Privacy Policy

Effective April 2021, Updated April 2023

At Universal Tennis LLC (“UT,” “we,” “us,” “our”), we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal information. By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

Remember that your use of UT’s Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.  

You may print a copy of this Privacy Policy. If you have a disability, you may access this Privacy Policy in an alternative format by contacting our support team. 

Privacy Policy Table of Contents 

What this Privacy Policy Covers 

Personal Data 

- Categories of Personal Data We Collect 

- Categories of Sources of Personal Data 

- Our Commercial or Business Purposes for Collecting Personal Data 

How We Share Your Personal Data

Data That Is Not Personal Data

Tracking Tools, Advertising and Opt-Out 

Data Security

Data Retention

Personal Data of Children 

California Resident Rights 

Other State Law Privacy Rights 

European Union and United Kingdom Data Subject Rights 

Changes to this Privacy Policy 

Contact Information

What this Privacy Policy Covers 

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Personal Data 

Categories of Personal Data We Collect 

This chart details the categories of Personal Data that we collect and have collected over the past 12 months: 

Universal Tennis Privacy Policy details

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

You

When you provide such information directly to us. 

  • When you create an account or use our interactive tools and Services.
  • When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
  • When you send us an email or otherwise contact us.

When you use the Services and such information is collected automatically.

  • Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
  • If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
  • If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.

Public Records

  • From the government or other sources with results such as tennis federations.

Third Parties

Vendors

  • We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
  • We may use vendors to obtain information to generate leads and create user profiles.

Advertising partners

  • We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications.

Social Networks

  • If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.

Users and Clubs

  • If you are a providers such as a club, college or coach that has elected to adopt UT’s Pro and/or Premium products or services (the “Club”), we may ask you during the onboarding process or through your use of the Services to provide us with the first name, last name, and email addresses of your individual club members (“Club Member Information”) for the purpose of registering these members within the Club’s page on the Services and pursuant to this Privacy Policy. We will not distribute, sell, or rent such Club Member Information, or use such Club Member Information in any way that is not described in this Privacy Policy. By providing us with any Club Member Information, you represent and warrant that you have obtained all necessary rights and consents from each such Club member to provide us with his or her Club Member Information and to allow us to use his or her Club Member Information in accordance with the terms of this Privacy Policy. You may also invite your individual Club members to use and register for our Services by distributing to those individuals the specific codes/links provided to you by UT. It is your responsibility to maintain and monitor the accuracy of a list of those individuals to whom you have distributed such codes/links. Any individual or Club member who has registered for our Services may choose at any time to remove his or her Club Member Information from the Service by sending a removal notice to support@universaltennis.com.

Our Commercial or Business Purposes for Collecting Personal Data

  • Providing, Customizing and Improving the Services
    • Creating and managing your account or other user profiles.
    • Processing orders or other transactions; billing.
    • Providing you with the products, services or information you request.
    • Calculating your rating.
    • Meeting or fulfilling the reason you provided the information to us.
    • Providing support and assistance for the Services.
    • Improving the Services, including testing, research, internal analytics and product development.
    • Personalizing the Services, website content and communications based on your preferences.
    • Doing fraud protection, security and debugging.
    • Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the "CCPA").
  • Marketing and selling the Services
  • Corresponding with You
    • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about UT or the Services.
    • Sending emails and other communications according to your preferences or that display content that we think will interest you.
  • Meeting Legal Requirements and Enforcing Legal Terms
    • Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
    • Protecting the rights, property or safety of you, UT or another party.
    • Enforcing any agreements with you.
    • Responding to any claims that any posting or other content violates third-party rights.
    • Resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for  materially different, unrelated, or incompatible purposes without providing you notice. If you are a California resident, please note that we only use or disclose your sensitive personal information for the purposes set forth in section 7027(m) of the CPRA regulations and we do not collect or process sensitive personal information with the purpose of inferring any characteristics about California residents.


How We Disclose Your Personal Data

We disclose your Personal Data to categories of service providers and other parties listed in this section.

Depending on national and/or state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

  • Service Providers. These parties that help us provide the Services or perform business functions on our behalf. They include:
    • Hosting, technology and communication providers.
    • Security and fraud prevention consultants.
    • Support and customer service vendors.
    • Payment processors.
    - If you elect to purchase and/or provide any paid services (one-time and/or on a recurring subscription basis), you will enter into an agreement with our payments partner, Stripe, Inc., for the payments service and Stripe's use of your data.
    - Please review the Stripe Privacy Policy (https://stripe.com/privacy), which will apply to you.
  • Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include:
    • Marketing providers.
    • Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
    • Companies that track how users found or were referred to the Services.
    • Companies that track how users interact with the Services.
  • Affiliates. These are our corporate affiliates.
  • Business Partners. These parties partner with us in offering various services. They include:
    • Businesses that you have a relationship with.
    • Companies that we partner with to offer joint promotional offers or opportunities or joint marketing campaigns.
    • Resellers and integrators, including, for example, third party platforms we may integrate our rating system with or who may receive our match score data feeds.
    • Other associations you are affiliated with or in the territory where you reside.
  • Parties You Authorize, Access or Authenticate
    • Third parties you access through the services.
    • Social media services.
    • Other users.
    • If you are a participant in the UTR Pro Tennis Tour, we may share your Personal Data with other third parties as described in the contract executed between you and UT in connection with the UTR Pro Tennis Tour.

Legal Obligations and Anti-Corruption Investigations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

We may also share your Personal Data with the Tennis Integrity Unit for the purpose of assisting with their anti-corruption investigations. You may read the Tennis Integrity Unit’s privacy policy here: https://www.tennisintegrityunit.com/privacy-policy.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

Tracking Tools, Advertising and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Services, to analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

  • Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
  • Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services such as by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google Inc (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.
  • Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.” You can decide whether to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you, or to modify your preferences with respect to Cookies, you can access your Cookie management settings by clicking [LINK]. To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union or in the United Kingdom.

Information about Interest-Based Advertisements:

We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.

Data Security

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Data Retention

We retain Personal Data about you for as long as you have an open account with us or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

For example:

  • We retain your payment data for as long as we need to process your purchase or subscription.
  • We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 13 years of age or from EU or UK residents under 16 years of age; if you are a child under the age of 13 (or an EU or UK resident under the age of 16), please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age or an EU or UK resident under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age or an EU or UK resident under 16 years of age may have provided Personal Data to us, please contact our support team.

California Resident Rights

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact our support team.

Access

You have the right to request certain information about our collection and use of your Personal Data  over the past 12 months. In response, we will provide you with the following information:

  • The categories of Personal Data that we have collected about you.
  • The categories of sources from which that Personal Data was collected.
  • The business or commercial purpose for collecting or selling your Personal Data.
  • The categories of third parties with whom we have shared your Personal Data.
  • The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business  purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.

Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA or the GDPR, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Correction

You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CCPA or the GDPR, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.

Exercising Your Rights

To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods:

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Opting Out of Personal Data Sales and Sharing

In this section, we use the term ‘sell’ as it is defined in the CCPA. If you are a participant in the UTR Pro Tennis Tour, you are bound by the Player Agreement you enter as a pre-requisite of participating in the UTR Pro Tennis Tour, and in so doing, allow us to sell your Personal Data, subject to your right to opt-out of these sales.

If you are a participant in the UTR Pro Tennis Tour, we sell your Personal Data to the following categories of third parties:

  • Third parties as described in the contract executed between you and UT in connection with the UTR Pro Tennis Tour.

If you are a participant in the UTR Pro Tennis Tour, over the past 12 months, we have sold the following categories of your Personal Data to categories of third parties listed above:

  • Profile or Contact Data.
  • Consumer Demographic Data.
  • Non-Public Education Data.
  • Geolocation Data.
  • Inferences Drawn From Other Personal Data Collected.
  • Other Identifying Information that You Voluntarily Choose to Provide.
  • Other Data (i.e. match scores and results and tournament and/or event scores and results). 

If you are a participant in the UTR Pro Tennis Tour, you have the right to opt-out of the sale of your Personal Data. You can opt-out using the following method:

Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.

Under the CCPA, we share the Personal Data of minors that participate in the UTR Pro Tennis Tour and that are between 13 and 16 years of age in a way that may be considered a sale. If you are between 13 and 16 years of age, you must authorize us to sell your Personal Data. To our knowledge, we do not sell the Personal Data of minors under 13 years of age.

Personal Data Sales and Sharing Opt-Out and Opt-In for Website Visitors

Under the CCPA, California residents have certain rights when a business “shares” Personal Data with third parties for purposes of cross-contextual behavioral advertising. We have shared the following categories of Personal Data for the purposes of cross-contextual behavioral advertising:

  • Device/IP Data
  • Web Analytics Data

As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CCPA, sharing your data through third party Cookies for online advertising may be considered a “sale” of information. You can opt out of data selling and/or sharing by following the instructions in this section.

We share Personal Data of website visitors with the following categories of third parties:

  • Ad Networks.
  • Marketing providers (including for cross-contextual behavioral advertising purposes)

We have shared the following categories of Personal Data of website visitors with the categories of third parties listed for the following purposes:

  • Marketing and selling the Services.
  • Showing you advertisements, including interest-based or online behavioral advertising.

You have the right to opt-out of the sharing of your Personal Data. You can opt-out using the following methods:

  • You can email us at legal@universaltennis.com. 
  • You can opt-out of retargeted advertising cookies by visiting your Cookie management settings here: [LINK].
  • You can use a Global Privacy Control or similar control that is legally recognized by a government agency or industry standard and that complies with the CCPA. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal. Please note this does not include Do Not Track signals.

Once you have submitted an opt-out request, we will not ask you to reauthorize the sharing of your Personal Data for at least 12 months.

To our knowledge, we do not share the Personal Data of minors under 16 years of age. 

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Opt-Out from Certain Third Party Marketing

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact our support team.

Other State Law Privacy Rights

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. You can exercise this right by contacting our support team with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.

Colorado Resident Rights

If you are a Colorado resident subject to the Colorado Student Data Transparency and Security Act (C.R.S. section 22-16-101 et seq.), we will not sell your Personal Data, use your Personal Data for targeted advertising, or use your Personal Data to build a user profile other than in connection with our Services as set forth in this Privacy Policy. Personal Data will be stored in a manner that protects its security, privacy, confidentiality, and integrity, including appropriate administrative, technological and physical safeguards.

European Union and United Kingdom Data Subject Rights

EU and UK Residents

If you are a resident of the European Union (“EU”), the United Kingdom (“UK”), Liechtenstein, Norway or Iceland, you may have additional rights under the EU / UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. UT will be the controller of your Personal Data processed in connection with the Services.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact our support team.

Personal Data We Collect

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds

The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
• Profile or Contact Data.
• Payment Data.
• Social Network Data.
• Consumer Demographic Data.
• Non-Public Education Data.
• Geolocation Data.
• Inferences Drawn From Other Personal Data Collected.
• Other Identifying Information that You Voluntarily Choose to Provide.
• Other Data.

  • Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
    • Profile or Contact Data.
    • Payment Data.
    • Device/IP Data.
    • Web Analytics.
    • Social Network Data.
    • Consumer Demographic Data.
    • Non-Public Education Data.
    • Geolocation Data.
    • Inferences Drawn From Other Personal Data Collected.
    • Other Identifying Information that You Voluntarily Choose to Provide.
    • Other Data.
    • We may also de-identify or anonymize Personal Data to further our legitimate interests.

Examples of these legitimate interests include (as described in more detail above):

• Providing, customizing and improving the Services.

• Marketing the Services.

• Corresponding with you.

• Meeting legal requirements and enforcing legal terms.

• Completing corporate transactions.

  • Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
  • Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Sharing Personal Data

The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.

EU and UK Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at legal@universaltennis.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

  • Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging on to your account.
  • Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging on to your account.
  • Erasure: You can request that we erase some or all of your Personal Data from our systems.
  • Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
  • Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
  • Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
  • Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
  • Right to File Complaint: You have the right to lodge a complaint about UT’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here:
    https://edpb.europa.eu/about-edpb/board/members_en.

Please note that automated decision making or profiling according to Art. 22 GDPR does not take place.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through UT and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. The U.S. is not deemed by the European Commission or the United Kingdom as providing an adequate level of protection for Personal Data, and is not covered by a suitable framework or certification recognized by the relevant independent public data protection authority as providing an adequate level of protection for Personal Data. If you do not wish for your Personal Data to be transferred to the U.S. or other jurisdictions, please do not submit your Personal Data to UT. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to UT in the U.S. and will be hosted on U.S. servers, and you authorize UT to transfer, store and process your information to and in the U.S., and possibly other countries. We undertake that when we transfer EU or UK Personal Data to a jurisdiction outside the EU or the UK, such as the U.S., to the extent applicable, we will follow and adhere to the European Commission’s Standard Contractual Clauses for the transfer of personal data to third countries, pursuant to Decision 2004/915/EC (the Standard Contractual Clauses, available at http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32004D0915&from=EN). If, in the future, there are alternative means of giving you equivalent protection to the GDPR when we transfer EU Personal Data outside the EU, United Kingdom, Liechtenstein, Norway or Iceland, for example, statutory codes of practice approved for our use, then we may use those methods instead.

Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the UT website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Information:

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

Individuals and the data protection supervisory authorities in the EU/EEA and individuals and the data protection supervisory authority (“ICO”) in the UK may also contact our data protection representatives according to Article 27 GDPR: