Last Updated as of: May 11, 2025
This Privacy Policy describes the policies and procedures of UMA LTD. (“UMA” or “we”, “our” or “us”) on the collection, use and disclosure of your information including personal or personally identifiable information (“Information”) and data we obtain from your activity on or through our UMA Smart Equipment, UMA website at: Uma.today (“Site”), the UMA mobile application (“APP”) and all other services, features, content or applications we offer, which you can also review in our Terms of Use (collectively, the “Services”), which we may utilize in our internal use as part of providing the Services (collectively with the User Content, the “Data”). We receive information about you from various sources, including: (i) if you register for the Services, through your user account on the Services (your “Account”); (ii) your use of the Services generally; and (iii) from Third Party Services (as defined below). By using our Services, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your Information and Data as described in this Privacy Policy. Any terms used but not defined in this Privacy Policy have the meanings set forth in our Terms of Use, available on the APP or on our Site.
We encourage you to read and understand our terms of service (“Terms”) before using or purchasing the Services. By accepting the Terms or this Privacy Policy and/or accessing, using, or purchasing the Services, you expressly consent to our collection, use and disclosure of your Information and Data in accordance with the Related Agreements. This Privacy Policy is incorporated into and subject to the Terms.
All capitalized terms or terms that were otherwise defined in the Terms that are not otherwise defined herein obtain their meaning from the Terms, including, without limitation, the definition of “you” and “your” used in the Terms.
1. Overview
This Privacy Policy covers the treatment of Information and Data gathered when you are using or accessing the Services. This Privacy Policy also covers our treatment of any Information that our business partners share with us or that we share with our business partners. This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third-party websites, services and applications (“Third Party Services”) that you elect to access through the particular service, or to individuals that we do not manage or employ. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.
The information we gather enables us to personalize, improve and continue to operate the Services. In connection with certain aspects of the Services, we may request, collect and/or display some of your Information.
2. What Information Do We Collect?
a. General. Our primary purpose in collecting information and data from you voluntarily is to provide you with a safe, smooth, efficient, and customized experience when using the
Services. We will only ask for and collect Information and Data that we consider necessary for achieving this purpose.
b. Account Information: You can browse the public facing sections of the Site without registering for an Account. However, in order to use or purchase the Services, you must register for an Account by providing your username, password, legal or preferred name, title, email address, phone number, address, billing information, birthday, sex, employer, dietary preferences, location and other similar information as appropriate. When registering for an Account, you must provide Information as requested or were indicated on the Site or the APP. At that time, you will no longer be anonymous to us. In addition, as you use or purchase the Services, you may be required or requested, from time to time, to provide further Information through the Services. We may use your contact information to send you information about our Services but you may unsubscribe from these messages through your Account settings. We reserve the right to contact you when we believe it is necessary, such as for account recovery purposes. UMA holds Information on behalf of users as it relates to the Services and/or their communication, interaction, and involvement with one another, directly or indirectly, through the Services.
c. User Content: Some features of the Services may now or in the future allow you to provide User Content to the Services, such as written comments or reviews. All User Content submitted by you to the Services may be retained by us indefinitely, even after you terminate your Account. We may continue to disclose such User Content to third parties in the form of Aggregate Information (as defined below) for the provision of Services.
d. Financial Information: If you have registered for an Account, we may collect your credit card, other payment method and/or banking information in an encrypted manner. If and when you add a credit card, payment method and/or banking information to an Account, such information and your Information may be shared with our third-party payment processor(s) only to the extent necessary to resolve or settle any disputes or claims. We do not store your financial information, such as valid credit card number, type, or other financial information to process a transaction on our servers.
e. Email, Text Message and Notifications: We may communicate with you via email, SMS, MMS or other text message (“Text Message”) or push notifications on the APP or Site (to the extent you permit us to do so), and we may collect information regarding such communications, such as confirmation when you open an email, read a Text Message or receive a push notification, and any responses from you. We use this information to improve our Services, including without limitation our customer service.
f. Recordings: You acknowledge and consent that UMA may use the UMA Smart Equipment features for Recordings (as described in the Terms) of you when you access our UMA Smart Equipment. The Recordings are for the limited purposes of ensuring the security of users, to validate user transactions and review user disputes or refund claims, and to protect us against theft or damage by any user. Any Recording is activated only when the door of the UMA Smart Equipment is opened by the user and stops when the door is closed. No Recording occurs based on proximity, field of vision, or passive movement. UMA does not use facial recognition technologies, and no biometric identification is performed. All Recordings are stored securely on encrypted, cloud-based servers managed by Third Party Services (as defined below). Recordings are retained for a period of thirty (30) days and are automatically deleted thereafter, unless required for an active investigation or as mandated by applicable law. For clarity, UMA does not share Recordings or user data with any third parties, except if required by applicable law including for insurance or criminal investigations, or in response to valid law enforcement requests. Any user data collected in such Recordings is for our internal use only for the purposes described in this section and by using our Services you consent to being recorded in such Recordings and Data collection by UMA for such limited purposes.
g. Device Identifiers: When you access the Site by or through a device, we may access, collect, monitor and/or remotely store one or more “device identifiers”. Device identifiers allow us to uniquely identify your device and are used to enhance the Service (including sending updates and information from the Service). A device identifier does not collect or share any other personally identifiable information about you. A device identifier may also be used in conjunction with other Information.
h. IP Address Information and Other Information Collected Automatically: We automatically receive and record information from your web browser when you interact with the Services, including your IP address and cookie information. This information is used for fighting spam/malware and also to facilitate collection of data concerning your interaction with the Services. Generally, the Services automatically collect usage information, such as the number and frequency of visitors to UMA Site and APP. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Services so that we can analyze and improve them.
i. Information Collected Using Cookies: Cookies are pieces of text that may be provided to your computer through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit. We use cookies to help us remember and process the items in your purchase transaction, understand and save your preferences for future visits, serve you and keep track of advertisements, compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. Our cookies do not, by themselves, contain Information, and we do not combine the general information collected through cookies with other Information to tell us who you are. Most browsers and mobile devices have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. This Privacy Policy covers our use of cookies only and does not cover the use of cookies by Third Party Services. We do not control when or how Third Party Services may place cookies on your computer.
j. Aggregate Information: We collect statistical information about how both unregistered and registered users, collectively, use the Services (“Aggregate Information”). Some of this information is derived from Information. This statistical information is not Information and cannot be tied back to you, your Account or your web browser. We
share this type of statistical data so that our partners can understand how and how often people use our Services and their services or websites, which facilitates improving both their services and how our Services interface with them. In addition, these third parties may share with us non-private, aggregated or otherwise non-personal Information about you that they have independently developed or acquired.
k. Information Regarding Your Social Networks: Occasionally, you can use your Account on our Services to interact with your accounts on other services, such as Instagram, Facebook and WeChat. You can access posting and sharing tools on the Services, including a “share” button that allows you to post information to your social networks outside of the Services (“Share”). Please note that these tools may be operated by Third Party Services. By using these tools, you acknowledge that the Third Party Service that operates the tool may be collecting information about your browser or online activity through its own tracking technologies and subject to its own privacy policy. When you use these tools, some of your information from the Services (such as the Listing information you selected to Share) may be shared with the Third Party Service and others. Therefore, we encourage you to read the privacy policies and other policies of the social networks you use in connection with the Services.
3. How and with Whom is Your Information Shared
Consistent with the permissions you give us to collect the information, we may use your Information we collect:
a. To better respond to your individual needs, personalise, and improve your experience with the Service and products;
b. to ensure technical functionality of the Service, develop new products and services, and analyse your use of the Service, including your interaction with applications, advertising, products, and services that are made available, linked to, or offered through the Service;
c. to communicate with you for Service-related or research purposes including via emails, notifications, text messages, or other messages, which you agree to receive; d. to communicate with you, either directly or through one of our partners, for marketing and promotional purposes via emails, notifications, or other messages, consistent with any permissions you may have communicated to us (e.g., through your account settings); in the preferences section, we inform you of the controls you can use to opt out from receiving certain messages;
e. to share with our Third Party Service providers that we retain and contract with to perform certain tasks on our behalf. We may need to share Information with our Third Party Service providers in order to provide products or services to you. These third parties may have access to your Information only to perform these tasks on our behalf. These entities are bound by contractual obligations to keep personal information confidential and can use it only for the purposes for which we disclose the information to them;
f. to share with our subsidiaries and affiliates for the purposes outlined in this Privacy Policy; g. to process your payment, initiate and complete a transaction;
h. to ensure security and prevent or detect or investigating fraud;
i. to comply with any legal or regulatory obligations, such as complying with any court order, law, or legal process (such as a subpoena), including responding to any government or regulatory request, lawful requests by public authorities, or meeting national security or law enforcement requirements;
j. if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of UMA, our subscribers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
k. to enforce this Privacy Policy, the Terms, and any other terms that you have agreed to, including to protect the rights, property, or safety of UMA, its users, or any other person, or the copyright-protected content of the Service; and
l. For any other purpose disclosed by us when you provide the information. m. With your consent.
n. as otherwise stated in this Privacy Policy.
4. Do We Disclose Any Information To Outside Parties?
While we work with Third Party Service providers who provide website, application development, hosting, maintenance, and other services for us, and these providers may have access to, or process personal data as part of providing those services for us, we limit the information provided to these to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.
We do not sell, trade, or otherwise transfer your Information to any external parties. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, and we take care to use Third Party Services that we believe are reputable and capable of performing the services we require of them, including, without limitation, the handling of confidential information and Information and Data and the compliance with all applicable laws.
We may also release your Information when we believe release is appropriate to comply with the law, enforce our Site policies, or protect ours or others’ rights, property, or safety. However, non personally identifiable user or visitor information may be provided to other parties for marketing, advertising, or other uses.
While we will do everything our power to ensure the security of user Data and Information, including Recordings, it is ultimately the responsibility of the third party service provider selected for our servers and UMA shall not be held responsible for breaches arising out of the actions or inactions by such third party service providers.
We may disclose Information and Data to the acquiror or its agents in the course of the sale of our business, in accordance with applicable law. If we do this, the disclosure will be subject to confidentiality arrangements customary in such transactions.
5. Public Information About Your Activity on the Services:
Some of your activity on and through the Services is public by default. This may include, but is not limited to, content you have posted publicly on the APP or Site or otherwise through the Services. Registered users may have some of this information associated with their Accounts. Unregistered users will not have this association, but information concerning their use of the Services (such as what pages they have visited) may be tracked anonymously through the use of cookies and stored by us.
Please also remember that if you choose to provide Information using certain public features of the Services, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services.
6. How Do We Protect Your Information and Data?
We implement a variety of industry standard measures, including secure servers and protocols, to maintain the safety of your Information when you place an order or enter, submit, or access your Information. Your Account Information will be protected by password and/or one-time password. It is your responsibility to secure the information to prevent unauthorized access to your Account and Information. We recommend using a unique password for your UMA Account that is not used for other online accounts.
All supplied sensitive information or financial information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are subject to confidentiality obligations. After a transaction, your private information (credit cards, social security numbers, financials, etc.) will not be stored on our servers.
We cannot guarantee the security of any Account Information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
7. Data Retention:
Except as otherwise provided in this Privacy Policy, UMA may retain your Information and Data for a period of time consistent with the original purpose of collection and for as long as it is required for the purposes for which it was collected, which is determined in our sole discretion, in accordance with the applicable laws. For instance, we may retain your personal information during the time you have an account to use UMA App or Site or our Services, or as agreed in our term agreements, and for a reasonable period of time thereafter. We also may retain your Information and Data during the period of time needed for UMA to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes, and enforce our agreements. Notwithstanding the foregoing, we may periodically de-identify (a) Information from collected Data in unused Accounts; and (b) unnecessary Information from Data collected elsewhere on and/or through the Service. Subject to the terms and conditions of this Privacy Policy and applicable law, with the exception of Aggregate Information, we may delete unused Accounts and the Information and Data associated with them within a time period as required by applicable law.
8. Information We Share With Your Consent:
Except as set forth above, you will be notified when your Information may be shared with another party that is not otherwise disclosed in this Privacy Policy and/or the Terms, and will be able to prevent the sharing of this information. . Where we have asked for your consent to use, retain and/or process your Information and Data (if applicable), you can withdraw this consent at any time. We will do our best to accommodate your request, subject to applicable laws and the terms and conditions of this Privacy Policy.
9. Other Information and Data Collectors:
Except as otherwise expressly included in this Privacy Policy, this document only addresses the use and disclosure of Information and Data we collect from you. To the extent that you disclose Information and Data to other parties through the Services, different rules may apply to their use, collection and disclosure of Information and Data. Except as provided herein, since we do not control the Information and Data use, collection, or disclosure policies of third parties, you are subject to their privacy policies. We encourage you to ask questions before you disclose Information and Data to others.
10. Age Restrictions, Your Access and Right to Information:
Our Services are for use by persons who are the applicable age of majority in the user’s province of residence. We do not knowingly collect Information or Data from persons under the age of majority. For Services provided to users below such age of majority, you represent that you have the consent of a parent or legal guardian (if applicable) to use our Services and to provide any personal information, through the Site or the APP, or otherwise.
You have the right to access and correct your Information or Data (collectively, the “Information” for purposes of this section). If you want to review or correct your Information, you can login to the appropriate APP or Site or Service and visit your Account profile page or contact us directly with a written request.
If UMA processes your Information, you have the right to request deletion of Information we hold about you and we have the obligation to erase your Information, where:
a. the Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed,
b. you withdraw consent on which the processing is based and where there is no other legal ground for the processing,
c. you object to the processing and there are no overriding legitimate grounds for the processing,
d. the Information has been unlawfully processed, or
e. the Information has to be erased for compliance with a legal obligation to which UMA is subject.
In order to access, delete or update/correct your Information, please submit a written request through general@uma.today. In some cases, we may not be able to remove your Information, in which case we will let you know that we are unable to do so and why. For example, given the nature of sharing on the Services, any public activity on your Account prior to deletion may remain stored on our servers and will remain accessible to the public.
11. Jurisdiction:
Your Information may be collected, processed and stored by us or our service providers in Canada and in some cases, in other countries where our servers reside. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your Information, in some of these countries may not be equivalent to those in your country. If you are using the Services in the European Union or other regions with laws governing data collection and use that may differ from Canadian law, you consent to the transfer of your Information and other information to the Canada and other countries where we and our service providers operate.
12. Changes to This Policy:
We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we collect or use information, we will notify you by (a) posting a notice on the Site or your Account page; (ii) sending you an email at the address registered on the applicable Account; and/or (iii) otherwise notifying you pursuant to the notice or modification provisions in the Terms . A user is bound by any changes to the Privacy Policy when he or she uses the Services after such changes have been first posted.
If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to general@uma.today. We will make every effort to resolve your concerns.