Privacy Policy


Introduction and Scope 

Be Social YYC Inc. ("UPWEGO", "we", "us", and "our") considers matters relating to the protection of your personal information and your privacy to be extremely important.  Trun our business and to manage our relationship with you, we will need to collect, store, use, and disclose some of your personal information.  We have developed this privacy policy (the "Privacy Policy") to tell you how your personal information will be collected, used and disclosed.  This Privacy Policy applies to UPWEGO, its website and all related mobile apps, desktop apps, and application software interfaces (the "Platform") and the services offered by us ("Services").  This Privacy Policy does not apply to the privacy practices of third parties (including the businesses we partner with, referred to as "Teammates" on the Platform) who may also collect or receive data in connection with your use of the Services or the Platform. That said, we have included information about how the Platform and the Services interact with certain third parties whose services integrate with, or are used by, the Platform 


In this Privacy Policy, "you" and "your" mean you, provided you have created an account on the Platform, provided any information to us or used any Services.  Your use of the Services and the Platform is governed by our terms of use (the "Terms of Use"), found at https://upwego.ai/terms-of-use. If you don’t agree with our privacy practices, and the personal information we may collect, use and disclose as described in this Privacy Policy, then you may not use the Platform or the Services. 


1. General 

We will only collect, use and disclose your personal information as permitted by law.  Usually this means that we ask for your consent for the collection, use and disclosure of your personal information for a particular purpose.  However, in some limited situations your consent is not required (for example, where the collection, use or disclosure of the information is reasonable for an investigation or legal proceeding, or where a law authorizes or requires the collection, use or disclosure of personal information without consent).  UPWEGO may collect, use and disclose your personal information without your consent or knowledge in those limited types of situations. 


We are not responsible for third parties' (including our Teammates') privacy practices or the information they collect, use or disclose.  When you use a third party's services, that party's privacy practices and policies will govern your use of those services. 


We may change this Privacy Policy from time to time.  If we change how we use personal information, we will notify you by posting an announcement on the Platform or sending you an email. Users are bound by any changes to the Privacy Policy when they use the Platform or our Services after such changes have been posted. 


2. Personal Information We Collect and How We Collect It 

We collect personal information primarily to provide our online marketplace and related services on our Platform, including: name, address, date of birth, email address, phone number, credit card or other payment information, company name, and for representatives of our Teammatesinformation about their business/revenue ideas, profile picture, and banking information. 


When you use the PlatformUPWEGO automatically receives and records certain information on our server logs from your browser or mobile platform, including: your IP address; cookies; click history; geographical location; geographic locations you provide to us; geographic areas derived from your IP address; device; internet browser and operating system; device identifiers; domain name; access times; the duration of visit; posts to forums, transcripts of chats with support agents, and other interactive features on the Platform; and signups for training and certification or ordering. 


We use cookies on the Platform. Cookies are small data files stored in your web browser’s cache. Cookies allow a website or a third party to recognise your browser or device, by including your IP address or unique device identifier. We may use cookies as part of our authentication processes, to customize your experience on the Platform, and to gather performance data and analytics to help us improve the Platform and the Services. 


We receive and store information from third parties that interact in some way with the Platform—for example, Dynamicweb provides information to the Platform, so we can provide customer management and ecommerce services through the Platform, Avalara provides tax processing services to the Platform, and Google, Facebook, and Instagram collect information for UPWEGO advertising. 


Unless otherwise required or permitted by law or unless otherwise explained in this Privacy Policy: (i) we will only collect your personal information directly from you, and (ii) when we collect your personal information we will tell you about the ways we plan to use and disclosure your personal information.   


3. Use 

We will use personal information you provide only for purposes consistent with the reason you provided it. UPWEGO will use your personal information: to provide our services on the Platform; to communicate and manage our relationship with you, including by sending you service or support messages, updates, security alerts, and account notifications; to verify information you have sent us; to provide advertising about related services that may interest you; to personalize your experience on the Platform; and, to improve our Services, the Platform and our users' experience 


We, our integration partners, and our service providers receive information through our Services. This information may include information about your activity on the Services or on unaffiliated websites and apps, including information received from a web browser, operating system, or device (including such things as the web address of a web page visited, the address of the referring or exit web pages, and the time and date of those visits; information about the browser type and browser settings; information about the operating system, device model, and carrier; location information; IP addresses; and cookie information, pixels or other similar technology).  


We will keep your personal information for as long as we need it: as we run our business, to manage our relationship with you, and for other essential purposes, such as meeting our legal obligations. 


4. Disclosure 

UPWEGO works with, and may share your personal information with, the following: 

  • Teammates: contact and shipping information (if applicable), to enable a Teammate to fulfill orders for products or services you make through the Platform 

  • Third party integration partners or other service providers to the Platform 

  • Cookie information, so the integrator or service provider can distinguish between different visitors from the same IP address, and to customize your experience;  

  • Email address, if you ask to join a mailing list 

  • Payment and address information, to allow users to pay for their goods and services: full name, billing address, name on the card, credit card number, card expiry, card security code 

  • Google Analytics: geographical location, device, internet browser and operating system, IP address, Google Tag Manager data (snippet of code that helps track user behavior across websites) 


UPWEGO may work with other organizations towards some common purpose consistent with our business.  UPWEGO may need to disclose your personal information to these organisations.  In those casesUPWEGO will require that these other organizations agree to follow this Privacy Policy and that they will only use and disclose your personal information as they need to for the common purpose. 

We may provide aggregate or anonymous information to our partners, such as statistics based on member sign ups, member usage, views and impressions, so that our partners may also understand how often people use their services and our Services. 


In certain circumstances we may disclose your personal information without obtaining your further consent, including to comply with laws about importing and exporting goods and services. 


If UPWEGO transfers or is considering transferring control of its operations to another organization, UPWEGO may transfer and disclose your personal information to that organization, for the limited purpose of enabling the parties involved in the proposed transfer to evaluate and complete the transfer.  In those cases, UPWEGO will require that the organization receiving the disclosed personal information agrees that it will follow Privacy Policy and that it will only use or disclose your personal information as we may under this Privacy Policy. 


We may engage other service providers to assist us in our activities, including legal counsel, accountants, auditors, investment advisors and information technology service providers.  It may be necessary for us to disclose your personal information to these service providers in some circumstances.  When we provide personal information to services providers, we require those services providers to protect the information in the same ways we do. These service providers may not use your personal information for any purpose other than the reason you provided it to us. 


5. Choices 

You have certain choices relating to your personal information we collect and use.  You may manage your browser settings to control how much of certain types of information are shared with UPWEGO, including through cookies.  You may also choose not to participate in certain aspects of the Platform, including: receiving marketing emails; using our third party integrated services, such as Dynamicwebor, providing reviews or otherwise posting information on the Platform. For further information about our Teammates', third party integration partners', and service providers' privacy policies and your choices relating to them, please contact the applicable party directly. 


You may request that we provide you with access to the personal information that we hold about you. You may ask us to correct any errors or delete any of the information we have about you.  We note, however, that your ability to exercise these choices is not absolute. In some circumstances (for example, if the information is protected by legal privilege or if the information was collected for an investigation or legal proceeding), we may deny some requests. Also, to protect your privacy and the privacy of others, we may have to verify that you are who you say you are before we can give you access to, or change, information about you.


6. Data Security 

The security of your personal information is important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, and disclosure. 


The safety and security of your information also depends on you. Where we have given you (or you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping it confidential. We ask you not to share your password with anyone. 


7. How to Contact Us 

You may contact us, to ask questions or exercise choices relating to this Privacy Policy, as follows: 

Privacy Officer: Joanna Radaczynski 

Email: Privacy@UPWEGO.ai 



Effective as of November 25, 2020 

V: 10660899.2