This Privacy Policy describes our policies on the collection, use, and disclosure of your information in connection with your use of our websites, emails, and mobile applications (“Site”). The terms “we”, “us”, and “WUP” refer to New Hopian Ventures, Inc. d/b/a whadaUpay.com. When you use the Site, you consent to our collection, use, and disclosure of your information as described in this Privacy Policy.
I. Information You Submit
We may store the information you submit to or through the Site. We use the information to fulfill your requests, provide Site functionality, improve Site quality, personalize your experience, display relevant advertising, provide customer support, message you, back up our systems, allow for disaster recovery, and comply with legal obligations. Among the information you submit to or through the Site, please note:
	a.	Account Registration: You must provide a valid email address in order to sign up for an Account on the Site. In addition, you may provide us with your full name. When you sign up for a whadaUpay account, we opt you in to receive emails from other whadaUpay users, business owners and whadaUpay by default. You can manage your email preferences and modify some of the information associated with your account . Note that you cannot opt out of receiving required administrative or legal notices.
	b.	Public Content: Your reviews, tips, posted content, and other content you post to the Site are meant for public consumption. We may display this content on the Site, and further distribute it to a wider audience through third party sites and services. In addition to the foregoing, WUP will present pricing data to Vendors in an aggregated format (regular and/or normalized) where possible, rather than individual customer information. However, specific circumstances, including but not limited to the amounts and types of data present in the system for a given Vendor, may permit a Vendor to identify You based on Your prior relationship with the Vendor.
	c.	Contacts: You can invite your friends to join the Site by providing their contact information. If you invite a friend to join and connect with you on the Site, we may use and store your friends’ contact information long enough to process your requests.
For more information on controlling your personal data, please see Sections 4 and 5, below.
II. Information We Collect
In addition to the information you submit to or through the Site, we also collect and store information from and about you in the course of your use of the Site. We use this information to analyze and track user behavior, personalize your experience, associate it with other information about you, provide the functionality and improve the quality of the Site, and may use it to display relevant advertising. For example:
	a.	Location: We may collect and store information about your location if you enable your computer or mobile device to send us location information. You may be able to change the settings on your computer or mobile device to prevent it from providing us with such information.
	b.	Activity: We may collect and store information related to you and your use of the Site, such as your browser type, IP address, unique device identifier, the phone numbers and names of businesses that you call through the Site, requested URL, referring URL, browser language, the pages you view, and the date and time of your visit.
	c.	whadaUpay Cookies: We may use cookies, web beacons, local shared objects (sometimes called “flash cookies”), and similar technology in connection with your use of the Site (“Cookies”). Cookies may have unique identifiers, and reside, among other places, on your computer, in emails we send to you, and on our web pages. Cookies may transmit information about you and your use of the Site, such as your browser type, search preferences, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. You can disable some (but not all) Cookies in your device or browser settings, but doing so may affect your ability to use the Site. To learn how to manage privacy and storage settings for local shared objects in particular, click here.
III. Third Parties
We do not rent, share, sell or trade personally identifiable information with third parties for their direct marketing purposes. That said, we work with third parties and they may have access to some of your information:
	a.	Advertising: We allow third parties who provide advertising services to use Cookies, as defined above, in connection with your use of the Site. As a result, they may collect and store the same type of information and use it for the same type of purposes as described for whadaUpay Cookies above, and they may be able to associate the information they collect with other information they may have about you. We do not necessarily have access to or control over the Cookies they use. Nevertheless, you may be able to opt-out of some of their practices by visiting the following links: Network Advertising Initiative, Omniture, Aperture and PrivacyChoice Please note that opting out does not prevent you from receiving advertisements.
	b.	Service Providers: We outsource some of our technical and customer support, tracking and reporting functions, quality assurance testing, payment processing functions, and other services to third parties. We may share information from or about you with them so that they can perform their services.
	c.	Aggregate Information: We may share user information in the aggregate with third parties, such as advertisers and content distributors. For example, we may disclose the number of users that have been exposed to, or clicked on, advertisements.
	d.	Business Transfers: We may share information from or about you with subsidiaries, joint ventures, or other companies under common control, in which case we will require them to honor this Privacy Policy. If another company acquires whadaUpay or all or substantially all of our assets, that company will possess the same information, and will assume the rights and obligations with respect to that information as described in this Privacy Policy.
	e.	Investigations: We may investigate and disclose information from or about you if we have a good faith belief that such investigation or disclosure is (a)reasonably necessary to comply with legal process and law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process served on us; (b)helpful to prevent, investigate, or identify possible wrongdoing in connection with the Site; or (c)protect our rights, reputation, property, or that of our users affiliates, or the public.
	f.	Links: The Site may contain links to unaffiliated third party websites. Except as set forth herein, we do not share your personal information with them, and are not responsible for their privacy practices. We suggest you read the privacy policies on all such third party websites.
IV. Controlling Your Personal Data
WUP may use Your Content in connection with providing the services offered under the Site, but will keep confidential from other users and Vendors, and not attribute to you, personal contact information related to Your Content. Although your identity will remain confidential, pricing and other information you provide about Vendors may be reported or made available to them by WUP. WUP will present pricing data to Vendors in a normalized and aggregated format where possible, rather than individual customer information. However, specific circumstances, including but not limited to the amounts and types of data for a given Vendor, may permit a Vendor to identify you based on your prior relationship with the Vendor.
Please also note that the messages you send or receive using the Site are only private to the extent that you and the sender/recipient keep them private. For example, we do not have any control over whether a recipient of one of your personal messages publicly posts it or its contents.
V. Data Retention and Account Termination
The information we obtain from or about you may be processed and stored in the United States of America or anywhere else in the world. We may keep it as long as is permitted or required under the law. If you terminate your account, we will retain and continue to utilize the vendor or pricing information you provided during your membership, and may retain your other data for a period of 5 years (or longer if required by law) in our active systems in order to ensure our ability to satisfy the authorized uses under this Privacy Policy. For example, we may use retained data to prevent, investigate, or identify possible wrongdoing in connection with the Site or to comply with legal obligations. Please note that information may exist in backup storage even after it has been removed from our active databases. You can request that your account be terminated here. When logged into your account, you can remove or edit reviews that you have uploaded to the Site by clicking on the respective links below the review.
We will respond to requests relating to personal data sent from within the European Union according to the procedures mandated by the member state from where the request is sent. You will receive a response to your request within 30 days.
VI. Children
The Site is intended for general audiences and is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you become aware that a child has provided us with personal information without parental consent, please contact us. If we become aware that a child under 13 has provided us with personal information without parental consent, we take steps to remove such information and terminate the child’s account.
VII. Security
We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet or via mobile device, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
VIII. Dispute Resolution
If you believe that whadaUpay has not adhered to this Privacy Policy you may write to the whadaUpay Privacy Officer at the following address:
		whadaUpay Inc. support@whadaupay.com Attn: Privacy Officer
IX. Modifications to This Privacy Policy
We may revise this Privacy Policy from time to time. The most current version of the Privacy Policy will govern our use of your information and will be located on the site. If we make material changes to this Privacy Policy, we will notify our free trial or currently paid members by email or by posting a notice on the Site prior to the effective date of the changes. By continuing to access or use the Site after those changes become effective, you agree to be bound by the revised Privacy Policy.