing, search, or purchasing behaviour. These tools may also record Usage Information you enter when interacting with our Services or engaging in chat or form features.

Furthermore, we may collect personal data from other sources and third parties, including but not limited to our Website, your business website, and social media platforms. 

5. Use of Personal Data and Legal Basis

We process your personal data for specific purposes relevant to your relationship and engagement with us. In compliance with applicable data protection laws, we must always have a lawful basis for processing your personal data. We use the personal data we collect for several reasons, including providing our Services to you, communicating with you, verifying your identity, ensuring the proper functioning of our Website and Services, maintaining accurate records, and fulfilling legal obligations.

We rely on various lawful grounds or bases to process your personal data. These include obtaining your consent for processing, processing necessary to enter into or perform a contract with you, compliance with legal obligations, and processing necessary for our legitimate interests or those of a third party.

6. Disclosure of Personal Data

Our core service involves facilitating introductions between Buyers and Professionals. To perform these services, we will share information submitted in a ULPO request (including the Buyer's name, email address, and phone number) with relevant third-party Professionals who choose to respond to the ULPO request.

We may engage trusted third-party companies and individuals to assist in providing, analyzing, and improving our Services. These third parties will process your personal data on our behalf as our processors. We will disclose your personal data to these parties to enable them to perform necessary functions.

Additionally, we may share your information with third parties who use your personal data for their own purposes, such as payment processing or when you access our Services through their applications. These organizations will have their own privacy notices and are responsible for complying with applicable data protection laws.

In certain circumstances, we may disclose your personal data to:

• ULPO.co.in affiliates;
• Consultants and professional advisors, including legal advisors, auditors, and accountants;
• Business partners and joint ventures;
• Prospective sellers or buyers of our business and their advisors in connection with a business transaction or reorganization;
• Insurers;
• Courts, court-appointed persons/entities, receivers, and liquidators;
• Third parties such as legal advisors and law enforcement where necessary to comply with a legal obligation, enforce a contract, prevent fraud, or protect rights, property, or safety;
• Governmental departments, local government, statutory and regulatory bodies, including tax authorities;
• With your consent or at your direction, we may disclose your personal data to certain other third parties or publicly;
• Marketing providers to advertise and communicate with you about the Services;
• Third-party ad networks and advertising partners to deliver advertising and personalized content on our Services and other platforms;
• Your employer or colleagues if you interact with our Services in connection with your employment.

7. Data Retention Period

We will retain your personal data for a limited period, which is no longer than necessary for the purposes for which it is being processed. This includes compliance with legal or regulatory obligations, resolution of disputes, and enforcement of agreements. Once the retention of personal data is no longer reasonably necessary for the purposes outlined in Table C, we will either delete or deidentify the data. If deletion or deidentification is not possible (for example, due to storage in backup archives), we will securely store the data and isolate it from further active processing until deletion or deidentification becomes feasible.

8. Rights Regarding Personal Data

You have certain legal rights concerning any personal data we hold about you. These rights are subject to specific conditions and may vary based on your location or residency. For detailed information about your rights and additional privacy choices available to you, please refer to Table D, available here. If you have any concerns or queries regarding this Notice or how we process your personal data, please contact us using the details provided below.

The following privacy choices are available to all individuals with whom we interact:

• Communication Preferences: You may adjust settings for receiving communications from us at any time by visiting the ‘notifications’ section of your profile or clicking ‘unsubscribe’ in any email you receive from us.
• Automatic Data Collection Preferences: Certain Services may allow you to adjust preferences regarding our use of automatic data collection technologies that process Usage Information. For example, depending on where you access the Services, there may be a “Cookie Preferences” manager linked in the footer of our Websites that allows you to adjust preferences regarding certain automatic data collection technologies on the specific Website you are visiting. Note that any cookie preferences you express will only apply to the specific device and browser you are using at that time.
• Targeted Advertising Preferences: We engage third parties to facilitate targeted advertising based on predictions of your preferences using personal data, including Usage Information. This involves the use of various automatic data collection technologies, including cookies, web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies, and logging technologies. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help link the personal data we and our third-party partners collect to the same person, or otherwise target advertising to an individual on a third-party website or platform.

9. Children’s Personal Data

Our Services are not directed to children under the age of 18, and we do not intentionally collect or solicit personal data from such individuals. If you are under 18, you should not use our Services or provide us with any personal data. If a child under 18 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request removal of the personal data from our systems. If we discover that any personal data we collect has been provided by a child under 18, we will promptly delete that personal data. Where a service category on the Website caters to children under 18, only the personal data of the parent or guardian should be submitted to receive quotes from interested service providers.

10. Third-Party Websites and Services

Our Services may include links to third-party websites, plug-ins, applications, and other services. Except where we post, link to, or expressly adopt or refer to this Privacy Notice, this Notice does not apply to any personal data practices of third parties. To learn about the personal data practices of third parties, please visit their respective privacy notices.

11. Updates to this Privacy Notice

We may update this Privacy Notice periodically to reflect changes in the type of personal data we process and/or the manner in which it is processed. We encourage you to check this Notice regularly for updates.

12. Contact Us

If you require more information about any of the subjects covered in this Privacy Notice or wish to discuss any issues or concerns with us, you can contact us at info@ulpo.co.in.