Privacy Statement
Last Updated on May 8 2022
I. PRIVACY, SECURITY AND TRANSPARENCY
Thank you for visiting the online and mobile resources published by Dream Financial Literacy which is owned by Universal Border Solutions, hereafter called [DFL]. Our privacy statement contained hereunder serves, to give notice about the types of personal information we collect, how we use it, who we share it with and why, and what we do to try to protect it. We encourage you to read them carefully. In the meantime, we provide a quick overview below.
1 What do we collect?
There are two types of information that we obtain from you online and then store and use:
• non-personal information that’s collected automatically from each visitor, such as your device operating system; and,
• personal information that you voluntarily provide to us or that is collected automatically.
2 Why do we use it?
We use non-personal information to administer our online and mobile resources, make them better, and to make business decisions about what programs our customers might like.
We use voluntarily provided personal information to respond to your inquiries and provide you with the services you have requested, amongst other uses as further described below. We do not sell or rent your personal information to third-party data vendors or marketing companies. As you might expect, we disclose your information when required by law.
3 When do we share it?
We share personal information when needed to fulfill our legal obligations and when our vendors and business partners need it to perform under the contracts we have with them. We do not sell or rent any personal information to third-party data brokers or marketing companies.
4 Your Privacy Choices and Rights
You do not have to provide personal information to enjoy most of the features of our online and mobile resources. Moreover, you can opt-out of certain activities like newsletters and announcements. Residents of California and data subjects whose personal information was obtained while they were in the GDPR Jurisdictions have certain additional rights.
5 Contacting
Questions about this highlights page or our online privacy statement may be sent to info@universalbordersolutions.com
II. SOME IMPORTANT VOCABULARY
Although not itself a contract, this privacy statement is an important document that explains how we address some of our legal obligations, and your related legal rights, involving personal information, so clarity is important. We’ll use this section to let you know about some words that have special meanings whenever you see them in this statement. Let’s start with the word “statement” itself: when we reference “this statement”, “this privacy statement”, and “our statement”, we mean Dream financial Literacy
Resources, a DBA of Universal Border Solutions Inc. online privacy statement you are reading now. Wherever we say “DFL” or “we”, “us”, or “our”, we mean Universal Border Solutions Inc. . We use the words “you” and “your” to mean you, the reader, and other visitors to our online and mobile resources who are, in all cases, over the age of 13. This age requirement is discussed in more detail later in this statement.
When we talk about our “online and mobile resources”, we mean all websites and other internet features we own that allow you to interact with our websites, as well apps we’ve created and distributed to let our customers and followers view our online and mobile resources or otherwise interact with the content we provide. An “affinity action” is when you “follow” us, “like” us or take a similar or analogous action on our external social media presence. When we refer to “personal information”, we generally mean information that can be used to identify you or that can be easily linked to you. Thus, a fairly comprehensive list of personal information would include such things as your name, address, telephone number, email address, social security number and date of birth. The privacy laws in some jurisdictions include unique elements in what they consider to be the personal information of the consumers or data subjects they protect. If those laws apply to us, as in the case of the California Consumer Privacy Act (“CCPA”) or European General Data Protection Regulation (“GDPR”), our use of the phrase “personal information” includes the unique elements required by such laws. When we reference the “GDPR Jurisdictions” we mean the countries comprised by the European Economic Area, the United Kingdom (which soon will leave the European Union), Switzerland and Japan which, having received an “adequacy decision” from the European Commission, adheres to the material terms of the GDPR.
III. WHO DO WE COLLECT PERSONAL INFORMATION FROM?
We collect personal information from four groups of data subjects:
• visitors to, and users of, our online and mobile resources
• our customers
• current members of our workforce and those who apply for
posted jobs
• our third-party vendors and business partners
The categories of information we collect from each of these groups, and the ways in which we use it, differs. As you may have noticed, it’s possible that the same person could fall into more than one group. For instance, someone who works for us might, on their day off, visit one of our general websites. Most of this statement addresses our processing
and sharing of personal information collected from visitors to and users of our online and mobile resources and our customers. The immediately following paragraphs provide a quick summary overview about everyone else.
1 Our Workforce and Job Applicants
We collect and retain the types of professional or employment-related personal information you would expect an employer to have about its existing and former workforce and new job applicants. We provide legally required notices of collection, and describe our use and sharing of the personal information of our workforce and applicants in greater detail in confidential internal human resource manuals and documents accessible to members of our workforce, or by publication on the proprietary workforce/applicant portals and apps we operate. In some cases, such portals and apps may be operated by third parties who transfer the personal information to us. In those situations, the legal responsibility to provide notice usually rests with the third party, not us.
2 Vendors and Business Partners
Like all corporate enterprises, we buy goods and services, lease equipment and office space and attend industry events. In doing so, we interact with many existing and potential vendors and business partners from whom we necessarily collect certain personal information in connection with our contractual and business relationships. As with our customers, this information is typically limited to minimum business contact information. We use and share personal information collected from our vendors and business partners to manage, administer and perform under our contracts with them, or share information about our products. We describe our use of vendor and business partner personal information in greater detail in our confidential contracts with those parties or on the internal vendor management portals we operate.
IV. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE USE IT?
Generally, we collect personal information through automated/technical means and when you voluntarily provide it to us. We describe that type of voluntary submission immediately below. By using our online and mobile resources or purchasing our products or services, you are signifying to us that you agree with this section of our privacy statement and that we may use and disclose your information as described.
Voluntarily Submitted Information.
If you participate in certain activities via our online and mobile resources, you may be asked to provide us with information about yourself. The types of personal information we collect in those situations includes identifiers (such as your name, email address, physical address, and phone number), professional information (such as the business you are in), and financial account information (such as your credit card information).
For example, if you choose to send us an email or fill out an online form, you are voluntarily providing personal information to us. In doing so, you agree that we have a reasonable and lawful basis (such as to provide, maintain, and enhance the online and mobile resources and our product and service offerings, create reports on usage of the online and mobile resources, perform our contractual obligations, inform our marketing efforts, comply with law, or satisfy our legitimate business interests) on which to collect, use, and
disclose that information for the purpose it is requested and for other reasonable internal business purposes. We do not sell, rent, or trade voluntarily submitted personal information with third parties.
If you don’t want us to collect this type of personal information, please don’t provide it. This means you shouldn’t participate in the activities on our online and mobile resources that request or require it and you may want to communicate with us by phone or regular mail instead. Participation is strictly your choice. Not participating may limit your ability to take full advantage of the online and mobile resources, but it will not affect your ability to access certain information available to the general public on the online and mobile resources.
Here are some of the ways you voluntarily give us your personal information and how we use it:
• Emails and Online Forms – When you send us an email or
fill out an online form, such as to contact us, your email
address and any other personal information (e.g., home
address or phone number) that may be in the content of your
message or attached to it, are retained by us and used to
respond back directly to you and to process your request.
Depending on the personal information provided,
communications from us may be in the form of emails,
telephone calls, and/or text messages. We may also send
you information about any of our products or services we
think may be of interest to you.
• Registering for an Account – When you register for an
account or you register your child for a sub-account, you
submit personal information to us such as your name and
email address (or your child’s name and email address)
which we then retain. We use that information to create and
manage your account and in some cases establish a
password and profile to communicate with you and any sub
accounts you created via email.
• Registering for Events – When you register for events,
conferences or programs we ourselves may host (rather than
outsource to a third party event manager with its own privacy
policies), you will be submitting the types of identifiers
described above. If the event requires a fee, we may also ask
you to submit credit card or other financial information.
We use this information to register you for the event and send
you communications regarding the event.
• Becoming a Subscriber to Our Service – If you formally
become a customer of our product or service offerings, you
will be required to enter into a subscription or other
agreement via our related website. We use any information
provided from our customers to perform our contractual
obligations and provide the products and services purchased
to them, to manage their accounts and communicate with
them.
• Social Media and Community Features – Some of our
online and mobile resources may offer social media-like
community features letting users post messages and
comments, and/or upload image or other files and materials.
If you choose to make use of these features, the information
you post, including your screen name and any other personal
information, will be in the public domain and not
covered/protected by this statement.
Automatically Collected Information.
When you visit our online and mobile resources, basic information is passively collected through your web browser via use of tracking technologies, such as a “cookie” which is a small text file that is downloaded onto your computer or mobile device when you access the online and mobile resources. It allows us to recognize your computer or mobile device and store some information about your preferences or past actions. We allow third party vendors to use cookies or similar technologies to collect information about your browsing activities over time following your use of the site. For example, we use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to help us analyze how you use the online and mobile resources and enhance your experience when you visit the online and mobile resources. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/. You can learn more about how to opt out of Google Analytics by going to https://tools.google.com/dlpage/gaoptout.
The internet activity information collected through cookies and other similar means includes such things as:
• the domain name and IP address from which you accessed our online and mobile resources;
• the type of browser and operating system you use;
• the date and time and length of your visit;
• the specific page visited, graphics viewed and any documents downloaded;
• the specific links to other sites you accessed from our online and mobile resources; and
• the specific links from other sites you used to access our online and mobile resources.
Additionally, if you access our online and mobile resources from a phone or other mobile device the mobile services provider may transmit to us uniquely identifiable mobile device information which allows us to then collect mobile phone numbers and associate them with the mobile device identification information. Some mobile phone vendors also operate systems that pinpoint the physical location of devices and we may receive this information as well if location services are enabled on your device. If you do not want us to collect and use geolocation data, disable location services through your device settings.
Regardless, we use both automatically collected information and mobile device information to compile generic reports about popular pages on our online and mobile resources, and to see how our customers and followers are accessing our online and mobile resources. We then use that data to administer the online and mobile resources and make them better, make your activities more convenient and efficient and to enhance
the functionality of our online and mobile resources, such as by remembering certain of your information in order to save you time.
We use and retain your personal information in accordance with applicable law and as long as necessary to carry out the purposes described above in accordance with our internal data retention procedures.
User Beware: External Sites, Apps, Links and Social Media.
We maintain a presence on one or more external social media platforms such as Twitter, Facebook, YouTube and LinkedIn. We may further allow the community features of our online and mobile resources to connect with, or be viewable from, that external social media presence. Similarly, our online and mobile resources may contain links to other websites or apps controlled by third parties.
We are not responsible for either the content on, or the privacy practices of, social media platforms, or any third party sites or apps to which we link. Those apps, sites and platforms are not controlled by us and therefore have their own privacy policies and terms of use. To be clear: neither this statement nor the terms of service appearing on or in any of our online and mobile resources apply to our social media presence or any third party sites or apps to which we may link.
V. WHEN/WITH WHOM DO WE SHARE PERSONAL INFORMATION?
1) Affiliates.
In addition to those third parties set forth above, we may share your information, including personal information, within our family of companies such as Universal Border Solutions. Those companies will use such information in generally the same manner as we do under this privacy statement which includes sending you information about their products, services, or initiatives that may be of interest to you.
2) Legally Compelled Disclosures.
We may disclose your information, including personal information, to government authorities, and to other third parties when compelled to do so by such government authorities, or at our discretion or otherwise as required or permitted by law, including but not limited to responding to court orders and subpoenas.
3) To Prevent Harm.
We may disclose your information, including personal information, when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of the online and mobile resources, or anyone else that could be harmed by such activities.
4) Business Transfer.
If DFL or its affiliates, or substantially all of its or their assets, are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation, or liquidation, personal information may be one of the transferred assets.
5) Vendors and Business Partners.
We may share your information, including personal information, with our vendors and other third parties with whom we have a contractual relationship. Examples of the categories of third parties with whom we share your information with and why include the vendors from whom we obtain technology and infrastructure services to host our online and mobile resources, perform credit card processing, API integration, and data analytics services. We may also share your information, including personal information, with vendors who provide third party software services that you have chosen to assist you with your sales funnels. We do our best to disclose only the information each of those parties need.
Please note, however, that we cannot guarantee that all of our vendors and business partners will agree to these contractual requirements; nor can we ensure that, even when they do agree, they will always fully comply.
VI. YOUR RIGHTS AND OPTIONS
If we are using personal information you provided to us in order to enable us to send you materials, such as newsletters or product alerts via text or email], and you decide you don’t want to receive such materials, you may opt out by following the opt-out instructions in the email or other communication (e.g., by responding to the text with “STOP”), or by contacting us using the contact information below. When we receive your request, we will take reasonable steps to remove your name from our distribution lists. You need to understand it may take a period of time to remove your name from our lists after your request and due to such latency you may still receive materials for a period of time after you opt out. In addition to opting out, you have the ability to access, amend, and delete your personal information by contacting us using the contact information below.
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 specifically respond to browser “do not track” signals.
VII. CHILDREN’S PRIVACY
Federal law imposes special restrictions and obligations on commercial website operators who direct their operations toward, and collect and use information from, children under the age of 13. We take those age-related requirements very seriously, and consistent with it do not intend for our online and mobile resources to be used by children under the age of 13 without first obtaining the verifiable consent of such child’s parent or legal guardian. Moreover, we do not knowingly collect personal information from minors under the age of 13, only a parent or legal guardian may provide such information after adhering to our verification process for submitting such information via the online and mobile resources. If we become aware that anyone under the age of 18 has submitted personal information to our online and mobile resources, we will delete that information and will not use it for any purpose whatsoever. If you believe that someone under the age of 18 has submitted personal information to our online and mobile resources, please contact us at info@universalbordersolutions.com We encourage parents and legal guardians to talk with their children about the potential risks of providing personal information over the Internet.
VIII. HOW DO WE PROTECT COLLECTED PERSONAL INFORMATION?
1. Our Data Security Program
We will take all reasonable security precautions to protect your personal information provided to our online and mobile resources. We have adopted, implemented and maintain an enterprise-wide corporate information security program that includes technical, organizational, administrative, and other security measures designed to protect, in a manner consistent with accepted industry standards and applicable law, against anticipated or actual threats to the security of personal information. We cannot, however, guarantee that your information, whether during transmission or while stored on our systems or otherwise in our care, will be free from unauthorized access or that loss, misuse, destruction, or alteration will not occur. Except for our duty to maintain the Security Program under applicable law, we disclaim any other liability for any such theft or loss of, unauthorized access or damage to, or interception of any data or communications including personal information. We have every reason to believe our Security Program is reasonable and appropriate for our business and the nature of foreseeable risks to the personal information we collect. We further periodically review and update our Security Program, including as required by applicable law.
Your ability to exercise these rights is subject to certain conditions and exemptions. Among those conditions is our right to decline part or all of a request if we cannot satisfy our reasonable doubts and concerns about your identity in a manner that helps us minimize the risk that unauthorized persons might use. We will respond to all requests without undue delay, and in accordance with the law of reasonableness.
CHANGES TO THIS PRIVACY STATEMENT
We reserve the right to change or update this statement from time to time. Please check our online and mobile resources periodically for such changes since all information collected is subject to the statement in place at that time. Typically, we will indicate the effective/amendment date at the beginning of this statement. If we feel it is appropriate, or if the law requires it, we’ll also provide a summary of changes we’ve made near the end of the new statement.
CONTACTING US
If you have questions about our privacy statement or privacy practices, please contact us at: info@universalbordersolutions.com
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