Privacy Policy

Last updated April 22, 2021

 

Thank you for choosing to be part of our community at Bosman Consulting Company, doing business as Upward Flourish (“Upward Flourish”, “we”, “us”, “our”).  We are committed to protecting your personal information and your right to privacy.  If you have any questions or concerns about this privacy notice or our practices with regards to your personal information, please contact us at hello@upwardflourish.com.

 

When you visit our website www.upwardflourish.com (the “Website”), and more generally, use any of our Services (the “Services”, which include the Website), these are your rights.  In this privacy notice, we explain to you the information we collect, how we use it, and what rights you have in relation to it.  Read through this important information carefully.  If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

 

This privacy notice applies to all information collected through our Services (which, as described above, includes our Website), as well as any related services, sales, marketing, or events.

 

Please red this privacy notice carefully as it will help you understand what we do with the information we collect. 

 

1. WHAT INFORMATION DO WE COLLECT?

 

Information automatically collected

 

In short: Some information is collected automatically when you visit our Website. 

 

We automatically collect certain information when you  visit, use, or navigate the Website.  The information does not reveal your specific identity (like your name or contact information) but may include device and usage information such as your IP address, browser and device characteristics, operating system, language preferences, referring URL’s, device name, country, location, information about how and when you use our Website, and other technical information.  This information is primarily needed to maintain the security and operation of our Website and for our internal analytics and reporting purposes.

 

Like many businesses, we also collect information through cookies and similar technologies.  The information we collect includes:

• Log and Usage Data: Log and usage data is comprised of service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Website which is recorded in log files.  Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings, and information about your activity on the Website (such as date/time stamps associated with your usage, pages and files viewed, searches and other actions you take, and features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”) and hardware settings).
• Device Data: We collect device data such as information about your computer, phone, tablet, or other device you use to access the Website. Depending on the device used, this device data may include information such as your IP address, location, browser type, hardware model, internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data: We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type of settings of the device you use to access the Website.  For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address).  You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device.  Note however that if you choose to opt out, you may not be able to use certain aspects of our Services.

 

2. HOW DO WE USE YOUR INFORMATION?

 

In short: We process your information for purposes based on legitimate business interests, compliance with our legal obligations, and/or your consent.

 

We use personal information collected via our Website for a variety of business purposes described below.  We process your personal information for these purposes with your consent to enter into a contract with you and/or for compliance with legal obligations.

 

We use the information we collect or receive:

 

• To post testimonials. We post testimonials on our Website that may contain personal information.  Prior to posting a testimonial, we will obtain your consent to use your first name, last initial, and the content of the testimonial.  If you wish to update or delete your testimonial, contact us at hello@upwardflourish.com and provide your name, testimonial location, and contact information.
• Request feedback. We may use your information to request feedback and to contact you about your use of the Website.
• To manage user accounts. We may use your information for the purposes of managing your account and keeping it in working order.
• To send administrative information to you. We may use your personal information to send you new service and feature details and/or information about changes in terms, conditions, and policies.
• To protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).
• To enforce our terms, conditions, and policies for business purposes, to comply with legal and regulatory requirements, or in connection with our contract.
• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• To deliver and facilitate delivery of services to the user: We may use your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
• To send you marketing and promotional communications. We may use the personal information you send to use for our marketing purposes if this is in accordance with your marketing preferences.  For example, when expressing an interest in obtaining information about us and our Website, subscribing to marketing, or otherwise contacting us, we will collect personal information from you.  You can opt-out of our marketing emails at any time using the “unsubscribe” button at the bottom of those emails.
• Deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising tailored to your interests and/or location and to measure its effectiveness.
• For other business purposes. We may use your information for other business purposes, such as data analysis, identification of usage trends, determining the effectiveness of our marketing campaigns, and to evaluate and improve our Website, services, marketing, and your experience.  We may use and store this information in aggregated and anonymized form so that it is not associated with the end user and does not contain personal information.  We will not use personal information without your consent.

 

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

 

In short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

 

We may process or share your data that we hold based on the following legal reasons:

 

• Consent: We may process your data if you have given us specific consent to use your personal information or for a specific purpose.
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
• Legal Obligations: We may disclose your information where we are legally required to do so to comply with applicable law, government requests, judicial proceedings, court orders, or legal processes (such as in response to a court order or subpoena or in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or act regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person, or as evidence in litigation in which we may be involved.
• Website Development: Your information may be accessible by our website development teams in other countries.  Safeguards are in place on our servers to ensure that this information is secure.

 

More specifically, we may need to process your data or share your personal information in the following situations:

 

• Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice.  Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

 

4. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

 

In short: We may transfer, store, and process your information in countries other than your own.

 

Our servers are in the United States. If you are accessing our Website from outside United States, please be aware that your information may be transferred to, stored, and processed in our facilities.  It also may be relayed to third parties (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE?” above), and it may be shared in other countries.

 

If you are a resident of the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country.  However, we will take all necessary measures to protect  your personal information in accordance with this privacy notice and applicable law.

 

5. HOW LONG DO WE KEEP YOUR INFORMATION?

 

In short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

 

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).  No purpose in this notice will require us to keep your personal information for longer than the period in which you have an account with us.

 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information,  or if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

 

In short: We protect your personal information through a system of organizational and technical security measures.

 

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process.  However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.  Despite our safeguards, hackers, cybercriminals, or other unauthorized third parties might defeat our security and improperly collect, access, steal, or modify your information.  Although we will do our best to protect your personal data, transmission of such information to and from our website is at your own risk.  It is your responsibility to only access the Website within a secure environment.

 

7. DO WE COLLECT INFORMATION FROM MINORS?

 

In short: We do not knowingly collect data from or market to children under 18 years of age unless it has been provided to us by a parent or legal guardian. 

 

By using the Website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the website.  If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.  If you become aware of any data that we may have collected from children under 18, please contact us at hello@upwardflourish.com.

 

8. WHAT ARE YOUR PRIVACY RIGHTS?

 

In short: You may review, change, or terminate your account at any time. 

 

If you are a resident of the EEA or UK and you believe we are unlawfully processing your personal information, you have the right to complain to your local data protection supervisory authority.  You can find their contact details here: https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080

 

If you are a resident of Switzerland, the contact details for your data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html

 

If you have questions or comments about your privacy rights, you may email us at hello@upwardflourish.com.

 

Account Information

 

If you would like to review or change the information in your account or terminate your account at any time, you can log in to your account  to update these settings.

 

If you delete or request to terminate your account, we will deactivate or delete your account and information from our active databases.  However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or to comply with applicable legal requirements.

 

Cookies and similar technologies:  Most web browsers are set to accept cookies by default.  If you prefer, you can usually choose to set your browser to remove and/or reject cookies.  If you choose to remove and/or reject cookies, this could affect certain features of our Services.  To opt-out of interest-based advertising on this and other  websites, visit http://www.aboutads.info/choices.

 

Opting out of email marketing:  You can unsubscribe from our marketing email list at any time by using the unsubscribe link or by contacting us at hello@upwardflourish.com.  You will then be removed from the marketing email list; however, we may still communicate with you for transactional emails, service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.  To otherwise opt-out, you may access your account settings and update your preferences.

 

9. CONTROLS FOR DO-NOT-TRACK FEATURES

 

Most web browsers and some mobile operating systems and mobile applications include a Do Not Track (DNT) feature or setting that you can activate to signal your privacy preferences and not have data about your online browsing activities monitored and collected.  At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized.  As such, we don not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.  If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

 

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

 

In short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information. 

 

California Civil Code Section 1789.83, also known as the “Shine the Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the preceding calendar year.  If you are a California resident and would like to make such a request, please submit your request in writing to us at hello@upwardflourish.com.

 

This law has provisions for users under the age of 18 which are not applicable to our site because we do not offer our site or services to minors.  Please see section 7 above for more detail.

 

11. DO WE MAKE UPDATES TO THIS NOTICE?

 

In short: Yes, we will update this notice as necessary to remain compliant with all relevant laws. 

 

We may update this privacy notice from time to time.  The updated version will be indicated by the revised date and it will be effective as soon as it is posted.  If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification.  We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

 

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

 

If you have questions or comments about this notice, you may email us at hello@upwardflourish.com.

 

Bosman Consulting Corporation

Canada­­­­