Our Key Privacy Principles

For the U Group, privacy isn’t just a matter of complying with legal requirements. Privacy is at the heart of our business model and everything we do. To that end, we are committed to the following five key privacy principles:

1. “Privacy First” Commitment

Your privacy is our top priority. We have designed every aspect of our business with a privacy-centric mindset that puts you in control of your own personal information.

1. Transparency

You will always know what data we collect from you and how we use it. There will be no surprises.

1. Data Minimization

We only collect the personal information necessary for us to provide our services. If we don’t need it, we won’t ask for it or otherwise obtain it.

1. Limited Third-Party Sharing

Your personal information stays with us, unless you have clearly authorized us to share with other parties – in which case we require those other parties to comply with the same high data protection standards we set for ourselves. For more information on sharing with third parties, see the How Do We Share Your Information? section below.

1. User Control

You get to decide how your personal information is used, stored and shared. We offer tools that empower you to make the choices that are right for you. For more information on your choices, see the Your Rights and Choices section below.

Consistent with the Key Privacy Principles outlined above, the following sections dive into the specific details of how we collect, use and share information about you, as well as your rights and choices about such collection, use and sharing.

Scope of this Privacy Policy

“We,” “us,” “our” and “the U Group” refer to The U Group & Co Limited and its affiliated companies, including The U Group & Co Ltd. “Services” refers to this website as well as the services we make available via our apps – currently OláNota (www.olanota.com) and ReceiptJar (www.receiptjar.com) (collectively, the “Apps”). 

When we refer to “this” Privacy Policy, we also mean our app Privacy Policies as applicable.

By accessing or using our Services, you agree to this Privacy Policy. We therefore encourage you to read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with such policies and practices, please don’t use our Services. 

We may revise this Privacy Policy from time to time (see Changes to this Privacy Policy). If you continue to use our Services after we make changes, you are deemed to have accepted those changes, so please check this Privacy Policy periodically for updates. Rest assured, however, that any revisions will be fully consistent with our Key Privacy Principles above.

We welcome your questions or comments about our privacy practices. Our contact information is provided in the Contact Us section below. 

What Information Do We Collect?

We collect two types of information from users of our Services: (1) information you provide to us, and (2) information we collect automatically. For details, see below.

1. Information You Provide to Us

We collect certain information you provide directly via our Services:

• Your contact information when you:

• Contact us by email, chat, telephone, or via a contact form.

• Seek access to our Services and other resources (such as reports) that we make available.

•  Information you provide about yourself when you register for an App account, including your name and email address,. If you log into your App account using your Facebook account, you may provide your consent for Facebook to share certain information from your Facebook account with the App.

• Information contained in the purchase receipts and invoices you upload to your App account, submit via email or through using our Email Connect and Sync All features. The purchase receipt and invoice information may include details of what was purchased, the supplier information, the total amount spent and the date and time of the purchase.

• Information you provide when you respond to a survey or fill out a form. This information may include sensitive information such as race, ethnic origins or religious beliefs if you voluntarily provide this information. 

• Payment information if you decide to subscribe to our fee-only Services.

• The content of your communications with us, to the extent necessary to provide you with our Services. This includes information collected from you by telephone, video or in correspondence (including email, live chat, mail, text message or social media). All telephone or video calls between you and our representatives may be recorded for training, quality control and compliance purposes, and by continuing with any such call you consent to it being recorded.

2. Information Collected Automatically

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns. This information may include:

• Details of your use of our Services, including traffic data, logs, and other communication data and the resources that you access and use on our Services.

• Information about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and other similar information. This data may include IP address, MAC address, device advertising ID (e.g., IDFA or AAID), and other device identifiers.

• Location information, including information provided by a mobile or other device interacting with the App, or associated with your IP address, where we are permitted by law to process this information.

Why do we collect this information? Because it helps us to improve the Services we make available to you, including by enabling us to:

• Estimate our audience size and usage patterns.

• Store information about your preferences, allowing us to customize our Services according to your individual interests.

• Speed up your searches.

• Recognize you when you return to our Services.

The technologies we use for this automatic data collection may include cookies. No doubt you are familiar with cookies: a small file placed on the hard drive of your computer. 

You may refuse to accept browser cookies by activating the appropriate setting on your browser. Be aware, however, that if you select this setting, you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies (for the limited purposes described above) when you direct your browser to our Services. 

3. Use of Third Party Cookies

Some content on the Services are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies to collect information about you when you use our Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with targeted content. 

4. Information Collected from Third Parties

We may collect certain information about you from third-party sources, including:

• Information about you from third parties that is publicly available, such as personal information and estimated demographic information, if you connect your account to a third party and grant us permission to access this information.

• Invoice information from merchants in cases where you have provided us with access to an online account.

• Information about you from third-party companies that specialize in collecting publicly available information. This may include estimated demographic information and information from public records, such as voter registration.

• Information about you from other sources. This may include demographic information from data collection companies and others so that we can provide anonymous market research reports to customers and partners.

How Do We Use Your Information?

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Services and its contents to you, including to provide customer support.

• To provide you with information, products, or services that you request from us.

• To fulfill any other purpose for which you provide it.

• If you have an account with the U Group, to provide you with notices about your account. 

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

• To notify you about changes to our Services or any products or services we offer or provide through      it.

• To allow you to participate in interactive features of our Services.

• In any other way we may describe when you provide the information.

• For any other purpose with your consent.

• To comply with our legal and regulatory obligations, including to exercise or defend our legal rights (including to detect, investigate and prevent activity that violates our terms and conditions or that may be illegal).

In addition, when you upload your purchase receipts to one of the Apps, send purchase receipts via email or participate in a survey, we use the information contained in those receipts or surveys to prepare reports for our clients. We assure you, however, that all of your personal information is removed from the receipts and surveys before we share any reports with any third parties. Our clients never see your personal information or any other information that could possibly identify you or any other individual. All data shared with third parties is fully anonymized and de-identified. 

We may also use your information to contact you about our goods and services that may be of interest to you. If you do not want us to use your information in this way, please let us know at privacy@theugroup.co. 

We may use information that doesn’t identify you (including personal information that has been de-identified) without obligation to you except as prohibited by applicable law. 

For further information on your rights and choices regarding how we use your information, see Your Rights and Choices below.

How Do We Share Your Information?

We share personal information about you as follows:

• Service Providers. We may share your information with our agents, vendors and other service providers (collectively "Service Providers") in connection with their work on our behalf. Service Providers assist us with services such as payment processing, credit checks, data analytics, marketing and promotional services, website hosting, and technical support. Service Providers are prohibited from using your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information that doesn’t identify you for other purposes.

• Affiliates. We may share your information with our related entities, including our parent and sister companies. For example, we may share your information with our affiliates for customer support, marketing and technical operations.

• Merger or Acquisition. We may share your information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.

• Security and Compelled Disclosure. We may share your information to comply with applicable laws or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share your information to protect the rights, property, life, health, security and safety of the U Group, our Services or any third party.

• Consent. We may share your information for any other purpose disclosed to you and with your consent.

We may share aggregated information that is de-identified with our clients, other third parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see Your Rights and Choices below.

Your Rights and Choices

As we noted in our Key Privacy Principles, you have full control over how your personal information is used, stored and shared.

1. Review and Update of Account Information

You may access, update, or remove certain account information that you have voluntarily submitted to us through our Services by either completing our Privacy Rights Request Form or sending an email to us at privacy@theugroup.co. We may require additional information from you to allow us to confirm your identity. 

Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. California residents have additional rights as set forth in Your California Privacy Rights below.

2. Tracking Technology Choices

Cookies. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations. You can change your preferences with regards to cookies and other trackers found only on our website at any time by clicking on the Your Privacy Choices link at the bottom of our website.

Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit www.allaboutdnt.com. 

Please be aware that if you disable or remove tracking technologies, some parts of our Services may not function correctly.

3. Targeted Advertising

If you do not want us to use information that we collect or that you provide to us to deliver advertisements, you can opt-out by completing our Privacy Rights Request Form. You may also opt out of most such advertising by going to the following websites operated by industry trade and self-regulatory organizations: http://networkadvertising.org/choices (operated by the Network Advertising Initiative) or http://www.aboutads.info (operated by the Digital Advertising Alliance). 

4. Global Privacy Control

U Group does recognize Global Privacy Control signals, which allow you to opt out of the selling or sharing of your personal information. For more information on the Global Privacy Control, including how to set up the Global Privacy Control, see www.globalprivacycontrol.org. 

5. Communications

You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, by completing our Privacy Rights Request Form or by emailing us at privacy@theugroup.co with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of certain non-promotional emails, such as those about your account, transactions, servicing, or the U Group’s ongoing business relations with you.

Your California Privacy Rights

California law grants additional privacy rights to California residents. In particular, the California Consumer Privacy Act (“CCPA”) requires businesses to disclose, for the past 12 months, (i) the categories of personal information collected, (ii) the sources of the collected personal information, (iii) the purposes for which the collected personal information is used, (iv) the categories of personal information disclosed for a business purpose, and (v) the categories of any personal information “sold” or “shared.” The U Group provides these disclosures below. 

Because the CCPA defines the “selling” and “sharing” of personal information very broadly, the U Group’s use of third party cookies may be encompassed within these definitions. In that case, the U Group may be deemed to “sell” or “share” certain “Identifiers” as defined under California law. For your rights regarding opting out of such selling or sharing, see Your Privacy Choices.

California residents also have the rights described below. We will not discriminate against any California resident who exercises these rights. 

Right to access/know your information. You may request from us a list of (i) the personal information that we have collected about you, and (ii) the categories of third parties to whom we have disclosed your personal information. You have the right to up to two (2) access requests each twelve (12) months.

Right to delete your information. You may request, at any time, that we delete your information and direct our service providers to delete your information from their records. We are not required to delete any information that is necessary to provide our Services you have requested, to detect security incidents, or to comply with a legal obligation, among other limited exceptions.

You may contact us to exercise these rights by completing our Privacy Rights Request Form or by emailing us at privacy@theugroup.co. To ensure the privacy and protection of individuals, we are required to verify your identity (or that of your authorized agent) or otherwise authenticate your request(s), which we will do in accordance with the CCPA regulations. Please note that, under the CCPA, we are not required to grant a request to access/know or a request to delete with respect to personal information obtained from you in your role as an employee, owner, director, officer or contractor of a company and within the context of the U Group providing its services to such company.

Your European Privacy Rights 

If you are a resident of the European Union, the United Kingdom or Switzerland, you are entitled to certain information and have certain rights under the General Data Protection Regulation (Regulation (EU) 2016/679) as implemented in the European Union, the United Kingdom or Switzerland (the “GDPR”). Those rights include: 

• The right of access to your information.

• The right to rectify your information if it is incorrect or incomplete.

• The right to have your information erased (“right to be forgotten”) if certain grounds are met.

• The right to withdraw your consent to our processing of your information at any time (if our processing is based on consent).

• The right to object to our processing of your information (if processing is based on legitimate interests).

• The right to object to our processing of your information for direct marketing purposes.

• The right to receive your information from us in a structured, commonly used and machine-readable format, and the right to transmit your information to another controller without hindrance from us (data portability).

If you are located in the European Union, the United Kingdom or Switzerland and you are or have been a user of our Services, we may send you marketing communications based on our legitimate interests, subject always to your right to opt out of such communications. Further, if you are located in the European Union, the United Kingdom or Switzerland, we will never share your information with a third party for such third party’s marketing purposes, unless you have specifically consented to us doing so.

You may exercise any of the above rights by completing our Privacy Rights Request Form or by emailing us at privacy@theugroup.co. We may request specific information from you to confirm your identity, and in some circumstances, we may charge a reasonable fee for access to your information.

Furthermore, if you believe that our processing of your information is inconsistent with your data protection rights under the GDPR and we have not adequately addressed your concerns, you have the right to lodge a complaint with the data protection supervisory authority of your country.

For purposes of the GDPR, we are a “controller” and you are a “data subject.”

International Transfers

The U Group is an international company, operating in multiple jurisdictions. Personal information we collect may be transferred to, stored or processed by us or our service providers in Australia, Brazil, the Philippines, the United States or any other country in which we or our service providers maintain facilities. We will ensure that any international transfers of personal information are subject to appropriate safeguards, such as approved standard contractual clauses or other means compliant with applicable global data protection laws. However, these laws may be less stringent than the laws in your country. By providing your information, you consent to such international transfer and processing. 

Children

Our Services are intended for a general audience and are not directed to individuals under 18 years of age. The U Group does not knowingly collect personal information as defined by the Children’s Online Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA or other applicable laws. If you are a parent or guardian and believe the U Group has collected such information in a manner not permitted by COPPA or other applicable laws, please contact us as at privacy@theugroup.co and we will remove such information to the extent legally required.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Services.

Data Retention

We will only retain your information for as long as reasonably necessary to fulfill the purposes specified in this Privacy Policy. Even if we delete some or all of your information, we may continue to retain and use aggregated or anonymous data previously collected so that it can no longer be used for personal identification and/or anonymize or aggregate your information. 

Changes to this Privacy Policy

We may revise this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy and updating the “last updated” date above. Your continued use of our Services indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your email address. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our website and this Privacy Policy to check for any changes.

Contact Us

If you have any questions or comments about this Privacy Policy or our privacy practices, please contact us as follows:

• The U Group & Co Limited

• Suite 1, Level 9, 111 St Georges Terrace, Perth WA 6000, Australia

• privacy@theugroup.co