Right Prose (“Website”), located at https://rightprose.co, is owned and operated by Up In Consulting, LLC, and is governed by the following Privacy Policy.              

We respect your privacy and are committed to protecting it. The purpose of this Privacy Policy is to inform you what personally identifiable information we may collect and how it may be used.

This Privacy Policy applies to information we collect:

• On the Website.
• In email and other electronic messages between you and the Website.
• When you interact with us on other platforms or through advertising, if there is a link to this Privacy Policy.

This Privacy Policy does not apply to:

• Information we collect offline, unless we have specifically indicated the applicability of the Privacy Policy to that information, or
• Information collected by third parties.

WEBSITE IS NOT INTENDED FOR USE OF CHILDREN UNDER 18

The Website is intended for users over the age of 18. If you are under the age of 18, you should cease using the Website. No one under age 18 should provide any information through the Website.

We do not knowingly collect information from any individual under the age of 18. If we learn that we have collected or received information from an individual under the age of 18, without the verified consent of a parent, we will immediately delete the information. If you believe we have unknowingly collected information from an individual under the age of 18, please contact us at admin@upinconsulting.com. 

INFORMATION WE MAY COLLECT

We collect information from and about the users of the Website, including:

• Personal Information: We may collect personal information, which is defined as information that would personally identify you, such as your name and email address. Under certain location-based rights, such as GDPR, this is synonymous with personal data.
• Non-identifying Information: We may collect information about you, but does not identify you personally, such as your browsing habits.
• Technical Information: We may collect information about the technology you are using to access the Website, such as your internet connection, browser, and other usage details.

SENSITIVE PERSONAL INFORMATION

At no time should you submit sensitive personal information to the Website. This includes your social security number, information regarding race or ethnic origin, political opinions, religious beliefs, sexual orientation, health information, criminal background, or trade union memberships. If you elect to submit such information to us, it will be subject to this Privacy Policy.

HOW WE COLLECT INFORMATION

Information You Voluntarily Submit to the Website

We may collect personal information if you voluntarily submit it to the Website, including, but not limited to:

• Making a contribution to the website, such as leaving a comment or rating
• Subscribing to a newsletter or providing your email address to obtain a free resource
• Submitting correspondence to us, such as entering your information into a contact form
• Entering transactions with the Website
• Creating a user profile, which allows you to establish a username and profile

Information We Collect from Others

We may receive information about you from other sources. For example, if you use third-party software through the site, they may transfer information to us for fulfillment.

Automatically Collected Information

We automatically collect certain information about you and the device with which you access the Website. For example, when you use the Website, we will log your IP address, operating system type, browser type, referring website, pages you viewed, and the dates/times when you accessed the Website. We may also collect information about actions you take when using the Website, such as links clicked, or details related to your Website visit.

This automatically collected information does not include personal information, but we may maintain it or associate it with personal information we collect. This helps us improve our Website.

Cookies

We may log information using cookies, which are small data files stored on your browser by the Website. We may use both session cookies, which expire when you close your browser, and persistent cookies, which stay on your browser until deleted, to provide you with a more personalized experience on the Website.

The Website uses cookies to store visitors’ preferences, record user-specific information on what pages users access or visit, ensure that visitors are not repeatedly sent the same banner ads, and customize Website content based on visitors’ browser type or other information that the visitor sends. Cookies may also be used by third parties, as described herein.

You may, at any time, prevent the setting of cookies, by the Website, by using a corresponding setting of your internet browser and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. However, if you deactivate the setting of cookies in your Internet browser, not all functions of our Website may be entirely usable.

Other Tracking Technologies

Some content or applications, including advertising, on the Website are served by third parties, including advertisers, ad networks, or content providers. These third parties may use cookies (alone or in conjunction with web beacons) to collect information about your use of the Website. This may be used to provide interest-based advertising. More information is listed below in the section on Advertising.

HOW YOUR INFORMATION MAY BE USED

We may use the information collected in the following ways:

• To operate and maintain the Website;
• To provide information or services that you request while using the Website;
• To create your account, identify you as a user of the Website, and customize the Website for your account;
• To provide you with notifications regarding your account, such as renewal notices.
• To send you promotional information, such as newsletters. Each email promotion will provide information on how to opt-out of future mailings;
• To send you administrative communications, such as administrative emails, confirmation emails, technical notices, updates on policies, or security alerts;
• To respond to your comments or inquiries;
• To market products through display or affiliate advertisements;
• To market to you on third-party platforms, such as Meta;
• To provide you with user support;
• To track and measure advertising on the Website;
• To process payment for purchases you make through the Website;
• To protect, investigate, and deter unauthorized or illegal activity;
• In any other way described to you at the time your information is collected;
• For any other purpose with your consent.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

If you have an account with us or have registered to use our services, we keep your personal information for as long as you have that account. We keep your information to respond to inquiries, demonstrate completion of our services, and compliance with the law.

We do not retain your personal information for longer than necessary for the reasons we have indicated in this Privacy Policy. When it is no longer needed, we will either delete or anonymize your personal data.

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated or non-identifying information about our users to third parties without restriction.

From time to time, we may share your information with third parties, such as:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties who we use to support the Website, which are further detailed below.
• To our successor or buyer of the Website in the event of a merger, acquisition, sale, liquidation, bankruptcy, or other corporate event which may result in the transfer of the Website.
• To fulfill the purpose that you provided your personal information. For example, if you subscribe to our newsletter, we will share your information with the software provider we use for our mailing list.
• With your consent.

• Circle.so – This service is used to host and manage our online community. When you join the community, your Personal Information, including your name, email address, and engagement activity, will be shared with this Service Provider. Circle.so helps us facilitate discussions, member interactions, and group content sharing. At no time is any sensitive personal or payment information passed back to us through Circle.so, beyond what is necessary for managing your participation and enhancing community engagement.

At this time, your personal information is not shared with any other third-party applications. This list may be amended from time to time in the Website’s sole discretion.

Except when required by law, we will not sell, distribute, or reveal your email addresses or other personal information without your consent; however, we reserve the right to disclose your personal information:

• To comply with a court order or any other legal process.
• To enforce our terms of use and other agreements for billing or collection purposes.
• If we believe it is necessary to protect the rights or safety of our company or third parties.

WEBSITE ANALYTICS

This Website uses Google Analytics 4 (“GA4”) to analyze traffic to the Website. In order to track usage, Google uses a first-party cookie to ensure compliance with privacy regulations.

We may use data from GA4 with Google Ads or Signals, which does include a cookie and may transfer your personal information to these services.

YOUR CONTRIBUTIONS TO THE WEBSITE

If you make certain types of contributions to the Website, such as leaving a comment/rating, certain information may be publicly visible.

Additionally, we may limit access to certain Website content so that it may only be accessed if you have created a user profile. In the case that such content is limited, we make no guarantees that this content will not be publicly visible in some way.

Please ensure that you do not make any contributions to the Website which may contain sensitive information or personal information that you would not wish to be accessible to the public.

YOUR CHOICES REGARDING HOW WE USE AND DISCLOSE YOUR INFORMATION

We aim to provide you with choices regarding the information you provide to us. You can control certain disclosure of information in the following ways. 

Do Not Voluntarily Disclose Your Information

If you do not want to voluntarily disclose your personal information, you may elect not to disclose your information to us.

Tracking Technologies

You may adjust your browser settings to refuse all or some cookies or to alert you when cookies are being sent. 

Display Advertising
We may use third-party advertising companies to serve content and advertisements when you visit the Website, which may use cookies or provide other personal information.

To opt out of display advertising, visit http://optout.networkadvertising.org/. 

Retargeting Ads
From time to time, the Website may engage in remarketing efforts with third-party companies, such as Google, Pinterest, Facebook, or Instagram, in order to market the Website. These companies use cookies to serve ads based on someone’s past visits to the Website. This means, after visiting the Website, you may see an ad for our services. However, your personally identifiable information is not used by any remarketing service other than to present you offers from the Website. We use the following third-party service providers for remarketing:

Facebook: Opt-out of Facebook remarketing here
Google: Opt-out of Google remarketing here
Pinterest: Opt-out of Pinterest remarketing here 

Affiliate Advertising
The Website may engage in affiliate marketing, which is done by embedding tracking links into the Website. If you click on a link for an affiliate partnership, a cookie will be placed on your browser to track any sales for purposes of commissions. 

You may refuse these cookies by adjusting your browser settings. 

Newsletters
On the Website, you may subscribe to our newsletter, which may be used for advertising purposes. All newsletters sent may contain tracking pixels. The pixel is embedded in emails and allows an analysis of the success of online marketing campaigns. Because of these tracking pixels, we may see if and when you open an email and which links within the email you click. Also, this allows the Website to adapt the content of future newsletters to the interests of the user. This behavior will not be passed on to third parties.

You may opt-out of future newsletters at any time by clicking on the “unsubscribe” button.

Residency-based Choices

Residents of or those domiciled in certain locations may have additional rights and choices related to their personal information. Please see the section below. 

RIGHTS RELATED TO YOUR PERSONAL INFORMATION

Certain consumer privacy and data protection laws may provide residents of or those domiciled in certain jurisdictions with additional rights regarding our use of their personal information. The following sections will apply, as stated, to the residents of the particular jurisdiction.

European Union and United Kingdom

If you are domiciled within the European Union or United Kingdom, you are entitled to certain information and have certain rights under the General Data Protection Regulation (“GDPR”) or UK GDPR. Throughout this policy, we have disclosed what information we collect and how it is used. Under these laws, we are a data controller and must provide you with certain information regarding the data we collect, our legal bases for doing so, and your rights related to your data.

Our legal bases for collecting your personal data:

• Consent – We may process information if you have provided us with your consent. This includes all voluntarily captured personal information or any information for which you have given us consent.
• Performance of a contract – We may process your information to perform a contract.
• Legitimate Interest – We have a legitimate interest in capturing information related to marketing activities and fraud prevention. Additionally, we capture information regarding your interactions with the Website to ensure that our Website is operating properly and to allow us to make improvements. We may also keep information regarding your interactions with the Website as a form of recordkeeping. We do not process your personal information on this basis if it is outweighed by the impact such processing may have on you.
• Legal Requirement – We may process your personal information if it is necessary for a legal obligation, such as security.
• Vital Interest – We do not process your personal information on this basis.
• Public Interest – We do not process your personal information on this basis.

Where We Hold Your Data: Generally, your personal information may be held in our offices (including our affiliates or parent companies), third-party companies, data processors or service providers.

You also have the following rights:

• Right to Be Informed – You may be informed as to how we use your personal information. This notice includes much information about this, but you may also inquire with us.
• Right to Access – You may access the personal information we have about you by submitting a request.
• Right to Opt-out – You may opt-out of future email communications by following the unsubscribe links in our emails. You may also contact us at the email below to be removed from our mailing list.
• Right to Amend/Rectify – You may contact us to amend or update your personal information.
• Right to Erase or Be Forgotten – In certain situations, you may request that we erase or forget your personal data.
• Right to Restrict Processing – Similar to the right to erase, you may request that we restrict processing of your personal data.
• Right to Data Portability – You have the right to port your personal data, when applicable.
• Right to Object – In some situations, you may have the right to object to how your personal data is being processed by filing a complaint. 
• Rights related to Automatic Decision Making and Profiling – You may have the right to not be subject to automatic decision making and profiling.

You may exercise any of these rights by emailing admin@upinconsulting.com.

Please note that we may need to retain certain information for recordkeeping purposes or to complete transactions, or when required by law. Unless you exercise such rights, we reserve the right to retain your data.

California Privacy Rights

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act (“CPRA”), California residents have additional rights related to their data. This Privacy Policy has previously disclosed how we collect information, but California requires that we disclose additional information regarding our data collection practices.

Information Collection and Sharing

The Website collects information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). The Website has collected the following categories of Personal Information from you, which are detailed below.

We may share your Personal Information by disclosing it to a third party for a business purpose. We only make these disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Information confidential, and prohibit using the disclosed information for any purpose other than performing the contract. We have disclosed the information listed in the categories below for a business purpose.

We do not sell your Personal Information OR We may also share your personal information by selling it to third parties, subject to your right to opt out of those sales.

In the preceding 12 months, we have completed the activities listed below in the categories covered by CCPA and CPRA.

Identifiers:

This category includes your: real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (“IP”) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

1.  The Website does not collect information in this category.

Personal Information as Described in California Customer Records Statute (CA Code 1798.80):

This includes your: name, signature, social security number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

1. The Website does not collect information in this category.

Protected Classification Characteristics (under California or federal law).

This includes: Age (over age 40), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental health disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, or genetic information.

1. The Website does not collect information in this category.

Commercial Information:

This includes records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

1. The Website does not collect information in this category.

Biometric Information:

This includes: an individual’s physiological, biological or behavioral characteristics, including an individual’s DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity.

1. The Website does not collect information in this category.

Internet or Other Electronic Network Activity Information:

This includes, but is not limited to, browsing history, search history, and information regarding a consumer’s interaction with the Website, application, or advertisement.

1. The Website does not collect information in this category.

Geolocation Data:

This includes your physical location or movements.

1. The Website does not collect information in this category.

Audio, Electronic, Visual, Thermal, Olfactory, or Other Similar Information:

1. The Website does not collect information in this category.

Professional or Employment-related information:

This may include your current or past employment history or other information related thereto.

1. The Website does not collect information in this category.

Education Information:

This is defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act, which includes: records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, schedule, student identification codes, student financial information, or student disciplinary records.

1. The Website does not collect information in this category.

Inferences Drawn from Personal Information:

This includes inferences drawn from the Personal Information collected by the Website to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

1. The Website does not collect information in this category.

Use of Your Personal Information under CCPA and CPRA

All uses of your Personal Information are provided within this Privacy Policy and are incorporated into your rights under CCPA and CPRA.

Rights related to Your Personal Information under CCPA and CPRA

CCPA and CPRA provide California residents with specific rights regarding their Personal Information. This section describes your rights and explains how to exercise those rights.

Right to Access – You have the right to request that we disclose certain information to you about the personal information we collect and how it has been used over the past 12 months. After we receive and confirm your verifiable consumer request, we will disclose the following:

• The categories of your personal information we collected;
• The categories of your personal information we sold;
• The categories of any third parties to whom we have sold your personal information;
• A list of which categories of your personal information we sold to each party; and,
• The categories of your personal information we disclose for business purposes.

Right to Deletion – You have the right to request that we delete your personal information.

Please note that this right does not apply when we need to retain your personal information to do the following:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.

Right to Non-Discrimination – You have the right not to be discriminated against for exercising your rights under CCPA. In particular, we may not:

• Deny you goods or services;
• Charge you different prices for goods or services, whether through denying benefits or imposing penalties;
• Provide you with a different level or quality of goods or services; or,
• Threaten you with any of the above.

How to submit a verifiable consumer request

To exercise these rights, you must submit a verifiable consumer request to us by:

• Contacting us at admin@upinconsulting.com.

Please note that only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a request on behalf of a minor child.

You may only make a request under these rights twice in a twelve-month period. Your verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information (or that it is an authorized representative acting on your behalf);
• Describe your request with sufficient detail that allows us to properly understand and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email admin@upinconsulting.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding receipt of your request.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Additional State Privacy Rights

Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia each provide (now or effective in the future) their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Data portability.
• Opt-out of personal data processing for:
  • Targeted advertising and sales (excluding Iowa);
  • Sales; or
  • Profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah)

• Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose (excluding Iowa and Utah).
• Either limit (or opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary state by state. To exercise any of these rights, please email admin@upinconsulting.com. To appeal a decision regarding a consumer request, please email admin@upinconsulting.com.

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to admin@upinconsulting.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

Nevada Online Privacy Law

Pursuant to the Nevada Online Privacy Law (“OPL”), Nevada residents may opt out of the sale of any personal information. As described above, your personal information may be shared with third-party service providers/operators in order to fulfill purchased products or to communicate with you. We do not sell (which is defined in the OPL as “the exchange of covered information for monetary consideration by the operator to a person for the person to license or sell the covered information to additional persons”) your covered information, which includes: your first and last name; your address; your email address; your phone number; your social security number; any identifier that would allow you to be contacted either physically or online; or, any other information concerning you, collected from you by the Website and maintained by us, in combination with an identifier in a form that makes the information personally identifiable.

CONTACT INFORMATION

At any time, please contact us at admin@upinconsulting.com for questions related to this Privacy Policy.

Please carefully review this Privacy Policy so you understand how we may use your personal information. If you do not agree with this Privacy Policy, your choice is to not use the Website. By accessing the Website, you are agreeing to the terms set forth in this Privacy Policy.

From time to time, we may make changes to this Privacy Policy. If you continue to use the Website after such changes are made, it will be considered your acceptance of the changes.

This policy was last updated on November 1, 2024.