Uulala Privacy Statement

Last Updated: February 23, 2018

Privacy Policy

This Privacy Policy ("Policy") covers the following affiliated companies in the Uulala family of companies: Uulala, Inc., Uhhlala Holdings, LLC, and any of their affiliates and subsidiaries. These entities are collectively referred to as "affiliated companies," "we," "us," and "our" throughout this Policy

Privacy is our priority

We are committed to maintaining the privacy and confidentiality of our customers' personal information. In the course of offering and providing financial products and services, we collect and maintain certain personal information. This Policy explains what personal information we collect and how we use and share such personal information. It also explains what you can do to limit the use and sharing of your personal information.

We do not disclose personal information about our customers to non-affiliated third parties, except as described below.

What types of information do we collect?

When you apply for a financial product or service, open or maintain an account with us, or when you agree to allow us to participate in our token sale, we may collect the following types of information:

In addition, we may compile aggregate, anonymous, or de-identified data from various sources, including but not limited to accounts and transactions. This data, which we may use for our business purposes consistent with applicable law, does not identify individual customers.

When do we disclose personal information and to what types of entities do we disclose personal information?

We may disclose personal information we collect, such as the categories described above, to make our financial products and services, as well as those offered by our service providers, available to you. We may also use and disclose personal information with your consent. If you decide to withhold certain information, it may limit our ability to provide you with the services or products you requested or that may be of interest to you. We do not disclose personal information about former customers to anyone outside of our affiliated companies except as permitted or required by law; to cooperate with regulators and law enforcement authorities; and to current or former corporate customers of Uulala to provide reporting and other services consistent with the terms of an employee stock plan.

We may disclose your personal information to the following entities:

We require that commercial entities (as described above) with which we share your personal information agree to keep your information confidential. We also prohibit those entities from using or disclosing your information except for a limited purpose and to the persons for whom disclosure was intended, or as otherwise permitted or required by law. Service providers to whom we disclose personal information must agree to contractual requirements consistent with our privacy and security policies. We prohibit our service providers from using personal information except for the specific purpose for which we provide to them, and we require them to comply with legal obligations applicable to the personal information at issue.

We may disclose information about your external financial accounts to our affiliated companies to provide you with account aggregation services and for marketing purposes unless you opt-out of such sharing.

We will request your consent before we use or disclose your personal information for a materially different purpose than those set forth in this Policy. Consent may be obtained by any legally sufficient method. For example, depending on the circumstances and applicable laws, consent may be obtained by providing you with notice and the opportunity to opt-out.

How may you limit the sharing of your personal information?

You may limit or "opt-out" of our sharing your personal information with non-affiliated third parties for their marketing purposes. However, because we do not currently share your personal information with any non-affiliated third party in a manner that would trigger this opt-out right, there is no need at this time for you to opt-out or take any other action telling us not to share such information with non-affiliated third parties.

You may also opt-out of our sharing certain personal information (for example, information other than your transactions and experiences with us, such as your credit report) among our affiliated companies. However, because we only share information about your transactions and experiences (for example, account balance, transaction activity, and account history) with our affiliated companies, there is no need at this time for you to exercise your opt-out right.

Finally, you may also limit certain kinds of marketing from our affiliated companies. You may elect to restrict our affiliated companies from marketing their products or services to you based on information about you that we share with them. Since our affiliated companies engage in such marketing from time to time, we are providing you with the ability to opt-out so that you do not receive these marketing communications in the future. To limit these marketing offers, please contact us by using the mail or telephone contact information provided below.

Your choice to limit marketing offers from our affiliated companies will apply until you tell us otherwise. You may change your opt-out status at any time. For consumers with joint accounts, an opt-out direction by one joint account holder will be treated as applying to all of the associated joint account holders.

Where do we store personal information?

The personal information that we collect from you will be stored in the United States and other countries that may have different privacy laws and standards than those in your country of residence. Your personal information may be transferred to or processed in the United States by us or by a third-party service provider working for us. By submitting personal information via our website or other means, you agree to such storage, transfers and processing.

Our third-party service providers may hold your personal information in countries other than your own, including the United States. You acknowledge and understand that the protection of your personal information will be subject to the applicable laws of each such jurisdiction, which may not provide for the same protection as your country of residence. For example, government entities in the United States and other countries may have certain rights to access your personal information. If you have questions about our policies and practices with respect to service providers outside your jurisdiction, including the collection, use, disclosure, or storage of personal information by our service providers worldwide, and you are entitled by applicable law to be provided this information, you may contact our Chief Privacy Officer by e-mail at compliance@Uulala.io. Please provide your first and last name and street address in your request.

How do we protect the confidentiality and security of personal information?

We maintain reasonable physical, administrative, and technical safeguards to protect your personal information from unauthorized access and use. Our employees and third-party service providers have access to your personal information only on a "need to know" basis, and we use security measures that comply with applicable federal and state laws. These measures may include device safeguards and secured files and buildings to ensure information remains confidential and secure.

What should I know about tracking technologies, “interest-based advertising” and “do not track”?

Tracking Technologies

We and our third-party service providers may collect and store certain information when you visit or interact with our website (“Usage Information”). This Usage Information may be stored or accessed using tracking technologies such as “cookies” and “web beacons” that may be downloaded to your personal computer, tablet, mobile phone or other device (“Device”) when you visit or interact with our website. Usage Information may include but is not limited to:

"Cookies" are small amounts of data that a website can send to your web browser and store on your computer. Cookies do not contain personal information (unless you knowingly provide it). We use both HTML cookies and Local Shared Objects (sometimes referred to as Flash cookies) that are built for use with the Adobe® Flash® Player for authentication purposes and to enhance navigation and website functionality. If you access your account online, cookies may be used to verify your identity, to authenticate you as a user on our system and to personalize aspects of your experience on our website. We also use cookies to let us know how our customers and other visitors are using our website so that we can optimize their experience. We permit certain third-party advertising providers to set cookies and use related technology such as web beacons or “clear GIFs” through our website and other websites on which we advertise, and via HTML email messages, to track performance of advertisements and to collect aggregate data on web page viewing.

Most web browsers can be set to notify you when an HTML cookie is placed on your computer. You can manually delete HTML cookies and set most browsers to refuse to accept HTML cookies, although doing so may affect your website experience. Flash cookies may be removed by managing your Adobe® Flash® Player settings. To delete or prevent placement of Flash cookies, you will need to visit the Adobe® Flash® Player Help site at www.adobe.com/go/settingsmanager, click on the hyperlink for "Website Privacy Settings Panel" on the left side of the screen, and follow the instructions for preventing third party Flash content from storing data on your computer.

Interest-based advertising

We use "interest-based" ads, which are also known as "online behavioral advertising." We may partner with ad networks and other advertising providers (“Advertising Providers”) who serve ads on behalf of us and others on non-affiliated sites. Some of these third parties may use cookies and other technologies to collect information about your online activities over time and across third party websites or online services to deliver advertising based on your interests and preferences, as inferred from your browsing history. Some of these ads may be personalized, meaning that they are intended to be relevant to you based on information that Uulala and its Advertising Providers collect about your visits to this site and elsewhere over time.

To learn more about this type of advertising and how to opt-out of this form of advertising, you may either visit www.aboutads.info to opt-out of sites and services participating in the Digital Advertising Alliance (“DAA”) self-regulatory program, or visit www.networkadvertising.org/choices/ to opt-out of this form of advertising by members of the Network Advertising Initiative (“NAI”). Note that electing to opt-out will not stop advertising from appearing in your browser or applications, although it may make the ads you see less relevant to your interests. In addition, if you use a different browser or erase cookies from your browser, you may need to renew your opt-out choice.

Do Not Track

Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third party web sites or online services (for example, browser “do not track” signals). Because a “Do Not Track” protocol has not been finalized, the information collection and disclosure practices of our website, and the choices that our website provides to consumers, will continue to operate as described in this Policy, whether or not a Do Not Track signal is received. Currently, we do not monitor or take any action with respect to these signals or other similar mechanisms.

How can customers access and update or correct their personal information?

As a customer, you may access and update some of your personal information. You may log on to our website using your user name and password and, from the home page, navigate to your account information select the information you want to change.

We make reasonable efforts to maintain your personal information in an accurate, complete and up-to-date form. Please contact us if you believe that your personal information is inaccurate, incomplete, or out-of-date. Or, where entitled by applicable law, you may request access to your personal information by sending an e-mail to compliance@uulala.io. Please include your first and last name and street address in your request. You may also update your information by calling or writing us using the contact information provided below. We will process your request in compliance with local laws and our policies and procedures. Please note that before we are able to provide you with any information or correct any inaccuracies, we may ask you for additional information to verify your identity.

Under certain circumstances, we may be unable to provide access to all of your personal information. We may deny or restrict access or deny your request to change your personal information for legally permissible reasons, such as where the information contains references to other individuals and is not reasonably severable; where it cannot be disclosed for legal, security, or commercial proprietary reasons; or where we have your personal information in our capacity as a third party administrative record keeper. We will advise you of any reason for denying or restricting an access request to the extent permitted by law, rule, or regulation.

Updates to this Policy

We may update this Policy from time to time, and will review it at least annually. We encourage you to periodically check back to this Policy to learn about updates to our privacy practices.

Notice to California residents

California law requires that we obtain your affirmative consent before we share your non-public personal information with non-affiliated third parties for their own marketing purposes. However, because we do not currently share personal information about you with any non-affiliated third party in a manner that would trigger this requirement, there is no need at this time for us to seek your consent.

To limit the sharing of your personal information

If you wish to opt-out of our sharing your personal information with our affiliated companies for marketing purposes, please contact us by telephone or mail:

Uulala Inc.
207 N. Euclid Ave, Ontario CA 91762

For questions regarding our Privacy Statement, please visit the Contact Us page on our website.

© 2018 Uulala Inc. All rights reserved.

How does Uulala collect my personal information?

We collect your personal information, for example, when you

We also collect your personal information from other companies such as credit bureaus and affiliates.

Why can't I limit all sharing?

Federal law gives you the right to limit only

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

What happens when I limit sharing for an account I hold jointly with someone else?

Your choices will apply to everyone on your account – unless you tell us otherwise.



Companies related by common ownership or control. They can be financial and nonfinancial companies.


Companies not related by common ownership or control. They can be financial and nonfinancial companies.

Joint Marketing

A formal agreement between non-affiliated financial companies that together market financial products or services to you.

Other important information

California residents: We do not share your personal information unless applicable law (1) permits us to do so without first obtaining your prior consent, or (2) we first provide you an opportunity to limit this sharing.

Nevada residents: Nevada law requires us to disclose that you may elect to be placed on our internal do-not-call list by calling us at 1-855-577-4587 For further information, contact the Nevada Attorney General’s office at 555 E. Washington Ave., Suite 3900, Las Vegas, NV 89101; by phone at 702-486-3132; or by email at BCPINFO@ag.state.nv.us.