UCES Protection Plan

UCES USER PRIVACY NOTICE

UCES USER PRIVACY NOTICE

In our User Privacy Notice we have compiled all essential information about our handling of your personal data and your corresponding rights for you. This User Privacy Notice is effective from September 1, 2019.

1. Scope and updates of this User Privacy Notice.

This User Privacy Notice applies to your use of this website and all United Credit Education Services (“UCES”) applications, services (including marketing services), products and tools (collectively the "Services"), regardless of how you access or use these Services, including access via mobile devices and apps. This User Privacy Notice also applies if explicit reference is made to it via a link or in a similar manner, e.g. on websites of partners on which Services from UCES are offered.

We may change this User Privacy Notice at any time by posting the revised User Privacy Notice on this website and indicating the effective date of the revised User Privacy Notice. You will be notified of any material changes to this User Privacy Notice via your account page and/or by email.


2. Controller

2.1 Use of the Services

The following company is responsible for the collection and processing of your personal data in connection with the provision of our Services to you as a customer of UCES:

United Credit Education Services, 37735 Enterprise Ct., Ste. 600B, Farmington Hills, MI 48331, USA

2.2 Use of the marketing services for Agents

The following company is responsible for the collection and processing of your personal data in connection with the provision of our marketing services (including all “back office” functions) to those persons who separately register to become independent sales agents (“Agents”) of UCES:

United Credit Education Services, 37735 Enterprise Ct., Ste. 600B, Farmington Hills, MI 48331, USA


3. Data protection officer and contact.

If you have any questions about this User Privacy Notice or about data protection at UCES in general, you can contact the controller at any time. Furthermore, if you have any questions or complaints regarding this User Privacy Notice, our global privacy standards or our handling of personal data, you can also contact the controller at any time.


4. What personal data we collect and process

We collect your personal data when you use our Services, create a new UCES account, register as an Agent, provide us with information via a web form, add or update information in your UCES account, or otherwise interact with us. We also collect personal data from other sources (such as third party service providers who provide services included in the UCES Protection Plan or credit agencies or bureaus). In total, we collect the following personal data:

4.1 Personal data you provide when using our Services or creating an UCES account.
  • -Data that identifies you, such as your name, address, telephone numbers or email addresses, your user name, or your social security number that you provide when setting up your UCES account or at a later date, and additional identification data and tax identification numbers that you provide when using our marketing services as an Agent
  • -Financial information (e.g. credit card and account numbers, payment details) in connection with a transaction.
  • -In some cases: age, gender, country of birth, nationality, employment status, family status, interests and preferences.
  • -You may provide us with additional information through a web form or by updating or adding information to your UCES account, by participating in inquiries, dispute resolution, customer service calls recorded with your consent, or if you contact us for any other reason regarding our Services.
  • -Other data that we are required or entitled by applicable law to collect and process and that we need for your authentication or identification, or for the verification of the data we collect.
4.2 Personal data we collect automatically when you use our Services or create an UCES account
  • -Data that is generated as part of any sales transactions or agent recruiting transactions that are linked to your UCES account as a result of a transaction in which you are involved, such as transaction amounts, time and location of transactions and payment methods
  • -Data that is generated through your other actions when you use our Services and which are linked to your UCES account, as well as data regarding all other interactions with our Services, and your communications with us.
  • -Location data, including the location data of your mobile device. Please note that for most mobile devices, you can manage or disable the use of location services for all applications in the settings menu of your mobile device.
  • -Computer and connection information, such as statistics regarding your use of services from UCES, information on data traffic to and from websites, referral URL, information on advertisements, your IP address, your access times, your browser history data, your language settings and your weblog information.
4.3 Personal data we collect in connection with the use of cookies and similar technologies

We use cookies, web beacons and similar technologies to collect data while you use our Services. We collect this data from the devices (including mobile devices) that you use our Services with. The data collected may include the following usage- and device-related information:

  • -Data about the pages you visit, the access time, frequency and duration of visits, the links on which you click and other actions you take as part of your use of our Services and in advertising and email content
  • -Data about your activities and interactions with our advertising partners including data about the advertisements you were shown, how often they were shown, when and where they were shown, and whether you took any action, such as clicking on an advertisement or making a purchase.
  • -Model or device type, operating system and version, browser type and settings, device ID or individual device identifier, advertisement ID, individual device token, and cookie-related data (e.g. cookie ID)
  • -The IP address from which your device accesses the Services.- Location data, including the location data of your mobile device. Please note that most mobile devices allow you to manage or disable the use of location services for all applications in the settings menu

5. Purposes and legal basis for data processing and categories of recipients

We process your personal data for various purposes and pursuant to various legal bases. We process your personal data primarily to provide and improve our Services, to provide you with a personalized user experience on this website, to contact you about your UCES account and our Services, to provide customer service, and to detect, prevent, mitigate and investigate fraudulent or illegal activity. We also share your information with third parties for these purposes.

Below you will find a summary of the purposes for which we process your personal data, including the categories of recipients to whom we transmit personal data for the purposes stated, sorted by legal basis:

5.1 We process your personal data in order to fulfil our contract with you and to provide you with our Services

This includes the following purposes

  • -Processing of data relating to you or your company for the purpose of entering into a contract with you and executing it
  • -Provision of our Services, including but not limited to enabling and performing transactions with third party service providers (including the transmission of your personal data to third party service providers where necessary to perform the transaction, including in cases of terminated, failed or subsequently voided transactions), providing and enhancing features such as payment processing, ratings and UCES account management, providing other services you may use (as described in connection with such services), and ensuring the functionality of our Services. In connection with the provision of our Services, we will send you notifications relating to the execution of transactions and the use of our Services in accordance with the communication preferences in your UCES account.
  • -Provision of our marketing services to persons who are Agents.
  • -Solution of problems with your UCES account, arbitration of disputes, providing other services within the scope of customer service as well as enforcement of fee claims. For these purposes, we may contact you via notification in email, telephone, SMS, push notification on your mobile device or by mail. If we contact you by telephone, in order to ensure efficiency, we may use automatically dialed calls with tape announcements or automated text messages in accordance with our User Agreement, to the extent permitted by applicable law.
  • -Processing of general location data (such as IP address or postal code) in order to provide you with location-based services (such as radius search and other content that is personalized on the basis of your general location data).
  • -Enforcement of our User Agreement, any Agent Enrollment Agreement, this User Privacy Notice and other rules and policies.

When we share the content of your listings and any related personal data with third parties, we do so only on the basis of an agreement that limits the use of such personal data by the third party to the purposes necessary to fulfil its contractual obligations to us. Third party providers are contractually obliged to take appropriate security measures with regard to this data. Third party providers are strictly forbidden to pass on personal data contained in your listings to other third parties. In case of data transmissions to UCES service providers, such restrictions result from our Binding Corporate Rules (see below).

5.2 We process your personal data in order to comply with legal obligations to which we are subject

This includes the following purposes:

  • -Participation in proceedings (including judicial proceedings) conducted by public authorities or government agencies, in particular, for the purpose of detecting, investigating and prosecuting illegal acts.
  • -Prevention, detection and mitigation of illegal activities (e.g. fraud, money laundering and terrorist financing).
  • -Ensuring the information security of our Services.
  • -Retention and storage of your personal data to comply with specific legal retention requirements.

Where necessary, we transmit your personal data to processors and the following recipients for one or several of the purposes described above:

  • -Law enforcement agencies, courts, government agencies or public authorities, intergovernmental or supranational bodies.
  • -UCES third party service providers
  • -Third parties who are involved in judicial proceedings, in particular, if they submit a legal order, court order or equivalent legal order to us.
5.3 We process your personal data in order to protect your vital interests or the vital interests of another natural person

-Prevention, detection, mitigation and investigation of unlawful activities that may result in impairment of your vital interests or the vital interests of another natural person, unless there is a statutory obligation to this effect.

Where necessary, we transmit your personal data to processors and the following recipients for one or several of the purposes described above:

-Law enforcement agencies, courts, government agencies or public authorities, intergovernmental or supranational bodies

-Third parties who are involved in judicial proceedings

-UCES service providers

5.4 We process your personal data where necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms

In order to reconcile our legitimate interests with your rights, we have introduced appropriate control mechanisms. On this basis, we process your data for the following purposes:

  • -Participation in proceedings (including judicial proceedings) conducted by courts, law enforcement agencies, government agencies or public authorities, intergovernmental or supranational bodies, in particular for the purpose of detecting, investigating and prosecuting illegal acts, unless there is a statutory obligation to this effect, and we may legitimately assume that the disclosure of the data is necessary to avert imminent disadvantages or to report a suspicion of an illegal act. In such cases, we will only disclose what we believe is necessary, such as your name, city, zip code, telephone number, email address, (previous) user names, IP address, and fraud complaints.
  • -Protection of the legitimate interests of third parties in connection with civil law disputes, unless there is a statutory obligation to this effect, if we may legitimately assume that it is necessary to disclose the data to such third parties in order to avert imminent disadvantages.
  • -Prevention, detection, mitigation and investigation of fraud, security breaches and other prohibited or unlawful activities, including the assessment of corresponding risks (e.g. through the use of captchas or the telephone number stored in your UCES account for two-factor authentication), unless there is a statutory obligation to this effect.
  • -Monitoring and improvement of the information security of our Services, unless there is a statutory obligation to this effect.
  • -Performance of identity checks, creditworthiness and other financial standing checks, evaluation of applications and comparison of information for accuracy and verification purposes.
  • -Provision of functions for users that make the processing of transactions easier or more convenient (e.g. administration of several delivery addresses).
  • -Analysis and improvement of the Services from UCES service providers, e.g. by reviewing information from users about blocked or crashed pages in order to identify and solve problems and to provide you with an improved user experience, including as part of product development.
  • -Analysis of telephone conversations with our customer service that we recorded with your consent.
  • -Advertisements by mail (according to your communication preferences in your UCES account).
  • -To the extent permitted by applicable law without your consent, communications with you via electronic mail (e.g. email) or telephone to offer you vouchers, discounts and special offers, to conduct opinion polls and surveys, and to inform you about our Services (according to your communication preferences in your UCES account).
  • -Notifications regarding promotions and information about our Services after logging into your account (according to your communication preferences in your UCES account).
  • -Customization of page content to display the items and services you may like based on the actions you take.
  • -Provision of shared content and services (such as registration for services, transaction processing and customer service) with UCES service providers or other third parties.
  • -Initiation, preparation and execution of a company acquisition, e.g. in the event of a merger with another company or takeover by another company. If such an event occurs, we will require the merged entity to comply with this User Privacy Notice with respect to your personal data. Should your personal data be processed for any purpose not specified in this User Privacy Notice, you will be informed in advance of the processing of your data for this new purpose.
  • -Assertion of or defense against legal claims, including those asserted by one UCES user against another UCES user.

Where necessary, we transmit your personal data to processors and the following recipients for one or several of the purposes described above:

  • -UCES third party service providers
  • -For Agents, other UCES Agents in your upline
  • -Law enforcement agencies, courts, government agencies or public authorities, intergovernmental or supranational bodies
  • -Third parties who are involved in judicial proceedings
  • -Other companies in the context of a company acquisition
5.5 With your consent, we process your personal data for the following purposes:
  • -Processing of your exact location data to provide location-based services
  • -Processing of your personal data on the basis of your consent, which you have given so that we or third parties can enable you to use certain services or make them available to you

Where necessary, we transmit your personal data to processors and the following recipients for one or several of the purposes described above:

  • -UCES third party service providers
  • -Third party financial institutions with whom we partner to offer financial products to you, for them to provide joint content and services (such as, registration, transactions and customer support). These third party financial institution partners will use your personal data to send you marketing communications only if you have requested their services.

Without your consent, we will not pass on your personal data to third parties for their marketing or advertising purposes, nor will we sell or otherwise make it available to third parties for a fee.

5.6 Data Sharing between UCES Service Providers

As set out above under "Personal data from other sources," we also receive access to personal data about you from UCES third party service providers. This enables us, in particular, to provide you, with your consent as legally required, with information about products and services, which we believe might interest you, and improve our products, services, content, and advertising by analyzing your use of the services of UCES third party service providers, in particular through the matching of certain data (e.g. cookie IDs). Furthermore, this allows us to better prevent, detect, mitigate and investigate fraud, security breaches and other prohibited or unlawful activities, including the assessment of corresponding risks. We will also grant access to personal data about you to UCES third party service providers for the aforementioned purposes. To the extent that UCES third party service providers have access to your personal data, they will follow practices that are at least as restrictive as the practices described in this User Privacy Notice.


6. Storage duration and erasure

Your personal data will be stored by us and our service providers in accordance with applicable data protection laws to the extent necessary for the processing purposes set out in this User Privacy Notice. Subsequently, we will delete your personal data in accordance with our data retention and deletion policy or take steps to properly render the data anonymous, unless we are legally obliged to keep your personal data longer (e.g. for tax, accounting or auditing purposes). As far as legally permissible or required, we restrict the processing of your data instead of deleting it (e.g. by restricting access to it). This applies in particular to cases where we may still need the data for the execution of the contract or for the assertion of or defense against legal claims. In these cases, the duration of the restriction of processing depends on the respective statutory limitation or retention periods. The data will be deleted after the relevant limitation or retention periods have expired.

How long we retain personal data may vary depending on the Services we provide and our legal obligations under applicable law. The following factors typically affect the retention period:

  • -Necessity for the provision of our Services
  • -This includes such things as executing the User Agreement with you, maintaining and improving the performance of our products, keeping our systems secure, and maintaining appropriate business and financial records. Most of our retention periods are determined on the basis of this general rule.
  • -Special categories of personal data. If we store special categories of personal data, a shorter retention period is usually appropriate.
  • -Consent-based processing of personal data. If we process personal data on the basis of consent (including consent to the extended storage), we store the data for as long as necessary in order to process it according to your consent.
  • -Statutory, contractual or other similar obligations. Corresponding storage obligations may arise, for example, from laws or official orders. It may also be necessary to store personal data with regard to pending or future legal disputes. Personal data contained in contracts, notifications and business letters may be subject to statutory storage obligations depending on national law.

7. Rights as a data subject

Subject to possible restrictions under national law, as a data subject, you have the right to access, rectification, erasure, restriction of processing and data portability with regard to your personal data. In addition, you can withdraw your consent and object to our processing of your personal data on the basis of legitimate interests. You can also lodge a complaint with a supervisory authority.

Your rights in detail:

  • -You can withdraw your consent to the processing of your personal data by us at any time. As a result, we may no longer process your personal data based on this consent in the future. The withdrawal of consent has no effect on the lawfulness of processing based on consent before its withdrawal.
  • -You have the right to obtain access to your personal data that is being processed by us. In particular, you may request information on the purposes of the processing, the categories of personal data concerned, the categories of recipients to whom the personal data have been or will be disclosed, the envisaged period for which the personal data will be stored, the existence of the right to request rectification or erasure of personal data or restriction of processing of personal data or to object to such processing, the right to lodge a complaint with a supervisory authority, any available information as to the personal data’s source (where they are not collected from you), the existence of automated decision-making, including profiling and, where appropriate, meaningful information on its details. Your right to access may be limited by national law.
  • -You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
  • -You have the right to obtain from us the erasure of personal data concerning you, unless processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defense of legal claims. The right to erasure may be limited by national law.
  • -You have the right to obtain from us restriction of processing to the extent that the accuracy of the data is disputed by you, the processing is unlawful, but you oppose the erasure of the personal data, we no longer need the data, but you need it to assert, exercise or defend legal claims or you have objected to the processing.
  • -You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller ("right to data portability").
  • -You have the right to lodge a complaint with a supervisory authority. As a rule, you can contact the supervisory authority of your usual place of residence, your place of work or the registered office of the controller.

If your personal data is processed on the basis of legitimate interests, you have the right to object to the processing of your personal data on grounds relating to your particular situation. The exercise of the above data subjects' rights (e.g. right to access or erasure) is generally free of charge. Where requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge an appropriate fee (at most our actual costs) in accordance with the applicable statutory regulations or refuse to process the application.


8. Cookies & similar technologies

When you use our Services, we and selected third parties may use cookies and similar technologies to provide you with a better, faster and safer user experience or to show you personalized advertising. Cookies are small text files that are automatically created by your browser and stored on your device when you use the Services. You can find detailed information about our use of cookies and similar technologies and your choices in our User Cookie Notice.

Our cookies and similar technologies have different functions:

  • -They may be technically necessary for the provision of our Services
  • -They help us optimize our Services technically (e.g. monitoring of error messages and loading times)
  • -They help us improve your user experience

We use cookies and similar technologies that remain on your device only as long as your browser is active (session cookies), as well as cookies and similar technologies that remain on your device longer (permanent cookies). Where possible, we take appropriate security measures to prevent unauthorized access to our cookies and similar technologies. A unique ID ensures that only we and/or selected third parties have access to cookie data.

You are free to disable the use of cookies and similar technologies if this is supported by your device. You can manage your cookie settings in your browser or device settings.


9. Data security

We protect your personal data through technical and organizational security measures to minimize risks associated with data loss, misuse, unauthorized access and unauthorized disclosure and alteration. To this end we use firewalls and data encryption, for example, as well as physical access restrictions for our data centers and authorization controls for data access.


10. Other important information regarding data protection

When you use our Services, your public user ID may be displayed and available to the public and associated with all of your public UCES activity. Notices sent to other users about suspicious activity and notice violations on our sites may refer to your public user ID and specific items. Accordingly, if you use a username that allows others to identify you, these others may be able to identify your UCES activities.

Some of the personal data that you provide to us (e.g. data by which we can identify you) are required to enter into the User Agreement and the Agent Enrollment Agreement. The provision of any other personal data is voluntary, but may be necessary for the use of our Services, such as bidding, purchase and sales data to complete a transaction.

Links to Other Websites

Links to third-party websites may be provided solely for your information and convenience or to provide additional shopping for various other goods and services through our Merchant and Services Partners. If you use these links, you will leave our Site. This Privacy Statement does not cover the information practices of those websites nor do we control their content or privacy policies. We suggest that you carefully review the privacy policies of each site you visit.

Children’s Privacy Protection

We take special care to protect the privacy needs of children and encourage parents to be an active participant in their child’s online activities. Our Site does not target and is not intended for children under the age of 18, and we will not knowingly collect Personally Identifiable Information from them. If we discover personal data from a child through our site, we will eliminate that data. You may learn more about protecting children’s privacy online by visiting: https://www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online.


YOUR USE OF OUR SITE MEANS THAT YOU ACCEPT THE PRACTICES SET FORTH IN THIS POLICY. YOUR CONTINUED USE INDICATES YOUR AGREEMENT TO THE CHANGES.