PRIVACY POLICY

Last modified: March 29th, 2024

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Bardini Studio Architecture, an Italian professional limited liability company (the “Company”, “We”, or “Us”) respect your privacy and are committed to protecting it through our compliance with this website privacy policy (the “Privacy Policy”).

This Privacy Policy describes the types of information that we may collect from you or that you may provide when you visit the website: https://www.theupstudio.com/ (our “Website”) and our practices for collecting, using, maintaining, transmitting, protecting, and disclosing such information.

This Privacy Policy applies to information we collect:
• in email, text, and other electronic messages between you and the Company or through links to the Website; and
• through social media pages controlled by us or that we interact with; and

This Privacy Policy shall not apply to information collected by:
• Us offline or through any other means including, without limitation, on any other website operated by Company or any third party; or
• Any third party, including information collected by any third party through any application or content that may link to or be accessible from or on the Website.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, YOU DO NOT HAVE OUR PERMISSION TO USE OUR WEBSITE. BY ACCESSING OR USING THIS WEBSITE, YOU AGREE TO THIS PRIVACY POLICY. WE MAY UPDATE, REVISE OR MODIFY ALL OR A PORTION OF THIS PRIVACY POLICY FROM TIME TO TIME (SEE CHANGES TO OUR PRIVACY POLICY). YOUR CONTINUED USE OF THIS WEBSITE AFTER WE MAKE SUCH UPDATES, REVISIONS OR MODIFICATIONS IS DEEMED TO BE ACCEPTANCE OF SUCH UPDATES, REVISIONS OR MODIFICATIONS; SO, IT IS IMPERATIVE THAT YOU CONSULT THE PRIVACY POLICY PERIODICALLY FOR UPDATES.

1. This privacy policy explains:
a. Websites Covered by This Privacy Policy
b. Changes to Our Privacy Policy
c. Contact Information
d. Types of Information We Collect
e. How We Use Your Information and Who We May Share It With
f. Third-Party Links & Content
g. Security and Data Location
h, WHAT ARE YOUR PRIVACY RIGHTS?

2. WEBSITES COVERED BY THIS PRIVACY POLICY.

a. Our Website may from time-to-time link to third-party websites for your convenience and to provide easy access to additional useful information. Should you select such a link you will leave the Website. We do not control those sites nor their privacy practices, which may differ from our practices and policies. Any personal data you choose to provide to or that is collected by such third parties is not in any way covered by this Privacy Policy. We recommend that you read over such website’s privacy policy before providing any personal information. A link to another website from Us does not constitute an endorsement or representation about the value, quality, or usefulness of anything found on that third-party website.

b. Throughout this policy, when we refer to “Websites,” we mean all Company affiliated or controlled websites and any other microsites or mobile websites we operate or use. “Social Media Pages” are the official social media pages we operate on Facebook, X (formerly known as Twitter), Instagram, LinkedIn, and other social media platforms.

c. PLEASE BE AWARE THAT IF YOU ELECT TO HAVE US SHARE YOUR INFORMATION WITH THIRD PARTIES, THOSE ELECTIONS TO HAVE YOUR INFORMATION SHARED WILL SUPERSEDE ANYTHING TO THE CONTRARY IN THIS PRIVACY POLICY.

3. CHANGES TO OUR PRIVACY POLICY.

a. We reserve the right to amend this privacy notice at our discretion and at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website home page. The date the Privacy Policy was last revised is identified at the top of the page. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
b. PLEASE NOTE THAT FOR CALIFORNIA RESIDENTS THE CALIFORNIA CONSUMER PRIVACY ACT OF 2018, AS REVISED BY THE CALIFORNIA PRIVACY RIGHTS ACT OF 2020 (“CCPA”) WILL GOVERN OUR USE AND YOUR RIGHTS WITH REGARD TO YOUR PERSONAL INFORMATION.

4. TYPES OF INFORMATION WE COLLECT.

a. When you access our Website, we collect several types of information from and about users of our Website, depending on the context of your interactions with Us and the Website (“Personal Information”), including information:
(i) by which you may be personally identified, such as: name, e-mail address, telephone number, ZIP code/postal code, or other additional information supplied by you, by which you may be contacted online or offline.
(ii) aggregated information about people who visit and interact with our Social Media Pages. “Aggregated” means information that regards you but does not include your personal information or otherwise is specifically associated with you.
(iii) If you call, email, text, or chat with our customer service agents, we may keep records of those conversations.

b. We collect this information:
(i) directly from you when you provide it to us;
(ii) automatically as you navigate through the site, or use our services. Information collected automatically may include usage details, IP addresses, and information collected through cookies.

5. INFORMATION YOU PROVIDE TO US.

a. The information we collect on or through our Website may include, but is not limited to:
(i) information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, and services requested; and
(ii) records and copies of your correspondence (including email addresses and related contact information) if you contact us;

b. We may take your personal information and de-identify it so as to make it non-personally identifiable, either by combining it with information about other individuals and/or by hashing the information or otherwise removing characteristics that make the information personally identifiable directly to you. We will treat de-identified information as non-personal to the fullest extent allowed by applicable law.

6. SOCIAL NETWORKING FEATURES.

a. Functionality on the Website may permit interactions between the Website and a third-party service such as Facebook, X (formerly known as Twitter), Instagram, LinkedIn, and other social media platforms (“Social Networking Features”). Examples of Social Networking Features include enabling you to “like” or “share” content from the Website or to “like” or “share” our page on a third-party service; to automatically or selectively show your social media posts on the Website; and to otherwise connect the Website to a third-party service. If you choose to share content or to otherwise post information through the Website to a third-party service, or vice versa, that information may be publicly displayed. Similarly, if you post information on a third-party service that references us (for example, by using a hashtag associated with us in your post), your post may be published on the Website or otherwise in accordance with the terms of that third party. Also, both we and the third party may have access to certain information about you and your use of the Website and the third-party service. These third-party social networking companies may collect information about your visit to a Platform through the Social Networking Features we have integrated into the Platform, and - if you are signed into your account with such a third-party social networking company – it may collect additional information in accordance with the terms of your agreement with that company. In addition, we may receive information about you if other users of a third-party service give us access to their profiles and you are one of their “connections” or information about you is otherwise accessible through your profile or similar page on a social networking or other third-party service. The information we collect in connection with Social Networking Features is subject to this Privacy Policy. The information collected and stored by the third party remains subject to the third party’s privacy practices, including whether the third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that third-party service.

b. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

7. INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES.

a. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
(i) details of your visits to our Website, including traffic data, location data, logs, and other communication data, and the resources that you access and use on the Website; and
(ii) information about your device and internet connection, including your IP address, operating system, and browser type.


b. The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with the personal information that we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
(i) estimate our audience size and usage patterns; and
(ii) to protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (e.g., for fraud monitoring and prevention).


c. The technologies we use for this automatic data collection may include:
(i) Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. These technologies are able to store a unique identifier for a device to allow a certain Internet site to recognize the device whenever the device is used to visit the site. These technologies may be used for many purposes by us and our third-party service providers, such as automatically collecting Usage Information, enabling features, remembering your preferences, and providing you with targeted advertising elsewhere online. If you do not want to accept cookies, you can block them by adjusting the settings on your Internet browser. You can find more information about cookies and how they work at www.allaboutcookies.org.
(ii) Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
(iii) Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
(iv) Web Browsers. Certain browsers, or browser add-ons, may provide additional local data storage mechanisms that are used in a manner similar to cookies, and some of the content included on our Platforms may make use of this local storage. If you choose to disable cookies, or to otherwise restrict local storage, some features of the Platforms may not function properly, including the shopping cart and ordering processes.
(v) Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Platforms, such as the links you click on. The code is temporarily downloaded onto your device from our server or a third-party service provider, is active only while you are connected to a Platform and is deactivated or deleted thereafter.

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources, or you provide to us.

8. DO WE COLLECT INFORMATION FROM MINORS?

Our Website is a general audience point of contact and is not directed to children under the age of thirteen (13). Further, we do not knowingly solicit data from nor market to children under eighteen (18) years of age. By using the Website, you represent that you are at least eighteen (18) years of age or that you are the parent or guardian of such a minor and have consented to such child’s direct use of the Website.

9. WHAT CATEGORIES OF PERSONAL INFORMATION DO WE COLLECT?

a. We have collected the following categories of personal information in the past twelve (12) months:
(i) Identifiers. Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, device identifier, date of birth (or partial DOB such as birth day and month), Internet Protocol address, email address and account name; or other similar identifiers.
(ii) Internet or Other Similar Network Activities. This includes browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements. This category includes: the hardware model, browser, and operating system you are using; the URL or advertisement that referred you to the Website you are visiting; all of the areas within the Website that you visit; devices you have used to access the Website; your time zone; location information based off your IP address; and mobile network (if applicable).
(iii) Geolocation data. This includes device location, Physical location, or movements that we can collect through your use of our Website.
(iv) Inferences Drawn From Other Personal Information. Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitude.

b. Personal information does not include: Publicly available information from government records, deidentified or aggregated consumer information.

c. We may also collect other personal information outside of the specified categories in instances where you interact with us in-person, online, or by phone or mail in the context of facilitation in the delivery of our Services and to respond to your inquiries.

10. HOW WE USE YOUR INFORMATION.

a. General Use.

(i) The information We collect about you or that you provide to us, including any personal information, is used to comprehensively understand your needs and interests, and permit Us to deliver a more consistent and personalized experience. For example, We may use your information:
(A) To present our Website and its contents to you;
(B) To provide you with information or services that you request from us;
(C) To carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
(D) To notify you about changes to our Website or any services we offer or provide though it;
(E) To allow you to participate in interactive features on our Website;
(F) To provide personalized promotional offers and select content to be communicated to you; 
(G) To detect, prevent and remediate fraud or other potentially prohibited or illegal activities; and/or
(H) For any other purposes with your consent.

b. We may use the information we collect for the following business purposes:
(i) Understanding You. Analyzing your activity with us (including your interactions with our affiliated websites, emails or other forms of communication) and monitoring the effectiveness of our advertising and communications.
(ii) Personalization. Using your preferences and other collected information to personalize our relationship with you, including presenting customized communication, advertising, emails, and ads on Social Media.
(iii) Communications. Communicating with you, including responding to your requests or other messages.
(iv) Your Experience. Serving content on our Website, developing our services, better understanding your needs and preferences, and constantly improving your experience.

c. Credit Cards/Electronic Payments. Credit card and electronic payment information is used solely for payment processing and fraud prevention efforts. Credit card information, and other sensitive personal information required to process a credit decision, is not used for any other purposes by us or our financial services providers, and will not be retained any longer than necessary to provide your services.

11. WITH WHOM WE SHARE YOUR DATA AND HOW IT IS USED.

a. Consent. We may process your data if you have given us specific consent to use your personal information for a specific purpose.

b. Legitimate Interests. We may process your data when it is reasonably necessary to achieve our legitimate business interests.

c. 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.

d. Legal Obligations. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

e. Vital Interests. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

f. More specifically, we may need to process your data or share your personal information in the following situations:
(i) 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.
(ii) Consultants and Other Third-Party Service Providers. We partner with third parties to assist with many aspects of our business, including fulfilling advertising, analyzing your interests and activity on our Website, and helping us communicate with customers. We may share your data with third-party service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect data on our behalf about how you interact with our Website over time.

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12. SECURITY AND DATA LOCATION.

a. Security Measures.
(i) We have implemented appropriate technical and organizational security measures designed to protect and secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.
(ii) 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. Although we do our best to protect your Personal Information, we cannot guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information transmitted to our Website. Although we will do our best to protect your personal information, any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. You should only access the Website within a secure environment.

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DPR CONSUMER PRIVACY RIGHTS NOTICE

ADDITIONAL NOTICE FOR EUROPEAN UNION (EU) RESIDENTS

This GDPR Consumer Privacy Rights Notice supplements the information contained in the Privacy Policy of DH Murray Architecture, PLLC, a New York professional limited liability company (“Company”, “We”, or “Us”) and applies solely to all visitors, users, and others who reside in the European Union (“EU”) (“Consumers” or “You”). We adopt this notice to comply with the General Data Protection Regulation (“GDPR”) and any terms defined in the GDPR have the same meaning when used in this Notice. This notice explains what information we collect about you, how that information is used, who receives this information, the circumstances in which such information is shared and the steps taken to maintain this information private and secure. If you are not resident of the EU, please refer to our privacy policy included on the first page of this document.

1. How We Collect and Use Personal Data.
a. We collect Personal Data from natural persons who are residents of the EU as described below.
(i) The types of Personal Data we collect:
(A) Identifiers: Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, device identifier, Internet Protocol address, email address and account name; or other similar identifiers.
(B) Personal Data in Customer Records: Includes any information that identifies, relates to, describes, or is capable of being associated with a particular consumer or household, including, the “identifiers” listed in (A), and the following: signature, physical characteristics or description, or any other information when and to the extent that you provide it to us directly or through third parties.
(C) Legally Protected Characteristics: Includes date of birth/age, gender, race, color, national origin, citizenship, marital status, physical or mental disability, and veteran or military status, when and to the extent that you provide it to us directly or through third parties.
(D) Internet or Network Activity: Includes, but is not limited to, browsing history on our websites, search history, information on a consumer’s interaction with our websites or applications.
(E) Geolocation Data: Includes information such as physical location or movements.
(F) Inferences from above used to Profile: Includes inferences drawn from other Personal Data, such as profiles reflecting a person’s preferences, behavior, attitudes, abilities, and aptitudes. The Company does not operate a website directed towards children or has actual knowledge that the bank is collecting or maintaining personal information from children online.

b. Sources from which we obtain your Personal Data:
(i) For each of these categories,* we obtain your Personal Data from a variety of sources, including from:
(A) our customers and consumers, with respect to both online and offline interactions you may have with us or our service providers and other entities with whom you transact;
(B) others with whom you maintain relationships who may deal with us on your behalf;
(C) the devices you use to access our websites, mobile applications, and online services;
(D) credit bureaus;
(E) identity verification and fraud prevention services;
(F) marketing and analytics providers;
(G) public databases;
(H) social media platforms; and
(I) other sources consistent with this Privacy Policy.
*Please note that the categories of Personal Data we collect about consumers will vary based on our relationship or interaction with those individuals.

c. Legal basis for processing:
(i) Depending on the purpose of the processing activity (see Section 2(d)), the legal basis for the processing of your personal data will be one of the following:
(A) necessary for taking steps to enter into or executing a contract with you for the services or products you request, or for carrying out our obligations under such a contract, such as when we use your data for some of the purposes in Section 2(d) (as well as certain of the data disclosures described in Section 2(e));
(B) required to meet our legal or regulatory responsibilities, including when we conduct the client on-boarding processes and make the disclosures to authorities, regulators and government bodies;
(C) in some cases, necessary for the performance of a task carried out in the public interest;
(D) necessary in order to protect the vital interests of the data subject or of another natural person;
(E) in limited circumstances, processed with your consent which we obtain from you from time to time (for instance, where required by laws other than the GDPR), or processed with your explicit consent in the case of special categories of Personal Data such as your medical information; and
(F) necessary for the legitimate interests of the Company, without unduly affecting your interests or fundamental rights and freedoms.
(ii) Where the Personal Data we collect from you is needed to meet our legal or regulatory obligations or enter into an agreement with you, if we cannot collect this Personal Data, there is a possibility we may be unable to on-board you as a client or provide products or services to you (in which case we will inform you accordingly).

2. How we use your Personal Data.
a. At the time you submit Personal Data or make a request, the intended use of the information you submit will be apparent in the context in which you submit it and/or because the Company states the intended purpose. The Company needs to collect, process and use Personal Data for a number of purposes. A primary purpose is to ensure we can provide customers with the products and services we offer and which they have requested. We also need to use Personal Data for purposes of carrying out our business operations, including confirming a person’s authority as a representative or agent of a customer, maintaining business continuity plans and processes, undertaking internal investigations and audits, handling legal claims, responding to requests form supervisory authorities, and complying with applicable laws and regulations.
b. We use the Personal Data we collect, as identified in the categories listed in Section 2(a) above, for the business purposes listed below:
(i) Financial, Legal and Compliance Management: Audits, accounting, and supporting our everyday operations, including to meet risk, legal, and compliance requirements;
(ii) Fraud Prevention: Reporting, evaluating and monitoring particular transactions and interactions, including online interactions, you may have with us or others on our behalf;
(iii) Security: Detecting and protecting against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecuting the same;
(iv) IT Operations: Debugging to identify and repair errors in our systems;
(v) Marketing/Prospecting: Short-term, transient use, including contextual customization of ads; conducting marketing and surveys associated with our products and services;
(vi) Customer Services: Providing services on your or our behalf, or on behalf of another, including maintaining or servicing accounts, providing customer service, fulfilling transactions, verifying identity information, processing payments, and other services;
(vii) Research: Conducting internal research to develop and improve technology;
(viii) Improving Products and Services: Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide;
(ix) Operation of our Sites: Preparing statistics, analyzing traffic patterns and performing analysis to support our operations; and
(x) Legal Proceedings: Receiving and responding to law enforcement requests, to prepare for or in support of ongoing litigation and as required by applicable law, court order, or governmental regulations.
c. We may also use the Personal Data we collect for:
(A) other operational processes,
(B) purposes for which we provide you additional notice, or
(C) purposes compatible with the context in which the Personal Data was collected.

3. Sharing of Personal Data.
a. When providing products or services to you, we will share Personal Data with other Company subsidiaries in order to ensure a consistently high service standard across our group, and to provide services and products to you.
b. In some instances, we also share Personal Data with our service providers, which provide services to us, such as IT and hosting providers, marketing providers, appraisers, adjusters, debt collectors fraud prevention providers, credit reference agencies, and others. For more information on the service providers with whom we share information, please see Reasons we can share your personal information. Whenever we disclose Personal Data, we execute a contract that describes such purpose and require the recipient to keep the Personal Data confidential and prohibit its use for any purpose other than to perform the obligations under the contract. When we do so, the Company requires such recipients to comply with appropriate measures designed to protect your Personal Data, including through contractual arrangements.
c. If required from time to time, we disclose Personal Data to public authorities, regulators, or governmental bodies, including when required by law or regulation, under a code of practice or conduct, or when these authorities or bodies require us to do so.
d. If our business or assets were sold to another party, Personal Data will be transferred as part of the transaction. The Company may also share Personal Data with prospective purchasers during the due diligence process related to the prospects of selling or transferring part of, or an entire business. The Company requires such recipients to comply with confidentiality, privacy, and other legal requirements and in response, follow security measures designed to protect your Personal Data.
e. We will disclose Personal Data when legally required, to exercise or protect legal rights, including ours and those of our employees or other stakeholders; or in response to requests from you or your representatives.

4. Transfer of Personal Data to Different Countries. We do business with service providers around the world and, in some instances, may transfer Personal Data to such providers in the course of doing business with them. These providers assist us with certain operations and activities. In those cases, the Company requires such recipients to comply with appropriate measures designed to protect your Personal Data, including through contractual arrangements.

5. How We Secure Personal Data. We implement appropriate technical and organizational measures to address the risks corresponding to our use of your Personal Data, including loss, alteration, or unauthorized access to your Personal Data. We require our service providers to do the same through contractual agreements.

6. How Long We Keep your Personal Data. We will retain your Personal Data for as long as it is needed or permitted in light of the purposes in Section 2(d). The criteria used to determine our retention periods include:
(i) the length of time we have an ongoing relationship with you;
(ii) whether there is a legal or regulatory obligation to which we are subject; and
(iii) whether retention is advisable in light of our legal or regulatory obligation (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

7. Your Data Protection Rights.
a. Laws in the EU enable individuals to have appropriate control and oversight over what organizations do with your Personal Data.
b. The following are your Personal Data rights:
(i) The right to be informed about our processing of your Personal Data.
(ii) The right of erasure (right to be forgotten), which allows you to ask us to destroy your Personal Data if you believe we no longer need it, or we are using it inappropriately. However, we may continue to retain your information if we are entitled or required to retain it.
(iii) The right to data portability, which includes the right to receive Personal Data you have provided to us in a structured, commonly used, and machine-readable format.
(iv) The right of access to data that has been collected and that we process. You may ask us for a description of the Personal Data we hold and the purposes for holding it. You may ask for a paper or electronic copy of this information.
(v) The right to rectify or correct data if it is inaccurate, or to have incomplete data completed.
(vi) The right to restrict processing when you contest data accuracy, when you believe our use is unlawful, or when you wish for us to keep but not use Personal Data beyond our time limit for storage, for purposes as described above in Section 2(d).
(vii) The right to lodge complaints with a data protection authority regarding any processing by us or on our behalf.
(viii) The right to object extends to direct marketing when Personal Data is processed for direct marketing purposes, including profiling to the extent it is related to such marketing. You may object to direct marketing by clicking the “unsubscribe” link in any of our emails to you or by emailing us at whatsup@theupstudio.com at any time.
c. The Company will seek to obtain your consent where required by applicable law. We may analyze users’ online activities, interests, and preferences in order to provide our services, such as to configure our online channels and apps for a better experience, and/or for marketing purposes. Where we process your Personal Data on the basis of your consent, you have the right to withdraw that consent at any time subject to applicable legal obligations. Please also note that the withdrawal of consent shall not affect the lawfulness of processing, based on consent before its withdrawal.

8. How to Revoke Your Consent to Our Use of Your Personal Data and Submit Privacy Related Inquiries.
a. You can direct all requests relating to access, correction, and other legal rights regarding Personal Data, or any questions regarding this Notice, by emailing us at whatsup@theupstudio.com.
b. We try to respond to all authenticated requests in relation to your legal rights within one month. Occasionally it may take us longer than a month to respond, if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
c. You may also submit a general privacy related inquiry in accordance with applicable laws and regulations. We will respond to such requests in accordance with applicable laws.
d. Please issue such requests by sending a completed inquiry to us via email at whatsup@theupstudio.com. Please provide your name and contact information along with your inquiry.

9. Changes to Our Privacy Notice. We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

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