The Upsilon Sigma Phi (“Upsilon Sigma Phi” or “we”, “our”, “us”) is committed to protect and respect your right to data privacy. This Privacy Notice is intended to inform users and website visitors (“you”) regarding our policies on data privacy.

The Upsilon Sigma Phi operates the website https://directory.upsilon.com/ (the “website”). The website is intended to collate information regarding the members of the Upsilon Sigma Phi to be accessed only by members of the Upsilon Sigma Phi and not by the general public.

By signing in using your Facebook, Google or Yahoo account, you accept the policies and procedures that we employ in relation to the collection and use of any personal data that you may disclose through the website. We may update this Privacy Notice from time to time as we improve our services. We will notify you of any changes that would substantially affect your data privacy rights and ask for your consent to such changes.

The Upsilon Sigma Phi is the personal information controller of any personal data that you disclose on the website.

The Upsilon Sigma Phi will only collect information from its members through the following channels:

• when you submit information by registering to use the website;
• when you message us through any of our social media accounts on Facebook and Google.

When you send us a message, we collect your Name, E-mail Address, and the contents of the message you send to us.

When you message us through any of our social media accounts, we will collect the contents of your message. We may also view the details of your public profile.

When you sign in using your Facebook, Google or Yahoo account, we collect your Name, E-mail Address and URL link to your public profile which we only use for our verification process.

When you submit your personal data, your personal data will be used for the following purposes:

1. To register you to use the website;
2. To communicate with you through any communication channel regarding any questions, concerns, or complaints that you may have in relation to your use of the website, your transactions, and exercise of your data privacy rights;
3. Improvement of the website;
4. To conduct direct marketing activities, such as e-mail announcements and other promotional activities;
5. To comply with statutory and regolatory requirements, including directives, issuances by, or obligations of the Upsilon Sigma Phi to any competent authority, regulator, supervisory body, enforcement agency, exchange, court, quasi-judicial body, or tribunal;
6. To enable the Upsilon Sigma Phi to exercise sound corporate governance over its businesses, ensure that risks arising therefrom are duly identified, measured, managed and mitigated, and enhance risk assessment and prevent fraud;
7. To conduct audits, investigate complaints and security threats;
8. Other legitimate business purposes;
9. Fulfill any other purposes directly related to the above-stated purposes.

The Upsilon Sigma Phi does NOT disclose any data collected to any 3rd party entity.

You may inform us of the specific personal information you do not want to be processed beyond the requested purpose. We will respect your request in so far as it is feasible to fulfill the purposes for which the personal data was collected.

We will retain your personal data for as long as you are registered at the website or until you request us to delete your personal data by contacting us if you no longer wish to keep your account. Your data will be stored on the secure servers of our third party service providers, which may be located in different locations, depending on the service provider.

The Upsilon Sigma Phi shall take commercially reasonable precautions to protect your personal data. Unfortunately, no data transmission over the internet can be considered as 100% secure. However, once the information has been received by the Upsilon Sigma Phi, it employs and observes security procedures and policies commensurate with industry standards to safeguard against loss, theft, unauthorized access, destruction, use, modification and disclosure. Further, the Upsilon Sigma Phi retains your personal information only as long as necessary to fulfill the purposes declared in this Privacy Notice or as may be required by law. When such purposes are fulfilled, the Upsilon Sigma Phi shall anonymize your information.

Only members of the Upsilon Sigma Phi are mandated to operate and hold personal data under strict confidentiality. They are required have received training on our privacy and security policies to ensure confidentiality and security of personal data.

You are entitled to the following rights:
1. The right to be informed on whether your personal information shall be, are being or have been processed;
2. Be furnished with the information indicated below before the entry of your personal information into the processing system of the personal information controller, or at the next practical opportunity:
   1. Description of the personal information to be entered into the system;
   2. Purposes for which they are being or are to be processed;
   3. Scope and method of the personal information processing;
   4. The recipients or classes of recipients to whom they are or may be disclosed;
   5. Methods utilized for automated access, if the same is allowed by the data subject, and the extent to which such access is authorized;
   6. The identity and contact details of the personal information controller or its representative;
   7. The period for which the information will be stored; and
   8. The existence of their rights, i.e., to access, correction, as well as the right to lodge a complaint.
3. Any information supplied or declaration made to you on these matters shall not be amended without prior notification.
4. Reasonable access to, upon demand, the following:
   1. Contents of your personal information that were processed;
   2. Sources from which personal information were obtained;
   3. Names and addresses of recipients of the personal information;
   4. Manner by which such data were processed;
   5. Reasons for the disclosure of the personal information to recipients;
   6. Information on automated processes where the data will or likely to be made as the sole basis for any decision significantly affecting or will affect you;
   7. Date when your personal information was last accessed and modified; and
   8. The designation, or name or identity and address of the personal information controller.
5. Dispute the inaccuracy or error in the personal information and have the personal information controller correct it immediately and accordingly, unless the request is vexatious or otherwise unreasonable. If the personal information has been corrected, the personal information controller shall ensure the accessibility of both the new and the retracted information and the simultaneous receipt of the new and the retracted information by recipients thereof: Provided, That the third parties who have previously received such processed personal information shall be informed of its inaccuracy and its rectification upon your request;
6. Suspend, withdraw or order the blocking, removal or destruction of your personal information from the personal information controller’s filing system upon discovery and substantial proof that the personal information are incomplete, outdated, false, unlawfully obtained, used for unauthorized purposes or are no longer necessary for the purposes for which they were collected; and
7. Be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal information.
8. Right to data portability - where personal information is processed by electronic means and in a structured and commonly used format, you have the right to obtain from the personal information controller a copy of data undergoing processing in an electronic or structured format, which is commonly used and allows for further use.

If you have further questions or concerns about this data privacy notice, or if you wish to exercise your rights as a data subject, you may contact our Data Privacy Team through data-privacy-officer@upsilon.com