Privacy Policy

DigitalMentors Business Center

Last Modified: September 9, 2019


  1. Purpose and Scope
  2. Personal Data Collection and Use
  3. Rights and Choices
  4. Control and Security
  5. Record-keeping
  6. Cookie Policy

1. Purpose and Scope

We respect your privacy. We want to inform you of the purposes for which we collect and use Personal Data, the types of Personal Data we collect, the types of third parties to whom we may disclose your Personal Data and the purposes for doing so, the rights and choices you have for limiting the use and disclosure of your Personal Data, and how to contact us about our practices concerning Personal Data.

This Privacy Policy applies to the Personal Data collected by registered Business Center account holders (“Members”) when individuals (“Site Visitors”) interact with a Business Center website, related subdomains, campaigns, services, and applications, if such content includes a link to this policy (“Content”).

We are the data controller for Personal Data relating to DigitalMentors Business Center Member accounts. We are the data processor for Personal Data relating to Members’ Business Center websites. This Privacy Policy concerns the processing for which we are the data processor. For processing for which we are a data controller, please visit

This Privacy Policy does not apply to information collected by us offline, on a website operated by a third party (including our affiliates and subsidiaries), or by a third party, including through an application or content (including advertising) that may link to or be accessible from our website.

The DigitalMentors Business Center is owned and operated by: Upward Enterprises, LLC, 500 East 4th Street #361, Austin, Texas 78701. When we refer to “Company” “we” or “us” in this Privacy Policy, we are referring to Upward Enterprises, LLC.

Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. If you do not agree with our policies and practices, your choice is to not use Content. By accessing or using Content, you agree to this Privacy Policy.

1.1. Inquiries or Concerns?

We are committed to resolving complaints about our collection and use of your Personal Data. Individuals with inquiries or complaints regarding this policy should first contact us at: [email protected]. We will respond to your request to access, update, or delete your information within ten business days. Before we are able to provide you with any information, correct any inaccuracies, or delete any information, however, we may ask you to verify your identity.

1.2. Revisions to this Privacy Policy.

We may revise this Privacy Policy to reflect changes in our legal or regulatory obligations or in the manner in which we deal with your Personal Data. It is our policy to post any changes we make to our privacy policy on this page and such changes will be effective from the time they are posted, provided that any material change to why we collect, use, or disclose your Personal Data will not apply to you, where your consent is required to such collection, use or disclosure, until we have obtained your consent to such change.

1.3. Children Under the Age of 13

Content is not intended for children under 13 years of age. No one under age 13 may provide Personal Data on our website. We do not knowingly collect Personal Data from children under 13. If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any personally identifiable information from children under the age of 13. If we learn we have collected Personal Data from a child under 13 without parent consent, we will delete that information. If you believe we might have information from or about a child under 13, please contact us at [email protected].

2. Personal Data Collection and Use

2.1. What is Personal Data?

For the purposes of this Privacy Policy, Personal Data is information, including Sensitive Data, that is: (i) about an identified or identifiable individual, (ii) received by us, and (iii) recorded in any form. Personal Data does not include anonymous or non-personal information (i.e., information that cannot be associated with or tracked back to a specific individual). “Sensitive Data” means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life, the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposal of such proceedings, or the sentence of any court in such proceedings.

2.2. Personal Data We Collect and How We Collect It

Our primary purposes in collecting Personal Data from or about Site Visitors is to process such data at the request of our Members, and to provide Site Visitors with efficient and customized Business Center services and features. We may collect and maintain Personal Data, including information:

  • by which you may be personally identified, such as your name, phone number, email address, mailing address, age, date of birth, financial account information (credit or debit card or bank routing information), Social Security Number or other government identifier, and social media connectors;
  • that is about you but individually does not identify you, such as your location, Internet Protocol (“IP”) address, referring URL, web pages visited, time spent on web pages, cookies, Flash cookies, pixel tags, and server logs; and
  • about your internet connection (including your Internet Service Provider), the equipment you use to access Content and usage details (including browser type, device identifier, operating system), and the actions you take on Content (referring and exit page, timestamps, and clickstream data).

We also track and analyze non-identifying and aggregate usage and volume statistical information from our Site Visitors.

We collect this information:

  1. directly from you when you provide it to us, including when registering to use Content, subscribing to a Business Center service, posting material to be displayed on public areas of Content, corresponding with us, or requesting further services;
  2. automatically as you navigate over time and across Content or other online services; and
  3. from third parties, for example, our Business Center Members and other business partners.

2.3. Our purposes in Collecting Personal Data

The Personal Data we collect is used and disclosed as is necessary to provide Business Center services to our Members and as reasonably required for their business purposes, including:

  • To present Content to you;
  • To provide you with information or services that you request;
  • To fulfill any other purpose for which you provide it;
  • To provide you with notices about your account, including expiration and renewal notices;
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  • To notify you about changes to Content or any products or services;
  • To offer you services and promotions you may be interested in;
  • To allow you to participate in interactive features in the Content;
  • To resolve disputes with, troubleshoot problems, and enforce our membership agreements;
  • In any other way we may describe when you provide the information; and
  • For any other purpose with your consent.

2.4. Types of Third Parties That May Receive Your Personal Data

We may disclose Personal Data to the following types of third parties:

We share your name, address, telephone number, and other contact details with the Member, if any, who referred you to the Content.

Service Providers
We may share Personal Data with our contracted service providers, such as billing or payment processors, to facilitate your use of the services; traffic tracking and targeted advertising services, which may enable Members to show you ads after you leave our site; and technical providers who help diagnose technical problems and administer our site so that we can constantly improve our services. Unless described in this Privacy Policy, we do not share, sell, rent, or trade any information with third parties for their promotional purposes.

Successors and Affiliates
We may share Personal Data with members of our corporate group and affiliates in order to work with them. For example, we may need to share Customer Information for customer relationship management purposes. We may also transfer Personal Data in the event of an audit or if we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution, or liquidation).

Partners and Affiliated Businesses Not Controlled by Us
We may partner with other companies to jointly offer products or services. If you purchase or specifically express interest in a jointly offered product or service from us, we may share Personal Data collected in connection with your purchase or expression of interest with our partners. We contractually require these third parties to keep Personal Data confidential and use if only for the purposes for which we disclose it to them. If you do not wish for your information to be shared in this manner, you may choose not to purchase or specifically express interest in a jointly offered product or service.

Compelled Disclosure
It may be necessary for us to disclose your Personal Data, either by law, legal process, litigation, or requests from public and governmental authorities. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose Personal Data if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. Other than as described above, we do not permit third parties to collect personally identifiable information about your online activities when you use our website and related services. We may disclose aggregated information about our users without restriction. Such information does not identify an individual person.

3. Rights and Choices

3.1. Choice

We offer you the means to choose how we use your Personal Data. To the extent required by applicable law, we obtain opt-in consent for certain uses and disclosures of Personal Data. You have a right to withdraw such consent at any time. We shall make reasonable efforts to accommodate individual privacy preferences.

Account Profile
To update your Personal Data or request deletion of your Personal Data, please email [email protected]. Requests to access, change, or delete your information will be handled within 30 days.

Tracking Technologies
We do not respond to your browser’s “do not track” signals or other mechanisms for indicating your preference regarding the collection personally identifiable information.

We use cookies and similar technologies. If you disable or refuse cookies, please note that some parts of the Content may then be inaccessible or not function properly.

Promotional Offers
If you do not wish to have your information used to promote a Member’s own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data. You can also always opt-out by sending us an email stating your request to [email protected].

You may manage your receipt of marketing and non-transactional email communications by clicking on the “unsubscribe” link located on the bottom of such communication. Additionally, you may send a request specifying your communications preferences to [email protected]. Note, if you make a purchase or have an account with us, you cannot opt out of receiving transactional emails related to the purchase or the services.

Targeted Advertising.
Members may partner with third party services and advertising networks to manage advertising on other sites. Such third parties may place cookies on your browser or device to gather information about your activities on ours and other sites that you visit in order to provide you with ads. We do not control third party collection or use of your information to serve ads. However these third parties may provide you with ways to choose not to have your information collected or used in this way.

Exceptions. We may disclose your Personal Data without offering an opportunity to opt out, when (i) required by law or legal process, or (ii) responding to lawful requests from public authorities, including to meet national security, public interest, or law enforcement requirements.

We cannot ensure that all of your private communications and other personally identifiable information will never be disclosed in ways not otherwise described in this Privacy Policy; third parties may unlawfully intercept or access transmissions or private communications.

3.2. EU Persons

Persons located in the EU have specific rights granted to them under the General Data Protection Regulation and national implementing laws, regulations, and secondary legislation. For clarity, with respect to data collected from Site Visitors, we are a data processor, processing Personal Data on behalf of our Members.

Limited Processing
We limit the processing of Personal Data of persons in the EU (“EU Personal Data”) to that which is relevant for the purposes of the particular processing. We do not process EU Personal Data in ways that are inconsistent with the purposes for which the information was collected or subsequently authorized by you.

In addition, to the extent necessary for these purposes, we take reasonable steps to ensure that the EU Personal Data we process is reliable for its intended use, and accurate, complete and current. In this regard, we rely on you to update and correct EU Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized. You may contact us at [email protected] to request that we update or correct relevant EU Personal Data.

Subject to applicable law, we retain EU Personal Data in a form that identifies or renders you identifiable only for as long as it serves a purpose that is compatible with the purposes for which it was collected or subsequently authorized by you.

Transfers of Personal Data
With respect to transfers of your Personal Data to third-party sub-processors, we will:

  1. enter into a contract with each relevant sub-processor;
  2. transfer Personal Data to each such sub-processor only for limited and specified purposes;
  3. ascertain that the sub-processor is obligated to provide the Personal Data with at least the same level of privacy protection as is required by applicable law;
  4. take reasonable and appropriate steps to ensure that the sub-processor effectively processes the Personal Data in a manner consistent with our obligations under applicable law;
  5. require the sub-processor to notify us if the sub-processor determines that it can no longer meet its obligation to provide the same level of protection as is required by our contract or applicable law; and
  6. upon notice, including under (e) above, take reasonable and appropriate steps to stop and remediate unauthorized processing of the Personal Data by the sub-processor.

3.3. Access

You generally have the right to access your Personal Data. Accordingly, where appropriate, we provide you with reasonable access to the Personal Data we maintain about you. We also provide you a reasonable opportunity to correct, amend, or delete your information.

We may limit these opportunities where the burden or expense of honoring a request would be disproportionate to the risks to your privacy, or where the rights of persons other than you would be violated. Other reasons for denying requests or limiting access include (i) interference with the execution or enforcement of the law or with private causes of action, including the prevention, investigation, or detection of offenses; (ii) breaching a legal or other professional privilege or obligation; and (iii) prejudicing security investigations or grievance proceedings or in connection with succession planning and corporate re-organizations.

Please contact [email protected] to request access to your Personal Data. If access cannot be granted, we will respond with a reason for denying your request.

3.4. Grievance procedure

You may file a complaint concerning our processing of Personal Data by email at [email protected]. If a failure to comply with this Privacy Policy or other obligations, we will take steps to remedy the issue.

If a complaint regarding Personal Data cannot be resolved through our internal processes, we will cooperate with applicable data protection authorities to address a complaint and provide appropriate recourse.

4. Control and Security

We take measures to prevent the loss, misuse, and alteration of your information. We carefully limit access to the database in which your personal information is stored. Additionally, we share and transfer your personal information only in the ways set forth in this privacy policy.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on Content.

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

4.1. Data Breach

If a breach of Personal Data occurs, we will notify the relevant authorities within 72 hours, or as otherwise required by applicable law, subject to likelihood of risk to the Site Visitor. Affected Members or Site Visitors will also be notified regarding the breach.

5. Record-keeping

As required by applicable law, we will maintain relevant records of:

  1. the purposes of Personal Data processing;
  2. the categories of data subjects and of Personal Data processed;
  3. the categories of recipients, including those in third countries;
  4. the countries to which Personal Data will be transferred and the instrument used to provide an adequate level of protection;
  5. where possible, the envisaged retention periods for different categories of Personal Data; and
  6. a general description of the security measures used to protect Personal Data.

These records shall be provided to data protection authorities upon request.