About Ulupono

Privacy

Last Updated: January 2020

Ulupono Initiative’s website, ulupono.com (the “Website”), is owned by Ulupono Initiative LLC (“Ulupono”). Ulupono respects your privacy and values its relationship with you. Please read this Privacy Policy to understand our policies and practices regarding our collection, use, and disclosure of the information that you submit to us and that we collect from you through, your rights relating to your personal information. This Privacy Policy does not govern information you might provide through a channel other than this Website.

Information We Collect

Information you submit to us

You may choose to provide personal information (for example, your e-mail address) for purposes, including the following.

News, Announcements, and Publications:On our Website, you may sign up to receive newsletters, announcements, and other marketing publications. To sign up, you will be asked to provide your email address. We use this information to send you the communications you requested. We also may use this information to communicate with you about other topics we believe may be of interest to you, where we have a legitimate basis for doing so.
Other uses of information:We may use the personal information you provide on the Website for our internal purposes. These purposes include administration of the Website, market research, data analytics, and compliance with our legal obligations, policies, and procedures.

Automatically-collected information

We may collect other information about you that does not reveal your specific identity or does not directly relate to an identifiable individual, such as: (1) browser and device information; (2) information collected through cookies, pixel tags (also known as web beacons and clear GIFs), and other technologies; (3) demographic information; and (4) information that has been aggregated in a manner that it no longer reveals your specific identity (collectively, “Other Information”).

If we are required to treat Other Information as personal information under applicable law, then we may use and disclose it for the purposes for which we use and disclose personal information as detailed in this Policy.

Cookies

We use “cookies” on the Website. Please refer to our Cookie Policy, which is made part of this Privacy Policy.

Children’s information

Our Website is directed at individuals over the age of 18 and is not directed at children under the age of 13. We will not knowingly collect personally identifiable information from children under the age of 13. If you are under the age of 13, do not provide personally identifiable information of any kind. Should you suspect that a child of whom you are the parent or legal guardian has provided us with personal information, please contact us at communications@ulupono.com and we will work with you to address the issue.

Your California Privacy Rights

Under California Civil Code Section 1798.83 (“Shine the Light Law”), California users are entitled to request information relating to whether a business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. We are providing the following information for California residents who have provided us with their personal information during the creation of or during the course of an established business relationship that is primarily for personal, family, or household purposes (“Individual California Users”).

We do not share personal information as defined by the Shine the Light Law with third parties for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light law by contacting us communications@ulupono.com or by sending a letter to: Ulupono Initiative, P.O. Box 2938, Honolulu, HI 96802 (Attention: Privacy Inquiry). Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address.

How we use your information

We use your personal information for legitimate business purposes, including:

Providing the functionality of the Website and fulfilling your requests:
- To maintain the functionality of the Website.
- To respond to your inquiries and fulfill your requests when you contact us via our online contact form.
- To send administrative information to you, such as information regarding our services and changes to our terms, conditions, and policies.

We will engage in these activities to manage our relationship with you and/or to comply with a legal obligation.

Providing you with newsletters and/or other marketing materials
- To send you our newsletters, publications, and mailings related to events that we think might be of interest to you.
- To send you information about our projects and other news about Ulupono.

We will engage in this activity with your consent or where we have a legitimate interest.

Aggregating and/or anonymizing personal Information.
- We may combine your personal information with that of all or a particular group of Website users to prepare collective and anonymous profiles of site users and their interests or behaviors.
Accomplishing our business purposes.
- For data analysis, for example, to improve the efficiency of the services we provide to our customers or to enhance, improve, or modify our current products and services.
- For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
- For fraud and security monitoring purposes, e.g., to detect and prevent cyberattacks or attempts to commit identity theft.
- To meet our legal and regulatory obligations.
- For identifying usage trends, for example, understanding which of our activities are of most interest to users.
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.

We engage in these activities with your consent, to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

If we contact you using your personal information, it will be via email. We only send emails to site visitors and users who sign up for one of our mailing lists or who agree to receive future communications from us. Our emails to you will contain clear information on how to unsubscribe from future communications. If you sign up for communications from us but then wish to unsubscribe, follow the unsubscribe instructions in the email you receive from us. Once we receive your unsubscribe request, we will cease our communication with you until and unless you re-subscribe for one of our mailing lists. You may also choose to stop receiving emails from us by notifying us at communications@ulupono.com at any time. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.

Where you have provided us with your personal information to receive newsletters or other marketing communications, we will store that information until you notify us that you no longer wish to receive these communications, or we determine that the information is no longer accurate.

Information we transfer or share with others

Consent: We may share information you submit to us with your consent or at your direction

Service providers: We may share your information with service providers we have retained to perform services on our behalf, for example, to host our Website or send email communications. We obligate these service providers to not use or disclose the information they receive from us except as necessary to perform services on our behalf or to comply with legal requirements.

External links:Our Website may include links to other websites whose privacy practices and policies we do not control. Once you leave our Website, disclosure or provision of your personal information, if any, is governed by the privacy policy and terms of use of the owner of the site you are visiting.

Compliance with law: In addition, we may disclose information about you (i) if we are required to do so by law; (ii) in response to a request from law enforcement authorities or other government officials; (iii) in connection with a judicial proceeding or to comply with a court order, law, or regulation applicable to us or the Website; or (iv) when we believe disclosure is necessary or appropriate to protect our property or assert our legal rights or to protect the property or safety of any other person.

Marketing choice and your rights to access and correct your personal information

We want to make sure that your personal information is accurate and up to date. You have the right to request access to and correction or deletion of your personal data, restrict processing concerning you and object to processing, as well as the right to data portability.

We will provide you with access to your personal information on request so you may view, update or correct your information. To protect your privacy and security, we will verify your identity before granting you access or enabling you to make corrections. You have the right to complain to a competent supervisory authority if you feel that we are not complying with our data protection obligations.

If you would like to access or correct your personal information or preferences, or have your information removed from our mailing list, please notify us at communications@ulupono.com.

How we protect personal personal information

To prevent unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss, and to ensure the correct use of information, we employ physical, technical, and administrative safeguards to protect against unauthorized disclosure, access to, or loss of the personal information we collect through the Website. All of our employees and any third parties we employ to process your personal information are obliged to respect its confidentiality. However, transmission of information through the internet is not secure. Although we seek to protect your information as described above, we cannot guarantee the security of any information you transmit to the Website or to us, and you transmit such information at your own risk.

Changes to our privacy policy

We regularly review our privacy policy to ensure that it provides an appropriate level of protection for your personal information and we may make changes to our Privacy Policy to keep it current with industry standards. We will post the date of the most recent revisions on this page. Check this page to make sure that you are current and up-to-date on our privacy policy. Any changes will become effective when we post the revised Privacy Policy on the Website. Your use of the Website following these changes means that you accept the revised Privacy Policy.

How to contact us

Should you have any questions or concerns about our privacy policy, send an email to communicatons@ulupono.com or contact us at:

Ulupono Initiative
P.O. Box 2938
Honolulu, HI 96802