Privacy Policy

February 8, 2019

UMA has created this Privacy Policy to explain how it collects, uses, discloses and safeguards Personal Information in connection with the use of the Website and Application. You can contact us for any questions, comments or requests about this Privacy Policy:


We may collect a variety of information from you in many ways. More specifically:

We collect information directly from you. For example, when you provide us with your contact information.
We collect information passively from you. For example, we may collect information through browser cookies or from devices used to connect to the Services.
We collect information from third parties. For example, we collect information from UMA Partners and through social media platforms. We may combine the information that we collect from third parties with the information we collect from you.    



    Personal Information collected may include:

    Contact information such as your name, email address and/or phone number.
    Other information you choose to provide us with when using the Services, such as User Materials. 



        We use the Personal Information we collect to:

        • Operate the Services

        • Analyze the use of and improve the Services

        • Comply with applicable laws and UMA’s policies

        • Provide the Services including the Memory Creations


        UMA may share the Personal Information it collects:

        • In connection with the operation of the Services

        • In case of a business transaction

        • For law enforcement



        The Services ARE intended for use BY YOU Only.

        This Privacy Policy shall be reviewed carefully as it governs the use of the Services.

        UMA may change this Privacy Policy from time to time. Should you object to any changes made, you shall stop using the Services. By continuing to use the Services after the amendment of this Privacy Policy, you will be deemed to adhere to its terms, as amended. If you have downloaded the Application and do not agree to all the provisions of the Privacy Policy, you must delete the Application from the handheld or tablet device onto which you downloaded the Application.

        You can contact us if you have any questions about this Privacy Policy:



        UMA is committed to protecting the privacy of Personal Information. In order to bring to your attention the privacy practices implemented, UMA has prepared this Privacy Policy, which summarizes: (i) the types of Personal Information collected, (ii) why it collects Personal Information, (iii) how it uses and protects Personal Information, and (iv) under what circumstances Personal Information is shared with its UMA Partners and other third parties when required or permitted under applicable law. This Privacy Policy further describes the decisions that can be made with respect to the collection, access, use and storage of Personal Information.



        2.1. In this Privacy Policy, the terms set forth below have the following meanings:

        Application means the UMAcode application, a free application for iOS and Android, developed and owned by UMA (including any updates and upgrades) allowing you or any Users to connect and access the Rivers of Life stored on the Website, via your handheld or tablet device’s camera scanning a UMAcode.
        Cookies means the small text files that are placed on the hard disk of devices when someone accesses the Services, which may either be temporary and disappear when such devices are turned off or be permanent and stay even after such devices are turned off.
        Memory Creations means the content automatically created by UMA’s proprietary creation engine from a River of Life.
        Personal Information means any information about an identifiable individual, including but not limited to contact information, address, e-mail address, photos or videos.
        Resources means the variety of resources provided through the Services, including but not limited to, download areas, audio files and video templates.
        River of Life means a summary of your/Users life(s) divided into chapters and generated by means of the Resources and by uploading User Materials on the Website.
        Services refers to the Website, the Application and all other products and services provided to you by UMA via the Website and the Application.
        UMA means UMA GLR Inc.
        UMAcode means a code linking Rivers of Life to objects (including, but not limited to, UMA Artefacts).
        UMA Partners means the business partners assisting UMA in the development or operation of the Services, such as, but not limited to: (i) Facebook, LinkedIn, Instagram and other social media offering marketing or promotional tools and platforms, (ii) Amazon Web Services providing servers location and cloud computing platforms for the storage of various information (including Personal Information).
        User means any person using the Services, including, without limitation, by accessing and browsing on the Website, downloading and using the Application and uploading User Content on the Website.
        User Materials means the content uploaded or otherwise provided by you/Users through your use of the Services and include, without limitation, photographs, voice recordings, videos, audio, comments, written works, names, artwork and other graphical or textual materials.
        Website means website available at org or any other URL, as may be applicable from time to time.
        Unless the context requires otherwise: (i) grammatical variations of any term defined herein have a similar meaning; and (ii) words importing the singular number shall include the plural and words importing the masculine gender shall include the feminine and neutral genders and vice versa.


          In the course of operating the Services, UMA will collect and/or process information about you, as described below. UMA also collects information about any User when such User accesses the Services or otherwise contacts UMA to enquire or make comments about the Services. In all cases, such Personal Information is only collected and used for the purposes detailed in this Privacy Policy and for no other purposes.

          3.1.1. Creation of online accounts

          A Uses account will need to be created in order for you to access all the functionalities of the Services.

          In order to create such a User account, you will be required to disclose to UMA the following Personal Information: your name and surname and login name.

          The foregoing information is required to create your unique user account and to authenticate you each time you sign in.

          Should you have difficulty logging in or need to reset your password, you may contact UMA as provided for below. Some information will be required to be disclosed (e.g. full name and login name) to ascertain your identity and provide you with a new password.

            3.1.2. Comments, requests for information and referrals

              Should you or any Users contact UMA to obtain information about the Services or about any other matter, then you or any Users will be required to provide your/their contact information (including names and e-mail addresses). This information is required by UMA in order to communicate with you and respond to your enquiries, comments or requests for information. You or Users may also provide additional Personal Information, including when making comments, enquiries or suggestions.

              Any comments, feedback, notes, messages, ideas, suggestions or other communications (collectively, “Comments”) sent to UMA shall be and remain the exclusive property of UMA. Your submission of any such Comments shall constitute an assignment to UMA of all worldwide right, title and interest in all copyrights and other intellectual property rights in and to the Comments. UMA will be entitled to use, reproduce, disclose, publish and distribute any material you submit for any purpose whatsoever, without restriction and without compensating you in any way. For this reason, we ask that you not send us any Comments that you do not wish to assign to us, including any confidential information or any original creative materials such as stories, product ideas, computer codes or original artwork.

              3.1.3. Marketing

                UMA may wish to provide information about the Services. In this regard, UMA may use the e-mail address or other contact information any person may provide from time to time to provide information about new features or services or to send news and information regarding the Services. Such communications will be sent in accordance with applicable laws. Such person may withdraw his/her consent at any time as set forth below. Note that UMA does not sell or share Personal Information to third parties for third party marketing purposes.

                3.1.4. Social media

                  UMA shares information about itself and its Services on Facebook. Similarly, if any person sends or accepts UMA’s “friend request” or otherwise “follows” UMA, then such person will share and UMA may consult the information that he/she and their “Facebook friends” posted on their Facebook pages. Since Users can always choose the audience that can see what they share via their Facebook privacy settings or the Facebook audience selector, any person is deemed to have agreed to share such information with their “friends” or persons they “follow”, including UMA as described in Facebook privacy policy and terms of use.

                  Other social media platforms such as Twitter, LinkedIn and Instagram will also allow any person to follow UMA and to add UMA to their contact list. In such a case, UMA will have access to such person’s web pages and profiles in accordance with the chosen settings, as more fully described in the privacy policies and terms of use of these social media operators. UMA will also get notification and access to any tweet, link or post in which UMA is tagged.

                    Any person shall review the privacy settings applicable to these accounts/pages to see the information to which his/her contacts have access and limit such access if required. Should UMA collect information available on social media accounts or pages, it shall do so on an aggregate and de-identified basis and for lawful purposes only.

                    3.1.5. Testimonials and promotional materials

                    Should you or any other person wish (or agree) to render any testimonial, opinion, photo or any other material available online regarding your/their appreciation of the Services, then UMA may post such promotional materials on its Website or any other social media, and may include your/their name or nickname and any other information You/they agreed to disclose. You/that person can thereafter request, at all times that such materials or other Personal Information be removed from the Website and any other social media. UMA does not however control the communications – if any – that you/such person may receive in connection with any promotional materials. Should you or any person wish to report any communication received regarding such promotional materials or other information, then you/such person should contact UMA as described below.

                    3.1.6. Information obtained from UMA Partners

                    UMA Partners may collect information about you or any other person as follows:

                    • Google Analytics: Google analytics will collect data about your or any Users’ interactions with the Services. In order to do so, Google Analytics will place codes on the Website, which will allow Google Analytics to see which information was consulted, the browser used, device and operating device used. Such information will then be processed and will be updated each time you or any Users interact with the Services. 
                    • The information so collected may be shared (in whole or in part) with UMA in order for UMA to update, upgrade or otherwise improve the Services, or to develop new services.


                    3.1.7. Information collected using Cookies

                    When you or any Users use the Services, certain information, including Personal Information (such as general browser information, Internet Protocol addresses, the interactions with the Website and any other information described below) may be collected by the following Cookies:

                    • Process Cookies: allow the Website to work properly in keeping track of requests, ensuring the integrity of web pages and allowing you and Users to browse from one page to the other.
                    • Security Cookies: are used each time an account is opened. These Cookies contain an encrypted, unique identifier that is tied to each account and placed in the browser, allowing UMA to identify you when you are logged into your account.
                    • Statistical Cookies: collect data, such as the date and time when the Website was last used and the frequency of such uses, the pages or content consulted and the manner the Website was used, the information provided and the features of their operating systems and connection information (e.g. Internet Protocol address). This information is collected for analytical and statistical purposes, such as to determine how often the Website or certain specific pages are visited, and what kinds of features and content seem to be most interesting. This information helps UMA to improve its Website, according to the needs and interests identified.

                    You or any Users, as applicable, can block Cookies unless they are required to allow the Services it offers to run properly. For instance, while statistical Cookies can be blocked, the situation is different for process and security Cookies, as they are essential for ensuring that the Website function properly. However, even if they cannot be blocked without affecting one’s ability to use the Website, these Cookies are of a temporary nature and accordingly, they will disappear when the browser software is closed or the device is turned off. Anyone experiencing problems with the functionalities of the Services should contact UMA:



                      UMA does not sell or rent Personal Information.

                      Furthermore, Personal Information is not shared, traded, used or disclosed to third parties for purposes other than those for which it was collected as described herein, unless required or authorized by law or unless proper consent was obtained, as applicable.

                      4.1. Personal Information

                      4.1.1. Sharing made in connection with the operation of the Services
                      Personal Information may be disclosed to UMA Partners that facilitates the operation of the Services, such as by providing assistance to UMA with respect to the maintenance and development of its Services. Disclosure will be made on a “need-to-know” basis, and after ensuring that proper contractual and other measures are in place.
                      4.1.2. Business transaction

                      Personal Information may be transferred to a potential purchaser or other business in connection with any business transaction or corporate reorganization, if such communication is necessary for the purposes of deciding whether to proceed with the sale or other transaction, and provided that such disclosure is made in full compliance with applicable laws.

                      4.1.3. Law enforcement
                      Personal Information may be used and disclosed if UMA, acting reasonably, believes that such use or disclosure is necessary to comply with any applicable laws, legal process or governmental request, or is otherwise required to protect its rights or to fulfil any other purpose set forth in the applicable law allowing or requiring the disclosure of Personal Information.


                      4.2. De-Identified Information used on an aggregated basis

                        UMA may use de-identified information on an aggregated basis in order to improve the Services. For instance, the Application may record encoded data of scanned UMAcodes. De-identified information may also be used for training, promotion, research and statistical purposes and any other purposes, as such information does not constitute Personal Information. In any event, note that such information could not and will not be used to re-identify You or any other individual.


                        5. PERMISSIONS

                          The following is a complete listing and description of what functions on your device that were developed by third parties are accessed and / or modified by the Application. Unless otherwise specified, these permissions apply both to iOS Devices and Android Devices.

                          5.1. Camera
                          Allows the Application to access your handheld or tablet device’s camera to scan the UMAcodes.



                            For the Application, you can access and change certain user settings from the settings menu on your handheld or tablet device. You may also uninstall; uninstall methods may vary depending on your handheld or tablet device or the iOS or Android version of the Application. UMA has no control over these functions and denies any responsibility of your use thereof, or any data or Personal Information sent to third parties as a result of said activities.



                            7.1. Requests from You
                            In accordance with applicable laws, you may make requests for access or for corrections of Personal Information by contacting UMA.


                            8. SECURITY MESURES IMPLEMENTED

                            8.1. UMA uses measures as may be reasonably required to preserve the security and privacy of Personal Information. In this regard, UMA has notably put in place or currently implements the following measures:
                            8.1.1. SSL technology: Each time the Website is accessed via Internet, Secure Sockets Layer (SSL) technology protects Personal Information by using server authentication and data encryption. No Personal Information will be communicated prior to this technology being activated, which can be confirmed by looking (i) at the address bar which will, depending on the browser, have a lock to the left of the Website address (URL), and (ii) at the URL or the address bar of the browser, where the first characters of the address in that line should change from “http” to “https”.
                            8.1.2. Limited access: Access to any Personal Information is granted to UMA’s employees, representatives and as applicable sub-contractors on a “need-to-know” basis only.
                            8.1.3. Secured center: UMA’s platform and servers are located in data centers located in Canada and UMA’s Website are currently being hosted in the Google Cloud/Microsoft Azure/etc. Additional information regarding these clouds can be obtained by reviewing Google cloud “Privacy and Security” page available here and Microsoft “Trust center” available here as of the effective date of this Privacy Policy (as may be amended from time to time or rendered available via other hyperlinks).

                              8.2. Despite the foregoing, you and any other person shall be aware of the following:

                              8.2.1. GENERAL CONSIDERATIONS: EVEN IF UMA USES TECHNOLOGIES, WHICH ARE OF MERCHANTABLE QUALITY SUITABLE FOR THE OPERATION OF THE SERVICES, ANY ELECTRONIC PLATFORMS AND SERVERS – AS with ANY OTHER FORM OF file – IS NOT INFALLIBLE AND FULLY SHELTERED FROM UNFORESEEABLE OR FORCE MAJEURE EVENTS, CYBERATTACKS OR UNAUTHORIZED USES AND ACCESS, AND YOU AND any OTHER PERSON shall BE AWARE THAT THERE IS A RISK IN TRANSMITTING ANY DATA ELECTRONICALLY. THIS RISK IS INHERENT IN ALL ELECTRONIC DEALINGS, AS WELL AS TO ALL OTHER FORMS OF COMMUNICATIONS. CONSEQUENTLY, UMA CANNOT GUARANTEE THAT INFORMATION WILL NEVER BE INTERCEPTED OR VIEWED OR SUBJECT TO OTHER INCIDENTS. such events may occur, pursuant to which devices or systems can be accessed or controlled by unauthorized persons, and undesirable COMMUNICATIONS AND invitations may be received. Should You or any PERSON receive a communication that looks like it is from UMA asking for Personal Information, You or such person shall avoid responding to such communications. UMA will never request financial and other sensitive information that way. If You or any PERSON have communicated Personal Information in response to a suspicious e-mail, pop-up or phony website claiming to be affiliated with UMA or if any of the foregoing events takes place, please contact UMA immediately.


                                9. STORAGE OF PERSONAL INFORMATION

                                  Subject to applicable laws, UMA shall retain and store Personal Information for use and disclosure consistent with this Privacy Policy, as long as necessary for the purposes detailed herein. To that end, UMA may retain Personal Information after a specific purpose has been fulfilled if reasonably necessary: (i) to comply with applicable laws or prevent any contravention; (ii) to resolve disputes; and (iii) to enforce this Privacy Policy. Once no longer required, the information will either be erased or stored on an aggregated and de-identified basis.


                                  10. THIRD-PARTY WEBSITES AND APPLICATIONS

                                    Should any link to third-party websites, applications or services (collectively, the “Third Party Site(s)”) be provided via the Services, then you and any other person shall be aware that these Third Party Sites operate independently, and are subject to distinct terms of use and privacy policies. For instance, if you use sharing features to send a message or to post on a social network, the information you send will be visible to others. It is strongly recommended that you and any other person as applicable, review the distinct terms of use and policies of such Third Party Sites, as UMA is not responsible for the content or practices of any such Third Party Sites.


                                    11. CONTACTING UMA

                                    • 11.1. Questions, Comments and requests
                                      All questions and Comments regarding this Privacy Policy or requests made in furtherance of said policy should be directed to UMA:
                                      Requests and demands made will be dealt with as soon as possible.
                                      • 11.2. Withdrawal of consent

                                      UMA may communicate with you or with any User for promotional and marketing purposes. UMA will generally use the same means of communication You or such User chose to contact UMA or the preferred means specified by you or that User. Should you or said User wish to be removed from one or more of UMA’s promotional mailing lists, then you or that User should click on the ready-to-use “unsubscribe” mechanism provided at the bottom of each e-mail or simply reply to that e-mail with the word “STOP” or “Unsubscribe.


                                      12. CHANGES TO THIS PRIVACY POLICY

                                        UMA reserves the right to change or modify this Privacy Policy from time to time. Any material change will be notified prior to the change taking effect via a web banner or by any other means, such as a notification upon opening the Application. Thereafter, the Privacy Policy as updated will be made available and easily accessible. Furthermore, an updated version of this Privacy Policy will be published each time a minor change is made. Anyone may determine whether this Privacy Policy has changed by looking at the effective date appearing at the top of said Privacy Policy. UMA recommends that this Privacy Policy be reviewed periodically in order to assess UMA’s current practices, as the continued use of the Services shall constitute acceptance of any amendment thereto. Should you, disagree with the amendments made to this Privacy Policy or other applicable terms and conditions, you shall immediately stop accessing or using the Website. If you have downloaded the Application and do not agree to all the provisions of the Privacy Policy, you must delete the Application from the handheld or tablet device onto which you downloaded the Application.