Privacy Policy

Effective Date: September 26, 2023

Universal Gifted Savings, Inc. is Delaware public benefit corporation (“UGS”, “us”, “we”, or “our”) that operates a website currently located at (the “Site”).   This page informs you of our privacy policies regarding the collection, use, and disclosure of Personal Data when you access and use our Site and the choices you have associated with your Personal Data. By accessing and using the Site, you agree to the collection and use of your Personal Data in accordance with this privacy policy.

1. Information Collection 

When you visit our Site, UGS collects a broad variety of information about you and how you use the Site.  UGS may use such information (including Personal Data) to provide and improve our programs, services, content, and advertising. If we cannot collect this information, we may not be able to provide you programs or services, and you may not be able to take advantage of certain site features.  Under no circumstances will we sell your Personal Data to any third-parties. 

2. Use of Data

The Site uses the collected data for various purposes:

– To provide and maintain the Site

– To notify you about changes to our Site

– To allow you to participate in interactive features of our Site when you choose to do so

– To provide customer care and support

– To provide analysis or valuable information so that we can improve the Site

– To monitor the usage of the Site

– To personalize your experience on the Site by presenting products, marketing messages, offers, and content tailored to you

– To send you marketing communications related to UGS and selected third-parties

– To identify usage trends, conduct and perform marketing analysis and data analytics

– To support crime and fraud monitoring and prevention, compliance audits and security

3. What Data We Collect

Usage Data.  Examples of the information we automatically collect and store include:

– Pages you visit, the time and date of your visit, the time spent on those pages, or product information that you view.

– Information transmitted by the device used to access the sites which includes technical information such as your operating system, browser type, browser version, device identifier, IP address, language and country of origin.

– Any information that you post or submit such as your request for more information, or when you register for an event, or post information.

– If you have or register for a UGS program, we will also connect this information with your saved account profile.

Personal Data. While using our Site, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include:– Email address– First name and last name– Phone number– Address, State, Province, ZIP/Postal code, City– Gender– Income and number of dependents (to determine financial eligibility)– Social security number (to provide tax forms)– Bank account information (to send deposits)

4. Your Personal Data Rights

Under applicable data privacy laws and depending upon our use or basis for processing, you have specific rights regarding your Personal Data, which may include the right to:

– Request information regarding your Personal Data, including the categories of Personal Data collected about you and categories of sources from which the Personal Data was collected

 – Request the business or commercial purpose for collecting Personal Data and the categories of third parties with whom we may share that information 

– Request that UGS correct, delete, or provide you a copy of your Personal Data 

– Object to or restrict UGS’s processing of your Personal Data

– Contact or lodge a complaint with the relevant data protection authority of your country if you have concerns about UGS’s use of your Personal Data

Requests regarding your Personal Data may be submitted to us by email. In order to process your request, we may need to verify your identity; applicable law may also permit or require us to retain information about you for specific purposes.

5. Cookies & Tracking

We use cookies and similar tracking technologies to track the activity on our Site and hold certain information. Cookies are typically small files downloaded onto your device (computer, phone, tablet, and similar devices) when you visit a website which may include an anonymous unique identifier. Cookies are widely used by website owners to make their websites work or to work more efficiently, as well as to provide reporting information. We use cookies on our Site, including first party and third-party cookies.  A “first party cookie” is one set by our Site. “Third party cookies” are set by third parties and enable third party features or functionality to be provided on or through the Site (e.g., advertising, videos, and website analytics services). 

We use cookie technology in several ways to enhance your experience on and continuously improve our Website, these include to: remember you when you return to our Website; identify you when you sign-in; authenticate your access; keep track of your specified preferences, demonstrated interests, or choices; tailor content to your preferences, interests, or geographic region; display personalized browsing history; deliver personalized or customized content on our Website and third party websites; track activity, downloads, and page views; monitor site usage; conduct research and diagnostics to improve our content, products, and services; and to help us analyze web traffic in general. We may also use cookies in interactions where you request something from UGS such as literature, software, technical support, seminar registrations, and/or when you participate in a survey.

We also work with third party companies, such as web analytics companies, advertisers, or companies working on their behalf. These companies use cookie technologies to serve the ads that appear on the Website or third-party websites directly to your browser, based in part on your online activity. These third parties employ cookies to measure and improve the effectiveness of advertisements for their clients, including us. To do so, these companies may use information about your visits to our sites and other websites. This information can also be used for online preference marketing purposes, including providing relevant advertisements about goods and services of interest to you. 

The Site uses the following types of cookies: 

Advertising & Marketing Cookies. These cookies enable interest-based advertising on the Website using information you make available to us when you interact with our Site. Interest-based ads are displayed to you based on cookies linked to your online activities, such as viewing products on our Site. We may also share this information with third parties for these purposes. These cookies help us to tailor advertisements to better match your interests, manage the frequency with which you see an advertisement, and understand the effectiveness of our advertising.

Analytics & Performance Cookies. These cookies, including cookies from Google Analytics, allow us to recognize and count the number of visitors on Website and see how visitors navigate our Site. This helps us improve the way the Site works (e.g., by making it easier for you to find information on the Site).

Functional Cookies. These cookies deliver enhanced functionality, including a more personalized and relevant experience on our Site by identifying who you are and storing your activity. If you do not allow these cookies, some or all Website features and services may not function properly.

Strictly Necessary Cookies. These cookies are necessary for the operation of the Website or to fulfill your requests (e.g., to access secure areas of the Site or to manage your configured cookie preferences).

You can control or delete cookies via your internet browser settings. The “Help” feature on most browsers will explain how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. 

Some web browsers may let you enable a “do not track” feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. This is different than blocking or deleting cookies, as browsers with a “do not track” feature enabled may still accept cookies. While the Site at this time does not recognize automated browser signals regarding tracking mechanisms, such as “do not track” instructions, you can generally express your privacy preferences regarding the use of most cookies and similar technologies through your web browser.

Examples of Cookies we use:

– Session Cookies. We use Session Cookies to operate our Site.  Session Cookies are deleted automatically at the end of your web browsing session when you close your browser, unless your browser is configured to persist your session.

– Preference Cookies. We use Preference Cookies to remember your preferences and various settings.– Security Cookies. We use Security Cookies for security purposes.

– Permanent Cookies.  Permanent Cookies are not deleted when your browser is closed and remain on your device until they either expire or are deleted.

6. Transfer Of Personal Data

UGS is a global company, and the information we collect, including Personal Data, may be transferred to and stored, processed, and accessed by, entities located in the United States and in other countries. Data protection laws differ around the world, and your information and Personal Data may be subject to access requests from governments, courts, or law enforcement in multiple jurisdictions. 

Your consent to this privacy policy followed by your submission of such information represents your agreement to the transfer of your Personal Data. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

7. Disclosure Of Data

We may disclose your Personal Data in the good faith belief that such action is necessary to:

– To comply with a legal obligation

– To protect and defend the rights or property of

– To prevent or investigate possible wrongdoing in connection with the Site

– To protect the personal safety of users of the Site or the public

– To protect against legal liability

8. California Residents  

If you are a resident of California, you may have one or more of the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law.

Right to Access and Right to Know Information regarding Personal Information. You have the right to request that we disclose to you the categories and specific pieces of Personal Information we have collected about you. Specifically, you have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:

– whether we are processing Personal Information about you

– the categories of Personal Information we have collected about you

– the categories of sources from which the Personal Information is collected

– the categories of third parties with whom we disclose Personal Information

– the specific pieces of information we have collected about you

– the categories of Personal Information about you, if any, that we have sold or shared and the categories of third parties to whom we have sold or shared the information, by category or categories of Personal Information for each category of third party to whom we sold or shared the Personal Information

– the categories of Personal Information about you that we disclosed for a business purpose and the categories of persons to whom we disclosed the information for a business purpose

Right to Deletion of Personal Information. You have the right to request that we delete Personal Information that we have collected from or about you. Please note if you have requested a service that requires the use of your Personal Information, we may not be able to provide that service if you choose to delete your personal Information.

Right to Correct. You have the right to request that we correct inaccurate Personal Information that we have collected about you.

Right to Opt Out. You have the right to opt out of the disclosure of Personal Information about you to third parties for monetary or other valuable consideration or the sharing of Personal Information about you for cross-context behavioral advertising, targeted advertising and profiling. To opt-out from the sale of personal information for valuable consideration to analytics, social media, and advertising partners, please use the following links:

– Google Advertising opt-out:

– Google Analytics opt-out:

– Trade Desk opt-out:

– Verizon Media opt-out:

Right to Appeal. If we decline to take action on a request that you make in accordance with the foregoing to exercise the foregoing privacy rights, then you may appeal our decision by replying to our response to your request by emailing us, or calling us.  Please use the reference ID associated with your request when you contact us so we can locate your records.

Right to Non-Discrimination. We may not discriminate against you because of your exercise of any of the foregoing rights, including by:

– Denying you goods or services;
– Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
– Providing you a different level or quality of goods or services; or
– Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Requests to Exercise Your Rights. You may request to exercise the foregoing rights by submitting a request through  [email protected].

We will process your request within 45 days after receipt of a verifiable request, unless we notify you that we require additional time to respond, in which case we will respond within such additional period of time required by law. If your request involves us providing Personal Information to you, we may deliver the Personal Information to you through your account, if you maintain an account with UGS, or, if not, electronically or by mail at your option. If electronically, then we will deliver the information to you or, if you so request and permitted by law, to another entity, in a portable and, to the extent technically feasible, in a structured, commonly used, machine-readable format that allows you to transmit the information from one entity to another without hindrance.

Agent Authorization.  You may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. Even if you use an agent, as permitted by law, we may require verification of the agent’s authorization to act on your behalf, require you to confirm you have authorized the agent to act on your behalf, and/or require you to verify your own identity.

Verification. We may require you to provide certain information, including contact information, to verify your identity before acting on your request to exercise your rights or granting you access to your information. We will only use this information to confirm your identity. In some cases we may need to collect additional information from you, and depending on the type of request we may use a third-party identity verification service to verify your identity. If we use a third-party identity verification service, our third-party identification verification service may ask you certain identity verification questions to match the information you provide with information that it has in its database.

Data Sharing for Direct Marketing Purposes. California Civil Code Section § 1798.83 further permits California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your Personal Information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us as specified below. To make such a request, please tell us your preference by contacting us.

Do Not Track. Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “do not track” signals.

Accessibility. If you use assistive technology and the format of this Privacy Notice interferes with your ability to access information, please contact us.

9. How We Protect Your Information

We implement reasonable technical, administrative, and physical safeguards designed to keep your Personal Data secure. For example, when you submit sensitive Personal Data, such as credit card information, through our Site, we utilize secure sockets layer (SSL) encryption technology. We also request that our third-party service providers use appropriate security measures to protect your information from unauthorized access or use. However, no data transmission is guaranteed as 100% secure.

10. Submissions and User Generated Content

Unless governed by separate terms identified at the time of submission, all suggestions, materials, remarks, or other intellectual property (e.g., ideas, experiences, and photos) you communicate or submit to us (“Submissions”) will be considered non-confidential and non-proprietary. UGS shall have no obligation of any kind with respect to such Submissions and shall be free to use and distribute Submissions for any purposes, without limitation of any kind.

11. Children’s Privacy

Our Sites are not intended for use by children under 13. We do not knowingly collect Personal Data from children under the age of 13 without parental or guardian consent. Please notify us as provided below in the Contact Us section if you believe we may have collected such information without parental or guardian consent or other than in a manner authorized by law, and we will work to delete it.

12. Contact Us

If you have any questions or comments about this Privacy Notice or our privacy practices or any requests with respect to the Personal Information we collect about you, you may contact us by sending an e-mail to [email protected], or by mail to 916 Silver Spur Road, Suite 310, Rolling Hills Estates, CA 90274.

13. Your Acceptance of Our Privacy Notice

By using our Site, you signify your acceptance of this Privacy Notice, and you agree to adhere to the terms and conditions posted on our Site under “Legal notice.” If you do not agree with the terms of this Privacy Notice, please do not access or use our Site or submit any Personal Data to us.

14. Changes to the Privacy Notice

UGS reserves the right to modify this Privacy Notice at any time, so you should review it frequently for changes. If we make changes to this Privacy Notice, we will post such changes here at Your continued use of our Site and/or provision of your Personal Data after such posting constitute your acceptance of such changes. If we make a change to this Privacy Notice that, in our sole discretion, materially affects the use or disclosure of your Personal Data, a notice will be posted at with a link to the updated Privacy Notice. Please contact us as described in the Contact Us section if you would like information regarding any changes.

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