Universal Promotions Inc. (UPI) is a company that helps other businesses manage and administer sweepstakes, contests and promotions (“Promotions”). Such “Promotions” gather personally identifiable information from those individuals who choose to enter, and those individuals who are automatically entered into “Promotions”, and anonymous data regarding the promotion itself. UPI takes its obligations both to its clients and to the people who enter or who are automatically entered very seriously.
This policy outlines our treatment of personally identifiable information we collect on behalf of our clients. There are two (2) types of Promotions in which UPI is involved: 1) Client Promotions; 2) “Opt-in” to client Promotions.
As a full service promotions company, UPI manages and administers “Promotions” on behalf of its clients. As part of those services, UPI collects personally identifiable information for its clients by use of online technology, UPI mailboxes, and points of entry offline. UPI collects such personally identifiable information solely for the use of its clients, (at times a client may direct UPI to share the data with an authorized third party vendor of a client), and for the management and administration of its “Promotions”. Personally identifiable information collected by UPI on behalf of a client belongs solely to the client and will be used solely in accordance with that particular’s clients “Promotions” guidelines. UPI is not responsible for data collected on behalf of its clients when such data is in its client’s possession.