Privacy Notice
Last Updated: 30-Dec-2024
This Privacy Notice applies to the processing of personal information by Umbra Lab, Inc., a Delaware corporation and its affiliates (“Umbra,” “we,” “us,” or “our”), including on our website available at www.umbra.space and our other online or offline offerings which link to, or are otherwise subject to, this Privacy Notice (collectively, the “Services”).
1. UPDATES TO THIS PRIVACY NOTICE
We may update this Privacy Notice from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Notice on our website, and/or we may also send other communications.
2. PERSONAL INFORMATION WE COLLECT
We collect personal information you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.
(A) Personal Information You Provide to Us Directly
We may collect personal information you provide to us.
- Account Information. We may collect personal information in connection with the creation or administration of your account. This personal information may include, but is not limited to, your name, date of birth, gender, email address, phone number, payment information, and other information you store with your account.
- Purchases. We may collect personal information and details associated with your purchases, including payment information. Any payments made via our Services may be processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
- Your Communications with Us. We, and our service providers, may collect the information you communicate to us, such as through email.
- Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.
- Interactive Features. We and others who use our Services may collect personal information you submit or make available through our interactive features (e.g., social media pages). Any information you provide using the public sharing features of the Services will be considered “public.”
- Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
- Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
- Job Applications. If you apply for a job with us, we will collect any personal information you provide in connection with your application, such as your contact information and CV.
(B) Personal Information Collected Automatically
We may collect personal information automatically when you use the Services.
- Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, Internet service provider, and location information (including, as applicable, approximate location derived from IP address and precise geo-location information).
- Usage Information. We may collect personal information about your use of the Services, such as the pages you visit, items you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use the Services.
(C) Personal Information Collected from Third Parties
We may collect personal information about you from third parties. For example, if you access the Services using a Third-Party Service (defined below), we may collect personal information about you from that Third-Party Service you have made available via your privacy settings. In addition, users of the Services may upload or otherwise provide personal information about others.
3. HOW WE USE PERSONAL INFORMATION
We use personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below.
(A) Provide the Services
We use personal information to fulfill our contract with you and provide the Services, such as:
- Managing your information;
- Providing access to certain areas, functionalities, and features of the Services;
- Answering requests for support;
- Communicating with you;
- Sharing personal information with third parties as needed to provide the Services;
- Processing your financial information and other payment methods for products and Services purchased;
- Processing applications if you apply for a job we post on our Services; and
- Allowing you to register for events.
(B) Administrative Purposes
We use personal information for various administrative purposes, such as:
- Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for such activity;
- Carrying out analytics;
- Measuring interest and engagement in the Services;
- Improving, upgrading, or enhancing the Services;
- Developing new products and services;
- Creating de-identified and/or aggregated information. If we create or receive de-identified information, we will not attempt to reidentify such information, unless permitted by, or required to comply with, applicable laws;
- Ensuring internal quality control and safety;
- Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;
- Debugging to identify and repair errors with the Services;
- Auditing relating to interactions, transactions, and other compliance activities;
- Enforcing our agreements and policies; and
- Carrying out activities required to comply with our legal obligations.
(C) Marketing
We may use personal information to tailor and provide you with marketing and other content. We may provide you with these materials as permitted by applicable law.
California Shine the Light: We do not share your personal information with third parties for the third parties’ direct marketing purposes.
If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.
(D) With Your Consent or Direction
We may use personal information for other purposes clearly disclosed to you at the time you provide personal information, with your consent, or as otherwise directed by you.
(E) Automated Decision Making
We do not engage in automated decision making or profiling.
4. HOW WE DISCLOSE PERSONAL INFORMATION
We disclose personal information to third parties for a variety of business purposes, including to provide the Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
(A) Disclosures to Provide the Services
We may disclose any of the personal information we collect to the categories of third parties described below.
Service Providers. We may disclose personal information to third-party service providers assisting us with the provision of the Services. This may include, but is not limited to, service providers providing us with hosting, customer service, analytics, marketing services, IT support, and related services. In addition, personal information and chat communications may be disclosed to service providers helping provide our chat features. Some of the service providers we may engage include:
- Google Analytics. For more information about how Google uses your personal information, please visit Google Analytics’ Privacy Notice. To learn more about how to opt-out of Google Analytics’ use of your personal information, please click here.
- LinkedIn Analytics. For more information about how LinkedIn uses your personal information, please visit LinkedIn Analytics’ Privacy Policy. To learn more about how to opt-out of LinkedIn’s use of your information, please click here.
Other Users You Share or Interact With. The Services may allow Umbra users to share personal information or interact with other users of the Services.
Third-Party Services You Share or Interact With. The Services may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use third-party websites, applications, services, products, and technology (each a “Third-Party Service”).
Any personal information shared with a Third-Party Service will be subject to the Third- Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.
Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners.
Affiliates. We may share your personal information with our corporate affiliates.
Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising”, “personalized advertising”, or “targeted advertising.” Some of the advertising Technologies we may use include:
- Google. For more information about Google’s use of your personal information, please visit Google’s Data Policy. To opt out of Google’s use of your information, please click here.
- YouTube. For more information about YouTube’s (owned by Google LLC) use of your personal information, please visit Google’s Data Policy. To opt out of Google’s use of your information, please click here.
- Twitter/X. For more information about X’s (formerly Twitter) use of your personal information, please visit X’s Privacy Policy. To opt out of X’s use of your information, please click here.
(B) Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
(C) Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.
5. YOUR PRIVACY CHOICES AND RIGHTS
(A) Your Privacy Choices
The privacy choices you may have about your personal information are described below.
Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note you will continue to receive transaction-related emails. We may also send you certain non-promotional communications regarding us and the Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Notice).
Do Not Track signals and Global Privacy Control. Certain web browsers and other programs may transmit “do-not-track” “opt-out” signals, also called a Global Privacy Control (or “GPC”) signal (we refer to these as “GPC Signals”), to websites with which the browser communicates. In most cases you will need to change your web browser’s settings or add an application to your web browser to enable your browser to send a GPC Signal. Our websites will recognize GPC Signals for website users differently, based on the location of the user when they access our websites. For users that access our websites from U.S. states that have laws requiring recognition of GPC Signals, we will recognize and apply the GPC Signal to inactivate all the cookies for that website, except for cookies that are necessary for the website to operate. Additionally, if you are accessing our websites from one of these states, you can determine if your browser GPC Signal has been recognized by clicking on the “My Privacy Choices” link in the footer of the website and checking that appropriate cookies have been turned off. For users from states not currently requiring recognition of the GPC Signal, our website servers may recognize and apply the GPC Signal for only advertising and social media cookies but will not apply the GPC Signal to functional or performance cookies. You can always check and adjust your cookie settings by going to the “My Privacy Choices” link in the footer of this website.
Some web browsers incorporate other “do-not-track” (“DNT”) or similar features that signals to websites with which the browser communicates that a visitor does not want to have their online activity tracked. As of the Effective Date, not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, we along with many other digital service operators do not respond to all DNT signals. We recognize GPC signals as required under certain state privacy laws, but we do not currently recognize other DNT signals. For more information about the Global Privacy Control, please visit https://globalprivacycontrol.org.
(B) Your Privacy Rights
In accordance with applicable law, you may have the right to:
- Confirm Whether We Are Processing Your Personal Information;
- Request Access to or Portability of Your Personal Information;
- Request Correction of Your Personal Information;
- Request Deletion of Your Personal Information;
- Request Restriction of or Object to our Processing of Your Personal Information;
- Request to Opt-Out of Certain Processing Activities including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in “profiling” in furtherance of certain “decisions producing legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws); and
- Withdraw Your Consent to our Processing of Your Personal Information. Please note your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal.
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. Please be sure to include:
- Your state and/or country of residence
- Your full name
- Your email
- Your address
- Your phone number
- The right that you would like to exercise
- Whether you are acting on your own behalf or on behalf of someone else
We will process such requests in accordance with applicable laws. You may be entitled to additional rights depending on where you live. If you live in a state or country offering comprehensive privacy rights, please review the supplemental notices below (Annex A – Supplemental U.S. Privacy Notice and Annex B – Supplemental European Privacy Notice).
Only you, or someone legally authorized to act on your behalf in certain jurisdictions, may make a request to exercise the rights listed above regarding your personal information. If your personal information is subject to a law allowing an authorized agent to act on your behalf in exercising your privacy rights and you wish to designate an authorized agent, please provide written authorization signed by you and your designated agent using the information found in “Contact Us” below and ask us for additional instructions.
To protect your privacy, we will take steps to verify your identity before fulfilling requests submitted under applicable privacy laws. These steps may involve asking you to provide sufficient information allowing us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to confirm the email address we have associated with you.
Some laws may allow you to appeal our decision if we decline to process your request. If applicable laws grant you an appeal right, and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.
6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws different from the laws where you live.
7. CHILDREN’S PERSONAL INFORMATION
The Services are not directed to children under 16 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children.
If you are a parent or guardian and believe your child has uploaded personal information to the Services in violation of applicable law, you may contact us as described in “Contact Us” below.
8. THIRD-PARTY WEBSITES/APPLICATIONS
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
9. Contact Us
Umbra is the controller of the personal information we process under this Privacy Notice.
If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us by:
- By Mail
Umbra Lab, Inc.
Attn: Privacy
133 E De La Guerra Street #39
Santa Barbara, CA 93101 - By Email
privacy@umbra.space
To ensure that your request is processed swiftly and accurately, please be sure to include the information requested in Section 5(B) of this Privacy Notice.
ANNEX A – SUPPLEMENTAL U.S. PRIVACY NOTICE
This Supplemental U.S. Privacy Notice supplements our Privacy Notice and only applies to our processing of Personal Information from U.S. consumers residing in a state with a comprehensive privacy law.
NOTICE AT COLLECTION
At or before the time of collection, U.S. consumers residing in a state with a comprehensive privacy law have a right to receive notice of our privacy practices. Such consumers can find this information below.
Personal Information Collected. See the section of this Supplemental U.S. Privacy Notice titled “Overview of Personal Information Collected, Disclosed, Sold and/or Shared” for a list of Personal Information which may be collected.
Uses of Personal Information. See the section of this Supplemental U.S. Privacy Notice titled “Uses of Personal Information” for a list of the purposes for which we use Personal Information.
Is Personal Information “Sold” or “Shared” for “Cross-Context Behavioral Advertising”? See the section of this Supplemental U.S. Privacy Notice titled “Overview of Personal Information Collected, Disclosed, Sold and/or Shared” for more details. See the section of this Supplemental U.S. Privacy Notice titled “‘Sales’ of Personal Information and/or ‘Sharing’ for ‘Cross-Context Behavioral Advertising” for instructions on how to opt-out of these activities.
For How Long is Personal Information Retained? To determine the appropriate retention period for Personal Information, we consider applicable legal requirements, the amount, nature, and sensitivity of the Personal Information, certain risk factors, the purposes for which we process your Personal Information, and whether we can achieve those purposes through other means.
Additional Information. For more information on our privacy practices, please review this Supplemental U.S. Privacy Notice and our Privacy Notice. Importantly, the section of our Privacy Notice titled “Your Privacy Rights” includes important details about how you can exercise some of the rights which you have under the CCPA.
CATEGORIES OF SOURCES FROM WHICH PERSONAL INFORMATION IS COLLECTED
We collect Personal Information you provide to us, collected automatically when you use the Services, and from third-party sources.
OVERVIEW OF PERSONAL INFORMATION COLLECTED, DISCLOSED, SOLD, AND/OR SHARED
U.S. consumers residing in a state with a comprehensive privacy law are provided with the right to know what categories of Personal Information Umbra has collected about them, whether Umbra disclosed Personal Information for a business purpose (e.g., to a service provider), whether Umbra “sold” such Personal Information, and whether Umbra “shared” such Personal Information for “cross-context behavioral advertising” in the preceding twelve (12) months. U.S. consumers residing in a state with a comprehensive privacy law may find this information below:
|
Category of Personal Information Collected by Umbra |
Category of Third Parties to Whom Personal Information is Disclosed for a Business Purpose |
Category of Third Parties To Whom Personal Information is Sold and/or Shared |
|---|---|---|
|
Identifiers |
|
|
|
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) |
|
|
|
Protected classification characteristics under California or federal law |
|
|
|
Commercial information |
|
N/A |
|
Biometric information |
|
N/A |
|
Internet or other electronic network activity |
|
|
|
Personal information revealing a consumer’s precise geolocation |
|
|
|
Sensory data |
|
N/A |
|
Professional or employment-related information |
|
N/A |
|
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g, 34 C.F.R. Part 99)) |
|
N/A |
|
Inferences drawn from other personal information to create a profile about a consumer |
|
|
|
Personal information revealing a consumer’s social security, driver’s license, state identification card, or passport number |
|
N/A |
|
Personal information revealing a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account |
|
N/A |
|
Personal information revealing a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership |
|
N/A |
|
Personal information revealing the contents of a consumer’s mail, email, and text messages unless Umbra is the intended recipient of the communication |
|
N/A |
|
Biometric information processed for the purpose of uniquely identifying a consumer |
|
N/A |
|
Personal information collected and analyzed concerning a consumer’s health |
|
N/A |
|
Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation |
|
N/A |
USES OF PERSONAL INFORMATION
We may use and disclose the Personal Information we collect for the following business and commercial purposes:
- Providing the Services as further described in our Privacy Notice;
- Processing for administrative purposes as further described in our Privacy Notice;
- Processing for marketing purposes as further described in our Privacy Notice;
- Processing with your consent or direction as further described in our Privacy Notice;
- Processing to carry out automated decision making as further described in our Privacy Notice;
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
- Helping to ensure security and integrity to the extent the use of Personal Information is reasonably necessary and proportionate for these purposes;
- Debugging to identify and repair errors impairing existing intended functionality;
- Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with Umbra;
- Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing analytic services, providing storage, or providing similar Services;
- Providing advertising and marketing services;
- Undertaking internal research for technological development and demonstration;
- Undertaking activities to verify or maintain the quality or safety of a service or product owned, manufactured, manufactured for, or controlled by Umbra, and to improve, upgrade, or enhance the service or product owned, manufactured, manufactured for, or controlled by Umbra.
“SALES” OF PERSONAL INFORMATION AND/OR “SHARING” FOR “CROSS-CONTEXT BEHAVIORAL ADVERTISING”
Umbra does not “sell” personal information as most consumers typically define the term “sell” or “sold.” However, our Services use advertising and analytics tools provided by third parties that may constitute a “sale” or “sharing” of personal information or “targeted advertising” under certain state laws. Under these laws, we may “sell” or “share” the following personal information categories to data analytics providers, advertising technology vendors, and social media platforms as described in this Privacy Notice: identifiers, internet or other electronic network information, commercial information, and inferences derived from these categories. To opt out of such selling or sharing, please email us at privacy@umbra.space.
DISCLOSURE REGARDING INDIVIDUALS UNDER THE AGE OF 16
We do not have actual knowledge of any “sale” of Personal Information or “sharing” of Personal Information of minors under 16 years of age for “cross-context behavioral advertising.”
DISCLOSURE REGARDING SENSITIVE PERSONAL INFORMATION
Umbra only uses and discloses sensitive Personal Information for the following purposes:
- To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
- To prevent, detect, and investigate security incidents compromising the availability, authenticity, integrity, and/or confidentiality of stored or transmitted Personal Information.
- To resist malicious, deceptive, fraudulent, or illegal actions directed at Umbra and to prosecute those responsible for those actions.
- For short-term, transient use.
- Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services.
- To verify or maintain the quality or safety of a product, service, or device owned, manufactured, manufactured for, or controlled by Umbra, and to improve, upgrade, or enhance the service or device owned, manufactured by, manufactured for, or controlled by Umbra.
- For purposes not inferring characteristics about individuals.
RIGHT TO LIMIT USE AND DISCLOSURE OF SENSITIVE PERSONAL INFORMATION
U.S. consumers residing in a state with a comprehensive privacy law may have the right to limit certain uses and disclosures of “sensitive Personal Information” by Umbra. Such consumers may exercise these rights by emailing us at: privacy@umbra.space.
NON-DISCRIMINATION
U.S. consumers residing in a state with a comprehensive privacy law have the right not to receive discriminatory treatment by us for the exercise of their rights conferred under applicable comprehensive privacy law.
ANNEX B – SUPPLEMENTAL EUROPEAN PRIVACY NOTICE
This Supplemental European Privacy Notice only applies to our processing of Personal Information that is subject to the EU or UK General Data Protection Regulation.
In some cases, providing Personal Information may be a requirement under applicable law, a contractual requirement, or a requirement necessary to enter a contract. If you choose not to provide Personal Information in cases where it is required, we will inform you of the consequences at the time of your refusal to provide the Personal Information.
If we process Personal Information that is considered a “special category of personal data,” then our processing of such Personal Information may be supported by one or more of the following conditions:
- Explicit Consent: You may have provided your explicit consent for our processing of your Personal Information.
- Necessary for Employment, Social Security, or Social Protection Law Purposes: Our processing of your Personal Information may be necessary for the purposes of carrying out obligations and exercising specific rights in the field of employment, social security, and/or social protection law.
- Necessary to Protect Vital Interests: Our processing of your Personal Information may be necessary to protect the vital interests of you if you are physically or legally incapable of giving consent.
- Publicly Available Personal Information: Our processing of your Personal Information may relate to Personal Information which has been manifestly made public by you.
- Necessary for the Establishment, Exercise or Defense of Legal Claims: Our processing of your Personal Information may be necessary for the establishment, exercise or defense of legal claims.
- Necessary for Substantial Public Interest: Our processing of your Personal Information may be necessary for reasons of substantial public interest.
- Necessary for Medical Purposes: Our processing of your Personal Information may be necessary for the purposes of preventive or occupational medicine, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services, or pursuant to contract with a health professional.
- Necessary for Substantial Interest in the Area of Public Health: Our processing of your Personal Information may be necessary for reasons of public interest and/or public health.
If your Personal Information is subject to the applicable data protection laws of the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your Personal Information violates applicable law.
- If you are located within the European Economic Area, you may find the contact details of the competent authorities in this link.
- If you are located within the United Kingdom, you may lodge a complaint with the Information Commissioner’s Office (ICO) by clicking here.
If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us by:
- By Mail
Umbra Lab, Inc.
Attn: Privacy
133 E De La Guerra Street #39
Santa Barbara, CA 93101 - By Email
privacy@umbra.space
To ensure that your request is processed swiftly and accurately, please be sure to include the information requested in Section 5(B) of this Privacy Notice.
If you wish to receive a response by email, please be sure to include your name, postal address, and email address. If we do not receive an email address, we will respond by postal mail.
