PRIVACY POLICY

Last Updated December 9, 2024


This “Privacy Policy” describes 1) what information may be collected from you on our Websites (defined below) and through our services, 2) how we use this information, 3) under what circumstances we may disclose the information to third parties and 4) the choices you can make pertaining to your information collected through our Websites and Website Content (defined below), including the personally identifiable data you submit on our Websites or when using our services. This Privacy Policy is incorporated by reference into the “Terms of Use” linked in our Websites that set forth the general rules and policies governing your use of our Websites and services.  You should read this Privacy Policy in its entirety before accessing our Websites or using our services. WHEN YOU ACCESS OUR WEBSITES OR USE OUR SERVICES, YOU AGREE TO THIS PRIVACY POLICY.  IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, OR TO ANY CHANGES WE MAY SUBSEQUENTLY MAKE, IMMEDIATELY STOP ACCESSING OUR WEBSITES AND USING OUR SERVICES.  FURTHER, OUR WEBSITES ARE NOT TO BE ACCESSED AND OUR SERVICES ARE NOT TO BE USED BY ANYONE WHO IS NOT A U.S. RESIDENT OR UNDER 21 YEARS OF AGE.


“Websites” refers to the websites provided for your use by Universal Language Productions LLC and/or its shareholder(s)/member(s), owner(s), subsidiaries and affiliated entities/businesses, including, but not limited to, Lilholt Technology Solutions LLC, Universal Language Productions LLC DBA IVLEY, ULP TV LLC, OOMCOM LLC and Suxcom LLC (collectively, “ULP,” “us,” “we,” or “our”) where this Privacy Policy is linked, however accessed and/or used, whether via personal computers, mobile devices or otherwise (collectively, "Computer") and the products, software, services, interactive features, applications and downloads that are operated by us and that may be available through, or interact with, our Websites.  This Privacy Policy does not apply to our collection of information from other sources (unless specifically stated). “Website Content” includes any derivative works or enhancements of same, including, but not limited to, all layout, messages, text, illustrations, instructions, files, images, designs, software, scripts, graphics, photos, sounds, music, videos, information, audio/visual combinations, advertising copy, eBooks, materials, products, services, URLs, technology, documentation, interactive features, the "look and feel" of the Websites, the compilation, assembly and arrangement of the materials in the Websites and any and all copyrightable material (including source and object code).  By using our Websites, Website Content and services, you consent to our collecting, using and sharing information in accordance with this Privacy Policy.

The words “use” and “using” in this Privacy Policy mean any time an individual (a “user”) directly or indirectly, with or without the aid of a machine or device, does or attempts to access, interact with, display, view, print or copy from the Websites, transmit, receive or exchange data or communicate with the Websites, or in any way utilizes, benefits, takes advantage of or interacts with any function, service or feature of the Websites, for any purpose whatsoever.  This Privacy Policy does not cover your rights or responsibilities with respect to third-party content or websites or any links that may direct your browser or your connection to third-party websites or pages.  Users of IVLEY’s consulting services that use OpenAI ChatGPT should refer to the Privacy Policy of OpenAI in this regard (see Section G below).


We keep this Privacy Policy linked in our Websites and you should review it frequently to inform yourself of any changes in this Privacy Policy, as we reserve the right to change it from time to time without prior notice to you.  Any changes will be effective immediately upon posting of the revised Privacy Policy.  If we make changes to this Privacy Policy that materially modify our rights to use your previously collected personally identifiable information, notification may be made through a prominent posting on the Websites. Users of IVLEY’s consulting services should also check OpenAI’s website from time to time to inform yourself of any changes to OpenAI’s Privacy and related policies.  Your continued use of the Websites, Website Content and services after revised versions are made available constitutes your consent and agreement to the revisions.


A. INFORMATION WE COLLECT

Our Websites typically collect two kinds of information about you: (1) information that you provide that personally identifies you and (2) information that does not personally identify you that we automatically collect when you visit our Websites or that you provide us.


1. Personally Identifiable Information:

Our definition of personally identifiable information includes any information that may be used to specifically identify or contact you, such as your first and last name, email address, postal address, phone number and age.  As a general policy, we do not automatically collect such personally identifiable information when you merely visit our Websites; however, we may collect technical computer information from users of our Websites, including their Internet Protocol (“IP”) addresses, browser types, device configurations, location data, domain names, mobile devices information (such as the IMEI number), access times and cookies (described in Section B.2. below). 

In connection with a feature, program, promotion, service, online store or some other aspect of our Websites you choose to use, we may collect personally identifiable information such as: 

(a)  your first and last name, email address, phone number, shipping and billing addresses, birthdate, payment information, username and password when creating a User Account in our Websites, effecting a payment transaction, using our services, using our online stores or in connection with a contest entry; 

(b) certain demographic information about you (e.g., age, birthdate, gender, interests, favorites, purchase and other preferences, and usage frequency) when participating in a survey, poll or in forums and chat rooms; 

(c) the types of content you view or engage with, the features you use and the actions you take;

(d) your product, service or website ratings and reviews and recommendations on our Websites; or 

(e) your personal data, including your likeness, that may be contained in any video, comment or other submission you upload or post to the Websites.

To use our services and products, we request personally identifiable information from you.  If you choose not to provide such information, you cannot use that service or product.

Third parties performing sales processing and delivery services on our behalf, such as your credit card company, PayPal, Federal Express and United Parcel Service, will collect, store and use non-public personally identifiable information, such as your name, address, phone number, email address, PayPal information, and credit card number, expiration date and Card Verification Value (“CVV”) code.  In addition, the third-party’s payment system will also collect information regarding the actual bill payment transaction, including the date and amount paid. See Section G below regarding additional privacy considerations pertaining to such third parties and their handling of your personally identifiable information.  If made available to us by such third parties, we will store and protect personally identifiable information in the same manner that we store and protect other personally identifiable information.

Certain information may not be personally identifiable when standing alone (e.g., your age) but may become so when combined with other information (e.g., your age and name).  Whether or not you provide this information is your choice; however, in many instances this type of information is required to access a feature, purchase a product or service, participate in a particular activity, realize a benefit we may offer or gain access to certain content on our Websites.

Social Media Sites


If you choose to register or log in to our Websites using a social media account (such as through Facebook or X, formerly Twitter), we receive certain profile information from your social media provider may vary depending on the social media provider but will often include your name, email address, friends list, profile picture and other information you choose to make public on such social media platform.

Note that we may maintain pages on social media platforms, such as Facebook, X, Google, YouTube, Instagram, Pinterest and other third-party platforms.  When you visit or interact with our pages on such platforms (for example, if you “like” or share a post from one of our social media accounts), the platform provider may share information about you with us, including your public profile, email address and friends list.  If you post information on social media or another third-party service that references our brands or our products and services (e.g., via an X hashtag), we may publish your post on our social media accounts and Websites.  The platform’s privacy policy will apply to your interactions and their collection, use and processing of your personal data.

If you choose to log in to our Websites through a third-party platform or social media network, or otherwise connect your account on the third-party platform or network to your account through the Websites, we may collect information from that platform or network.  For example, this information may include your username, user ID, profile picture, cover photo, list of your friends and contacts, your email address,  networks to which you belong (e.g., school or workplace) and contents of messages you send.


In addition, social media sites may collect your IP address or set cookies.  If you choose to share information through social media sites, you should review the privacy policies of those providers.


We will use the information we receive only for the purposes disclosed in this privacy policy or that are otherwise made clear to you on the relevant Websites.  Please note that we do not control, and are not responsible for, other uses of your personal data by your third-party social media provider.  We recommend you review their privacy notice to understand how they collect, use and share your personal data, and how you can set your privacy settings on their sites and apps.

2. Non-Personal Data:


Our definition of non-personal data is any information that does not personally identify you.  Non-personal data can include certain personally identifiable information that has been de-identified (that is, information that has been rendered anonymous).  We and/or our third-party service providers obtain non-personal data about you from information that you provide us, either separately or together with your personally identifiable information.  We and/or our third-party service providers also automatically collect certain non-personal data from you when you access our Websites.

We may collect device-specific information, such as geographic location and your hardware model, operating system version and IP address, as well as event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.

If you have a User Account with us, you have the ability to review and update your personal data online by logging into your account through our Websites. Alternatively, any individual who seeks access, or who seeks to correct, amend or delete inaccurate data, may direct his or her query to us at our address in Section K below or privacy@ulp.ai.

Please include your full name and email address associated with your account and a detailed description of your data request. In some cases, we may not be able to delete your personal data and will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

 
We will either respond to your request or, if applicable and appropriate, make the requested change in our active databases as soon as reasonably practicable.  Note that we may not be able to fulfill certain requests while allowing you access to certain benefits and features of our Websites.  Also, note that it is not always possible to completely change, remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons.  Also, if you have made any public postings on the Websites, such as in forums or blogs, these communications are generally not removed by us.


B. HOW WE USE & SHARE THE INFORMATION COLLECTED


1. Personally Identifiable Information:

 

The personally identifiable information you submit to us is generally used to carry out your requests, respond to your inquiries, better serve you or in other ways naturally associated with the circumstances in which you provided the information.  We may also use this information to later contact you for a variety of reasons, such as customer service, for internal business purposes, for administrative notices, to manage your account, to provide you with information or services or process transactions that you have requested or agreed to receive, to perform surveys, to communicate with you about content or other information you  have posted or shared with us via our Websites or with regard to your use of the Websites or services, to verify your eligibility and deliver prizes in connection with our Promotions (see Section C.4. below), to develop and display content and advertising tailored to your interests on our Websites, to communicate, at our discretion, changes to the Websites and/or Website policies or for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.  We may use your personally identifiable information, and also disclose such personally identifiable information to our shareholder(s)/member(s),  owner(s), subsidiaries and affiliated entities/businesses (collectively, “Affiliates”), to provide you with marketing or promotional information for our products and services, including those of our Affiliates.  We do not sell, license or share your personally identifiable information with unaffiliated third parties for their marketing purposes.

 

In certain instances, we may also share your personally identifiable information with our third-party vendors performing functions on our behalf (or on behalf of our Affiliates) (e.g., vendors that process credit card orders; deliver our merchandise; administer our Promotions (see Section C.4. below); provide us marketing or promotional assistance; process, analyze or store our data; assist us with customer service; host our email system; and process transaction payments).  While providing services for us, these companies may access your personally identifiable information.  These vendors agree to use this information and we share information with them only to carry out our requests.  We may share your personally identifiable information with participating sponsors to a program or Promotion (see Section C.4. below) you enter via our Websites and with third parties who assist us in using the content or other information you have posted or shared with us via our Websites (e.g., production companies we may use). 

Without limiting the generality of the foregoing, you authorize us to share (1) your name; email address; shipping and billing addresses; and phone number with service providers, such as your credit card company, PayPal, Federal Express and United Parcel Service, to the extent necessary to process and deliver your orders for products or services and (2) your name and email and shipping addresses with other service providers that we utilize to provide customer support, marketing and other services. Any such third parties to whom we may disclose personally identifiable information may have their own privacy policies that describe how they use and disclose personally identifiable information. Those policies will govern use, handling and disclosure of your personally identifiable information once we have shared it with those third parties as described in this Privacy Policy. If you want to learn more about their privacy practices, we encourage you to visit the websites of such third parties. Those entities or their servers may be located either inside or outside the United States.


We may make your personal information non-personally identifiable by either combining it with information about other users (i.e., aggregating your personal data with information about other users) or by removing characteristics (such as your name or email address) that make the information personally identifiable. This process is known as de-personalizing your information. You grant us a royalty-free, worldwide, perpetual, irrevocable and fully transferable right and license to use your personal data in connection with the creation and development of non-personally identifiable information and analytical and statistical analysis tools relating to the use of the customer data we collect on the Websites (the “Analytical Data”). We are expressly authorized to make any commercial use of the Analytical Data, including, without limitation, sharing the Analytical Data with third parties.

2. Non-Personal Data:


In addition to any personally identifiable information or other information that you choose to provide to us on the Websites, we and our third-party service providers may use a variety of technologies, now and hereafter devised, that automatically collect certain website usage information whenever you visit or interact with the Websites.  This information may include browser type, operating system, the page served, the time, the source of the request, the preceding page view and other similar information.  We may use this usage information for a variety of purposes, including to enhance or otherwise improve the Websites.  In addition, we may also collect your IP address or some other unique identifier for the particular device you use to access the Internet, as applicable (collectively, referred to herein as a “Device Identifier”).  A Device Identifier is a number that is automatically assigned to your Computer, and we may identify your device by its Device Identifier.  When analyzed, usage information helps us determine how our Websites are used, such as what types of visitors arrive at the Websites, what type of content is most popular, what type of content you may find most relevant and what types of visitors are interested in particular kinds of content and advertising.  We may associate your Device Identifier or Website usage information with the personally identifiable information you provide, but we will treat the combined information as personally identifiable information.  Website usage information may be collected using various methods, such as the following:

 

Web Beacons - Small graphic images or other web programming code called web beacons (also known as “tracking pixels,” “1x1 GIFs,” or “clear GIFs”) that track user activities and communicate with cookies (see next paragraph) may be included in our Websites and email messages.  Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon.   Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Websites, to monitor how users navigate the Websites, to count how many emails that were sent were actually opened or to count how many particular articles or links were actually viewed. You cannot opt out of web beacons used in webpages but you can limit their use by opting out of the cookies with which they interact. You can opt out of web beacons used in emails by having your email render emails in text mode only.


Cookies - A cookie is a data file placed on a Computer when it is used to visit the Websites.  Cookies may be used for many purposes, including, without limitation, tracking user preferences and web pages visited while using the Websites, as well as improving your experience.  We may store some of the information described in this policy with cookies to help maintain your preferences across browsing sessions.  Cookies may also assist us in analyzing how our services are used and the effectiveness of our marketing campaigns.  You may be able to remove, reject and/or disable some types of cookies using your browser’s preferences or other programs.  Some features of the Websites may not function properly or may operate slowly if you disable, delete or refuse to accept cookies.  Some of the cookies we use may be “Flash” cookies.  A Flash cookie is a data file placed on a Computer via the Adobe Flash plug-in that may be built into or downloaded by you to your Computer.  While they are harmless, depending on your browser, these cookies may not be deleted when your cookies are deleted or disabled and, in some instances, they may cause your cookies to reappear in your browser.  Please check your browser to determine where these types of cookies are stored and how they may be deleted or disabled.


We may use third-party ad servers to support web beacons and cookies.

Mobile Device Identifiers - Certain mobile service providers uniquely identify mobile devices and we or our third-party service providers may receive such device information if you access the Websites through mobile devices.  Certain features of our Websites may require collection of mobile phone numbers and we may associate that phone number to mobile device identification information.  Additionally, some mobile phone service providers operate systems that pinpoint the physical location of devices that use their service.  Depending on the provider, we or our third-party service providers may receive this information.

 

Embedded Scripts - An embedded script is programming code that is designed to collect information about your interactions with the Websites, such as the links you click on.  The code may be temporarily downloaded onto your Computer from our web server or a third-party service provider, may be active only while you are connected to the Websites and is deactivated or deleted thereafter.

 

Information collected through passive means may be non-identifying or may be associated with you.  In the latter case, it will be treated as personally identifiable information.

 

We use non-personal data in a variety of ways, including to help analyze site traffic, understand customer needs and trends, carry out targeted promotional activities and to improve our services.  We may use your non-personal data by itself or aggregate it with information we have obtained from others.  We may share your non-personal data with our Affiliates and third parties to achieve these objectives but remember that aggregate information is anonymous information that does not personally identify you.  We may provide our analysis and certain non-personal data to third parties (who may in turn use this information to provide advertisements tailored to your interests), but this will not involve disclosing any of your personally identifiable information.

 

3. Information You Provide About A Third Party


If you send someone else a communication from the Websites, such as sending Website Content to a friend, the information you provide (e.g., names and email addresses) is used to facilitate the communication and may be used for other marketing purposes.  Please be aware that when you use any send-to-a-friend functionality on our Websites, your email address may be included in the communication sent to your friend. Similarly, if you use our Websites to upload, share and/or distribute content (including videos, comments or other submissions) and such content contains personal data about others, such information may be stored in order to allow for such uploading, sharing and/or distribution.


4. Information Third Parties Provide About You


We also may, from time to time, supplement the information we collect with outside records from third parties in order to enhance our ability to serve you, to tailor our content to you and to offer you opportunities to purchase products or services that we believe may be of interest to you.  We may combine the information we receive from those other sources with information we collect through the Websites.  In those cases, we will apply this Privacy Policy to any personally identifiable information received, unless otherwise specifically disclosed by us at the time you provide your personally identifiable information.

 

C. OTHER USES


1. Email Communications:

 

If you send us an email with questions or comments, we may use your personally identifiable information to respond to your questions or comments and we may save your questions or comments for future reference.  For security reasons, we do not recommend that you send non-public personally identifiable information, such as passwords, social security numbers or bank account information, to us by email.  Further, we may send you email under the following circumstances: (a) if you request a particular service or sign up for a feature that involves email communications; (b) if it relates to purchases you have made with us (e.g., product updates and customer support); (c) if we are sending you information about our or others’ products and services; (d) if you consented to being contacted by email for a particular purpose; (e) if you send us an email, post information on the Websites (e.g., a blog) or otherwise submit information to us electronically, we may email you to follow up or otherwise communicate with you with respect thereto; (f) to provide you legal notices or notices with respect to your use of the Websites; or (g) to otherwise facilitate a transaction between us.  In certain instances, we may provide you with tools on the Websites that will allow you to set your preferences for receiving email communications from us, such as product and service updates and improvements, special offers or special distributions of content.  You may “opt out” of receiving such future commercial email communications from us by following the instructions included at the bottom of the emails we send; provided, however, we reserve the right to send you transactional emails, such as customer service communications.


2. Transfer of Assets:

 

As we continue to develop our business, we may sell or purchase assets.  If another entity acquires us or all (or substantially all) of our assets, the personally identifiable information and non-personal  data we have about you will be transferred to and used by this acquiring entity, though we will take reasonable steps to ensure that your preferences are followed.  Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.

 

3. Other:


We may disclose your personal data to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services they render to us.

 

Notwithstanding anything herein to the contrary and without prior notice to you, we reserve the right to disclose any personally identifiable or non-personal data about you if we are required to do so by law, with respect to notices and counter-notices pursuant to the Digital Millennium Copyright Act of 1998, Title 17 of the United States Code, Section 512 and/or if we believe that such action is necessary to: (a) fulfill a law enforcement or governmental request; (b) conform with the requirements of any applicable law, regulation or legal process, such as a court order or subpoena; (c) protect or defend our legal rights or property, our Websites or other users; (d) if we determine, in our sole discretion, that there is a violation of our terms, policies or the law; (e) to detect or prevent fraud or other illegal activity; (f) to protect against legal liability; or (g) in an emergency to protect the health and safety of our employees, Websites’ users or the general public. 


Some web browsers incorporate a “Do Not Track” feature that signals to the Websites that you visit that you do not want to have your online activity tracked.  California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how we respond to “Do Not Track” signals.  How browsers communicate the Do Not Track signal is not yet uniform, so a standard technological response has not yet been developed by the policy and technological communities.  For this reason, we do not respond to “Do Not Track” signals currently and we await the result of work by the policy and technological communities to determine when such a response is appropriate and what form it should take.  


To the best of our knowledge, other parties do not collect personally identifiable information about your online activities over time and across different Websites when you use the Websites.


4. Promotions:

 

From time to time, we may conduct promotions on our Websites, such as but not limited to, contests, sweepstakes, surveys and giveaways (“Promotions”) that may require registration by participants, including furnishing your name, mailing address, email address, telephone number and/or date of birth.  By entering any Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion.  If you choose to enter a Promotion, personally identifiable information may be disclosed to third parties or the public in connection with the administration of such promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.

 

5. Third-Party Ad Server Networks:

The Websites may use third parties such as network advertisers to serve advertisements on the Websites and may use traffic measurement services to analyze traffic on the Websites. Network advertisers are third parties that display advertisements based on your visits to the Websites and other websites you have visited. Third-party ad serving enables us to target advertisements to you for products and services in which you might be interested. The Websites’ third-party ad network providers, the advertisers, the sponsors and/or traffic measurement services may themselves set and access their own cookies and other technologies on your Computer and track certain behavioral information regarding users of your Computer via a Device Identifier. These third-party cookies and other technologies are set to, among other things: (a) help deliver advertisements to you in which you might be interested; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you. Note that any images (or any other parts of a web page) served by third parties in association with third-party cookies may serve as web beacons, which enable third parties to carry out the previously described activities. Third-party cookies, web beacons and other third-party technologies are governed by each third-party’s specific privacy policy, not this one. While we may use a variety of companies to serve advertisements on the Websites, we do not provide a means for opting out of third-party targeted advertising on our Websites.  

 

D. PUBLIC FORUMS


We may offer chat rooms, message boards, bulletin boards or similar public forums where you and other users of our Websites can communicate.  The protections described in this Privacy Policy do not apply when you provide information (including personally identifiable information) in connection with your use of these public forums.  We may use personally identifiable and non-personal data about you to identify you with a posting in a public forum.  Any information you share in a public forum is public information and may be seen or collected by anyone, including third parties that do not adhere to our Privacy Policy.  We are not responsible for events arising from the distribution of any information you choose to publicly post or share through our Websites.

 

E. CHILDREN


The features, programs, promotions and other aspects of our Websites and services requiring personally identifiable information are not directed to, or intended for, children and as highlighted above, individuals under the age of twenty-one (21) are not permitted to use our websites or services.  Therefore, we do not knowingly collect personally identifiable information from children under the age of twenty-one (21).  If you are a parent or guardian of a child under the age of twenty-one (21) and believe he or she has disclosed personally identifiable information to us, please contact us at our address in Section K below or privacy@ulp.ai as a parent or guardian of a child under the age of twenty-one (21) may review and request deletion of such child’s personally identifiable information, as well as prohibit the use thereof.  If you are a child under the age of twenty-one (21) who has inappropriately accessed our Websites or services, please notify us at our address in Section K below or privacy@ulp.ai so that we can delete your personally identifiable information and not use such information.


F. RETENTION AND KEEPING YOUR INFORMATION SECURE


We retain your personally identifiable information for only as long as we need in order to provide our services to  you, or for other legitimate business purposes, such as resolving disputes, safety and security reasons, or complying with our legal obligations.  How long we retain personally identifiable information will depend on a number of factors, such as:


  • Our purpose for processing the data (such as whether we need to retain the data to provide our services);

  • The amount, nature and sensitivity of the information;

  • The potential risk of harm from unauthorized use or disclosure; or

  • Any legal requirements that we are subject to.


We have implemented security measures we consider reasonable and appropriate to protect against the loss, misuse and alteration of the information under our control.  Please be advised, however, that while we strive to protect your personally identifiable information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and are not responsible for the theft, destruction or inadvertent disclosure of your personally identifiable information.  Therefore, you should take special care in deciding what information you provide to us when using our Websites or services.  In the unfortunate event that your “personally identifiable information” (as the term or similar terms are defined by any applicable law requiring notice upon a security breach) is compromised, we may notify you by email (at our sole and absolute discretion) to the last email address you have provided us in the most expedient time reasonable under the circumstances provided, however, that delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system, as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation.


G. OTHER SITES/LINKS


Our Websites may link to or contain links to other third-party websites or applications that we do not control or maintain, such as in connection with purchasing products referenced on our Websites and banner advertisements.  Also see Section A.1. regarding the use of third-party social media sites by you and us and privacy considerations pertaining to your personally identifiable information.  We are not responsible for the privacy practices employed by any third-party website or application.  The owners of these websites and applications (“Third-Party Owners”), such as your credit card company, PayPal, Federal Express and United Parcel Service that facilitate transactions between you and us, will collect from you, store and use non-public personally identifiable information, such as your name, address, phone number, email address, PayPal information, and credit card number, expiration date and CVV code.  Such Third-Party Owners have their own privacy policies and practices.


You should note when you leave our Websites.  We are not responsible for how Third-Party Owners or their applications use your personally identifiable information.  When you click on a third-party logo or URL displayed on our Websites that links you to a different third-party website or application, our Privacy Policy no longer applies.  These Third-Party Owners have their own terms of use, privacy policies or other policies and ask you to agree to the same. You must read the terms of use, privacy and other policies of the third party to see how your personal data will be handled on their website.  If you cannot find the Third-Party Owner’s privacy and related policies, then you should contact the respective webmasters of those websites to obtain information regarding their information collection, use and disclosure policies.  We are not responsible for the collection and use of your personally identifiable information by, nor the policies or practices of, Third-Party Owners.  Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it.

Specifically, users of IVLEY’s consulting services will need to use, currently, OpenAI ChatGPT (“ChatGPT”).  OpenAI is a third party unaffiliated with us.  To avail yourself of and potentially benefit from IVLEY’s consulting services, you will need to use ChatGPT which currently will require you to pay usage fees to OpenAI.  Because we are not affiliated with OpenAI, we do not receive any financial remuneration from your payment of usage fees to OpenAI.  


USERS OF IVLEY’S CONSULTING SERVICES AND OUR RELATED WEBSITES SHOULD REFER TO OPENAI’S TERMS & POLICIES, TERMS OF USE, SERVICE TERMS, USAGE POLICIES, SAFETY BEST PRACTICES, MODERATION, SHARING & PUBLICATION POLICY, PLUGINS & ACTIONS TERMS, DATA PROCESSING ADDENDUM, APPROACH TO PATENTS, BUSINESS TERMS, PRIVACY POLICY, HOW CHATGPT AND OUR (OPENAI’S) FOUNDATION MODELS ARE DEVELOPED, ENTERPRISE PRIVACY AT OPENAI, AND EUROPE PRIVACY POLICY, AMONG OTHERS, WITH REGARD TO YOUR USE OF CHATGPT.  FURTHER, AN ARTIFICIAL INTELLIGENCE MODEL SUCH AS CHATGPT LEVERAGES USER CONTENT TO IMPROVE ITS CAPABILITIES.  REAL-WORLD PROBLEMS AND DATA YOU ENTER OR THAT ARE CONTAINED IN YOUR CONVERSATIONS WITH CHATGPT MAY BE USED TO IMPROVE ITS CAPABILITIES.  CONSEQUENTLY, YOU SHOULD NOT SHARE ANY CONFIDENTIAL OR SENSITIVE INFORMATION WITH CHATGPT WHEN USING IVLEY’S CONSULTING SERVICES.


H. U.S. STATE DATA PRIVACY CONSIDERATIONS


Some states in the U.S. have privacy laws and regulations that require, subject to applicable statutory and regulatory exceptions, companies to make certain disclosures and grant certain rights to their users who are residents of such states regarding privacy matters.  Currently, we are generally exempt from such requirements but have included in this Section a summary of such disclosures and rights.


Depending on the state of residence and subject to applicable statutory and regulatory exceptions, resident users have the following privacy rights in regard to personally identifiable information to:


  • Know what categories of personally identifiable information we collect and why.

  • Update, access, correct or delete your personally identifiable information.

  • Access information relating to how your personally identifiable information is processed.

  • Opt out of targeted advertising or the sale or sharing of your personally identifiable information.

  • Transfer your personally identifiable information to a third party (i.e., right to data portability).

  • Restrict or object to how we process your personally identifiable information.

  • Withdraw your consent, where we rely on consent as the legal basis for processing your personally identifiable information.

  • Lodge a complaint with your local data protection authority.


The following provides additional information about the categories of personally identifiable information we collect and how we use and disclose that information.  You can read more about the personally identifiable information we collect and where we collect it from in “Information We Collect” above, how we use personally identifiable information in “How We Use & Share the Information Collected” and “Other Uses” above, and how we retain personally identifiable information in “Retention and Keeping Your Information Secure” above.


We collect the following information, as described above:


  • Identifiers, such as your name, contact details, IP address and other device identifiers.

  • Commercial information, such as your transaction history.

  • Network activity information, such as Website Content and how you interact with our services.

  • Communication information, such as your contact information when you send us email.

  • Geolocation data, such as the general area from which your device accesses our services based on information like its IP address, or precise location information you choose to provide.

  • Your account credentials and payment information.


We use this information for the following purposes, as described above, to:


  • Provide, analyze, maintain and improve our Websites and services.

  • Communicate with you.

  • Prevent fraud, illegal activity or misuse of our Websites and services.

  • Protect the security of our systems, Websites and services.

  • Comply with legal obligations and protect the rights, privacy, safety or property of our users or third parties.,


We may disclose information in the following circumstances, as described above:


  • Vendors, service providers and Affiliates to process transactions in accordance with our instructions.

  • Government authorities or other third parties for the legal reasons described above.

  • Parties involved in transactions.


We do not “sell” personally identifiable information to, “share” personally identifiable information for cross-contextual behavioral advertising by, or process personally identifiable information for “targeted advertising” purposes (as those terms are defined under state privacy laws) by, third parties. We also do not process sensitive personally identifiable information for the purposes of inferring characteristics about a consumer.


You can learn more about such privacy rights by contacting us at the address in Section K below or privacy@ulp.ai .  We will not discriminate against individuals who exercise their privacy rights under state law.


I.  INTERNATIONAL CONSIDERATIONS


OUR WEBSITES ARE OPERATED IN THE UNITED STATES AND THE INFORMATION WE COLLECT IS TRANSFERRED AND PROCESSED WITHIN THE UNITED STATES.  THE DATA PROTECTION AND OTHER LAWS OF THE UNITED STATES MIGHT NOT BE AS COMPREHENSIVE AS THOSE OF OTHER COUNTRIES.  CONSEQUENTLY, THE WEBSITES ARE INTENDED FOR USERS LOCATED ONLY IN THE UNITED STATES.  IF YOU ARE LOCATED OUTSIDE THE UNITED STATES, DO NOT USE THE WEBSITES.


J. SOLE STATEMENT


This Privacy Policy as posted is the sole statement of our privacy policy with respect to the Websites and services and no summary, modification, restatement or other version thereof or other privacy statement or policy in any form is valid unless we post a new or revised policy to the Websites.


K.  CONTACTING  US


Should you need to contact us, our mailing address is:

Universal Language Productions LLC

Lilholt Technology Solutions LLC

IVLEY

P.O. Box 7

Palmyra, NJ  08065