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.