Upstream Principles Privacy Policy

Welcome to (the “Site”), operated by UPSTREAM PRINCIPLES, LLC (collectively, “Upstream Principles,” “we,” “us,” “our”).  This Privacy Policy is intended to help you understand how we collect and use the personal and confidential information you decide to share or provide through use of the Site and the services offered on the Site.  This Privacy Policy sets forth our privacy practices and the possible uses of the information that we gather via the Site.  This Privacy Policy applies to the Site, regardless of the medium in which it is accessed (e.g., mobile browser, computer browser, etc.). 


This Privacy Policy applies to your use of the Site, regardless of the medium by which the Site is accessed by you.

The Information We Collect

When you visit the Site and use any of the services provided via the Site, we may collect information as disclosed below.

Personal Information:  We collect personal information to provide the information or services requested by an individual.  "Personal information" refers to any information relating to an identified or identifiable individual who is the subject of the information.  For example, when you provide us with certain personal information, it may include your name, your email address, your telephone number, your address, and any other personal or preference information that you provide to us. 

Usage Information.  When you use and navigate the Site, we may collect additional information from you that may not by itself reasonably identify you as the source (collectively, "Usage Information").  Usage Information may include information regarding your mobile telephone, your computer, your IP address, the type of Internet browser you are using, the location from which you are visiting the Site, or the areas of the Site you visited and the actions you performed on the Site.

How We Collect Information

Directly from You.  We collect Personal Information from you when you voluntarily provide Personal Information to us by, for example, by completing various forms, or requests for information.

Through Your Use of the Site.  We record Usage Information that your browser transmits when you visit our Site.  We also collect Usage Information about how you access and interact with the Site through the use of automated tracking technology, such as "cookies" and "web beacons."  A cookie is a small data file that is transferred to a web browser, which enables our Site to remember and customize your subsequent visit.  Most Internet browsers automatically accept cookies.  You can instruct your browser to block the acceptance of cookies or to provide you with a warning prompt before you accept cookies from our Site.  Please refer to your Internet browser's instructions to learn more about these functions.  If you reject cookies, the functionality of the Site may be limited, and you may not be able to participate in several of the Site's features.  Additionally, we may use web beacons, which are single-pixel, electronic images embedded in the Site that allow us to gather information about your browsing activities on the Site.

How We Use Information

We process your Personal Information to carry out the purposes below and otherwise where we can rely on a legal ground for such processing. Where required by law, we will ask you for your prior consent.

Provision of the Site:  The Site is a medium for interaction between you and us.  We use and share the information we collect from you for the purposes described below.  If you use our Site, we use your information to process and respond to your applications, requests, comments, inquiries, and other forms you submit through the Site.

Improving Our Site:  We use your information to enhance our understanding of our users’ preferences and improve our Site accordingly 

Service Providers: We may employ third-party service providers to perform functions on our behalf.  They may have access to personal information needed to perform their functions, but may not use it for other purposes.

Legal Obligations: From time to time, we may be required to share personal information in response to a valid court order, subpoena, government investigation, or as otherwise required by law.  We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful or related to an alleged unlawful activity.

Protection of Upstream Principles and Others: We may release your information when we believe release is appropriate to comply with the law or any rule, regulation, government or court order; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of Upstream Principles, our affiliated companies, our users, or others.  However, this does not include selling, sharing, or otherwise disclosing personally identifiable information from customers for commercial purposes in violation of the terms set forth in this Privacy Policy.

Sale or Acquisition: If we become involved in a transaction involving the sale of our assets, such as a merger or acquisition, or if Upstream Principles is transferred to another company, we may disclose and/or transfer your information as part of the transaction.  If the surviving entity is not Upstream Principles, your information may be used pursuant to the surviving entity’s privacy policies, which may be different from this Privacy Policy.

Other Legitimate Interests:  We will use and disclose your information when necessary for our legitimate interests, as long as such interests are not overridden by our users’ interests, rights, and freedoms with respect to their Personal Information. 

Your Rights under the European General Data Protection Regulation (GDPR)

If your Personal Information is subject to the GDPR, you have the following rights under the GDPR:

  • To access the Personal Information we maintain about you
  • To be provided with information about how we process your Personal Information
  • To correct your Personal Information
  • To have your Personal Information erased
  • To object to or restrict how we process your Personal Information
  • To request your Personal Information to be transferred to a third party

To exercise the above rights, please contact us at the information we provide below.  We will consider and process your request within a reasonable period of time.  Please be aware that under certain circumstances, the GDPR may limit your exercise of these rights.

If your Personal Information is subject to the GDPR, we may transfer your Personal Information to countries outside the European Economic Area using appropriate safeguards when necessary.

If your Personal Information is subject to the GDPR, we will retain such Personal Information as long as necessary to process your request, or other submission; perform relevant activities in connection with other contracts or agreements you hold with Upstream Principles; and comply with applicable law. 

If your Personal Information is subject to the GDPR, at any time, you may withdraw consent you have provided to Upstream Principles for using, disclosing, or otherwise processing your Personal Information. You may withdraw your consent by contacting us using the contact information below, and following the instructions in our communication to you.  Please note that your withdrawal of consent to process certain Personal Information about you (1) may limit our ability to deliver the Site and/or services to you, and (2) does not affect the lawfulness of our processing activities based on your consent before its withdrawal.

You may file a complaint regarding this Privacy Policy or our privacy practices by contacting us using the contact information we provide below.  Additionally, if your Personal Information is subject to the GDPR, you may file a complaint with your national Data Protection Authority.


We take reasonable precautions to protect the information that is either available from or collected by this Site.  We have taken steps designed to safeguard the Site’s integrity, its telecommunications, and computing infrastructure, including but not limited to, authentication, monitoring, auditing, and encryption.  Unfortunately, no data transmitted over or accessible through the Internet can be guaranteed to be completely secure.  As a result, we cannot ensure or warrant that Personal Information will be completely secure from misappropriation by hackers, nefarious or criminal activities, or in the event of a failure of computer hardware, software, or a telecommunications network.


This Site may contain links to or information about other websites that are outside our control or custody.  We are not responsible for the content or privacy practices of other websites and suggest you review their privacy statements to understand how your information is used or shared by those other websites.  We do not endorse or make any representations or warranties concerning, and will not in any way be liable for, any informational content, products, services, software, or other materials available on other websites, even if one or more pages of the other websites are framed within a page of our Site.


This Privacy Policy was last modified on the date first printed above. 

We may periodically revise the Privacy Policy in our sole and absolute discretion to reflect changes in our business practices.  If we revise the Privacy Policy, we will notify you by posting the updated Privacy Policy Statement on the Site.  Changes to the Privacy Policy will become effective and will apply to the information collected starting on the date we post the revised Privacy Policy on the Site.  Your continued use of the Site after any change has become effective will constitute your acceptance of any change. 

Other Provisions

Your California Privacy Rights.   California law provides that California residents have a right to request businesses to tell them how their personal information has been shared, if at all, with third parties for the third parties' direct marketing purposes.  To make such a request, please contact us at the contact information listed below.

Do Not Track.  Certain web browsers and other devices you may use to access the Site may permit you to indicate your preference that you do not wish to be "tracked" online.  At this time, the Site does not respond to "Do Not Track" signals.

Children Under 13.  We do not market to and do not knowingly collect any Personal Information from or about a child under the age of 13 without the consent of the child's parent or legal guardian.  

Comments and Questions

If you have a comment or question about the Privacy Policy, please contact us at the contact information listed: