Ulgen Holdings Inc (“Ulgen Holdings”, “we”, “us” or “our”) is a self-funded private holding company that builds technology companies. We are a Delaware corporation with our office at 165 Broadway, 23rd Floor, New York, NY 10006. This Privacy Policy describes how we process personal information that we collect through ulgen.holdings and any other website or online service that links to this policy, and through our communications with you (together, the “Service”).
Notice to European users: if you are in the European Economic Area or the United Kingdom (“Europe”), please also read the Notice to European users below. If you live in a U.S. state with a consumer privacy law, see the State privacy rights notice.
Personal information we collect
Information you provide to us
- Contact data, such as your name, email address, phone number, company and job title, when you share them with us.
- Communications data, meaning the content of the emails, calls and other correspondence you exchange with us, for example about our companies, press coverage or a business opportunity.
The Service has no accounts, forms or checkout, so we only receive the information above when you choose to contact us.
Information we collect automatically
- Device data, such as your IP address, browser type and version, operating system, device type and language settings.
- Online activity data, such as the pages you request, the page that referred you, and the date and time of each request.
Our servers and our network provider, Cloudflare, record this information in logs so that the Service can be delivered and protected. We do not use analytics, advertising or social media tracking technologies on the Service, and we do not build profiles of visitors.
Third-party sources
We may receive personal information from service providers that help us operate the Service, such as security signals from Cloudflare, and from parties involved in an actual or prospective business transaction, such as a merger, acquisition or reorganization.
Cookies and similar technologies
The Service uses only what it needs to work securely:
- A security cookie. Our web server’s firewall sets one cookie, named
server_session_followed by a code. It holds a value the firewall uses to tell legitimate visitors from automated attacks, lasts up to 10 days and is strictly necessary for security. - Cloudflare cookies. Cloudflare may set its own strictly necessary security cookies when it checks traffic for abuse.
- Local storage. If you choose a light or dark theme, your choice is saved in your browser’s local storage. It stays on your device and is never sent to us.
Because these technologies are strictly necessary or only remember a choice you made, we don’t ask for consent to use them. You can block or delete cookies and local storage in your browser settings, although parts of the Service may then stop working.
How we use your personal information
We use personal information for the following purposes, or as otherwise described when we collect it:
- Service delivery and operations: to provide and operate the Service, communicate with you, and respond to your requests, questions and feedback, including press and business inquiries.
- Security: to keep the Service and our systems secure, and to prevent, detect and investigate attacks, fraud and other abuse.
- Compliance and protection: to comply with applicable laws, lawful requests and legal process; to protect our, your or others’ rights, privacy, safety or property, including by making and defending legal claims; to audit our compliance with legal and contractual requirements; and to enforce our Terms of use.
- Corporate events: in connection with an actual or prospective business transaction, as described in How we share your personal information.
- Aggregated and de-identified data: to create aggregated or de-identified information, such as traffic statistics from server logs, which we may use for any lawful business purpose. We will not attempt to re-identify such data.
If we want to use personal information for a further purpose that is not compatible with the purpose for which we collected it, we will ask for your consent first.
Retention
We keep personal information only for as long as we need it for the purposes for which we collected it, including to meet legal, accounting or reporting requirements, to establish or defend legal claims, and to prevent fraud. Server logs are kept only as long as needed for security and operations. Correspondence is kept for as long as it is relevant to the conversation, or longer where the law requires it.
To decide how long to keep personal information, we consider its amount, nature and sensitivity, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it and whether we can achieve them by other means, and the applicable legal requirements. When we no longer need personal information, we delete or anonymize it, or, if that is not possible (for example, because it is stored in backups), we securely store it and isolate it from further processing until it can be deleted.
How we share your personal information
We may share personal information with the following parties, or as otherwise described when we collect it:
- Affiliates: our subsidiaries and affiliates, where they help us respond to you or operate the Service.
- Service providers: companies that provide services on our behalf, such as hosting on servers we operate, content delivery and security (Cloudflare), email (Google) and telephone services. They may use personal information only to provide those services to us.
- Professional advisors: lawyers, auditors, bankers and insurers, in the course of the professional services they provide to us.
- Authorities and others: law enforcement, government authorities and private parties, where we believe in good faith that it is necessary or appropriate for the compliance and protection purposes described above.
- Business transferees: parties to an actual or prospective business transaction, such as a financing, merger, acquisition, reorganization, sale of assets or shares, or an insolvency, including an acquirer, successor or assignee of Ulgen Holdings.
We do not sell personal information, and we do not share it for targeted advertising. Nuxo, IPAware and the other companies we build run their own websites under their own privacy policies.
Your choices
- Access, correction and deletion: you can ask us about the personal information we hold about you, and ask us to correct or delete it, by emailing [email protected]. Additional rights may apply depending on where you live; see the State privacy rights notice and the Notice to European users.
- Communications: we don’t send marketing emails from the Service. If you ask us to stop contacting you, we will.
- Cookies and local storage: see Cookies and similar technologies.
- Browser signals: we don’t track visitors across other websites or use personal information for targeted advertising, so signals such as “Do Not Track” and Global Privacy Control don’t change how the Service works for you. We honor Global Privacy Control as an opt-out request where the law requires it.
- Declining to provide information: you don’t have to give us any personal information to use the Service. If you contact us without the information we need to answer, we may not be able to help.
Other sites and services
The Service contains links to websites and services operated by others, including nuxo.io, ipaware.io, the websites of our other companies, LinkedIn, Google Maps and the publications that have written about us. These links are not an endorsement, and we do not control those websites or how they handle your information. Please read their privacy policies.
Security
We use technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.
International data transfers
We are headquartered in the United States, and we and our service providers operate in other countries as well. Your personal information may therefore be transferred to, stored in and processed in the United States and other locations where privacy laws may not be as protective as those in your state, province or country. Users in Europe should read the information about transfers out of Europe below.
Children
The Service is not intended for anyone under 18 years of age, and we don’t knowingly collect personal information from children. If you are a parent or guardian and believe that we have collected personal information from a child in a way prohibited by law, please contact us. If we learn that we have done so, we will comply with the applicable legal requirements to delete it.
Changes to this Privacy Policy
We may change this Privacy Policy at any time. If we make material changes, we will update the date at the top of this page and post the updated policy on the Service. Changes take effect when we post them, unless we say otherwise.
How to contact us
If you have questions about our practices or want to exercise a privacy right available to you, contact us:
- Email: [email protected]
- Mail: Ulgen Holdings Inc, 447 Sutter St, #1235, San Francisco, CA 94108, United States
- Phone: +1 415 660 9424
State privacy rights notice
This section applies to residents of U.S. states whose consumer privacy laws apply to us and grant the rights described below (the “State Privacy Laws”). Not every right is available in every state, and some State Privacy Laws may not apply to us at all. For this section, “personal information” has the meaning given to “personal data”, “personal information” or similar terms in the State Privacy Laws.
Your privacy rights
- Information and access: you can ask what categories of personal information we have collected about you, the sources and purposes, the categories of third parties we disclose it to, and for a copy of it.
- Correction: you can ask us to correct inaccurate personal information.
- Deletion: you can ask us to delete personal information we have collected from you.
- Opt-outs: we do not sell personal information, process it for targeted advertising, or use it for profiling or automated decisions that produce legal or similarly significant effects, so there is nothing to opt out of. We do not intentionally collect sensitive personal information.
- Appeal: if we decline your request, you can appeal our decision by replying to our response.
- Nondiscrimination: we won’t treat you differently for exercising these rights.
How to exercise your rights
Email [email protected] or call +1 415 660 9424. We may need to verify your identity, and may ask for information to do so, before we act on your request. Where the State Privacy Laws allow, you can use an authorized agent; we may ask for proof that you have authorized them and may verify your identity directly.
Information practices
The table below summarizes the personal information we have collected during the past 12 months, using the categories in the California Consumer Privacy Act. Information you choose to include in a message may contain other categories.
| Personal information | CCPA category | Purposes | Disclosed for a business purpose to | Sold or shared |
|---|---|---|---|---|
| Contact data | Identifiers; California customer records | Service delivery and operations; compliance and protection | Service providers; professional advisors; authorities; business transferees | No |
| Communications data | Identifiers; California customer records; professional information you choose to share | Service delivery and operations; compliance and protection | Service providers; professional advisors; authorities; business transferees | No |
| Device data | Identifiers; internet or other electronic network activity | Service delivery and operations; security; compliance and protection | Service providers; authorities | No |
| Online activity data | Internet or other electronic network activity | Service delivery and operations; security; aggregated statistics | Service providers; authorities | No |
We collect this information from the sources, and use it for the purposes, described earlier in this policy. We keep it according to the criteria in Retention, and we do not attempt to re-identify de-identified information, except to test whether our de-identification processes comply with the law.
California “Shine the Light”
We do not disclose personal information to third parties for their own direct marketing purposes.
Notice to European users
This section applies only to individuals in the European Economic Area and the United Kingdom. In this policy, “personal information” includes “personal data” as defined in the EU General Data Protection Regulation and the UK GDPR (together, the “GDPR”).
Controller
Ulgen Holdings Inc is the controller of the personal information covered by this Privacy Policy for the purposes of the GDPR. Our contact details are in How to contact us.
Our legal bases for processing
The GDPR requires us to have a legal basis for each purpose for which we use personal information. Ours are:
| Purpose | Personal information involved | Legal basis |
|---|---|---|
| Service delivery and operations | Contact data, communications data, device data, online activity data | Legitimate interests: running the Service and answering the people who contact us. Where you contact us about a contract with you, contractual necessity. |
| Security | Device data, online activity data | Legitimate interests: keeping the Service, our systems and our networks secure. Compliance with law, where security measures are legally required. |
| Compliance and protection | Any personal information relevant to the matter | Compliance with law. Where that does not apply, legitimate interests: following legal process and protecting our and others’ rights, property and safety. |
| Corporate events | Any personal information relevant to the transaction, kept to a minimum | Legitimate interests: enabling parties to an actual or prospective transaction to assess and continue our operations. |
| Aggregated and de-identified data | Device data, online activity data | Legitimate interests: understanding how the Service is used and making sure it works as intended. |
| Further uses | Any personal information relevant to the use | The original legal basis, where the further use is compatible with the original purpose; otherwise your consent. |
Sensitive information and automated decisions
Please don’t send us sensitive personal information, such as information about racial or ethnic origin, political opinions, religious or other beliefs, health, biometric or genetic data, criminal history or trade union membership. We do not make decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects.
Your rights
If you are in Europe, you can ask us to:
- Access your personal information and tell you how we process it.
- Correct inaccurate personal information.
- Delete personal information where there is no good reason for us to keep processing it.
- Transfer a machine-readable copy of your personal information to you or to a third party you choose.
- Restrict the processing of your personal information, for example while we check its accuracy.
- Object to processing based on our legitimate interests.
- Withdraw consent at any time, where we rely on your consent.
Send requests to [email protected] or to our postal address. We may ask for information to confirm your identity. If we decline a request in whole or in part, we will tell you why, subject to any legal restrictions.
You can also lodge a complaint with the data protection authority where you live. In the European Economic Area, you can find yours at edpb.europa.eu. In the United Kingdom, it is the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, telephone +44 303 123 1113, ico.org.uk.
Transfers out of Europe
We are based in the United States, and so are some of our service providers, so personal information we collect from you will be processed in the United States and possibly in other countries outside Europe. Not all of those countries are recognized as providing an adequate level of protection for personal information.
Where we transfer personal information out of Europe, we rely on one of these mechanisms: a decision or regulation recognizing the destination as adequate; appropriate safeguards, such as standard contractual clauses approved by the European Commission or the UK government; or, in limited cases, an exception the GDPR allows, such as a transfer that is necessary to respond to a request you sent us. Contact us for more information about the mechanism that applies, or for a copy of the relevant safeguards.