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Privacy Policy

Welcome to UpGradAd! Our website, UpGradAd, is operated by UpGradAd
Limited. Our registered office is located at 3rd Floor Office 207 Regent Street, London
W1B 3HH. We trade as UpGradAd.

At UpGradAd, safeguarding your privacy and protecting your Personal Data are of utmost importance to us. This Privacy Policy will outline how we handle your Personal Data when you visit our website, detail your privacy rights, and explain the legal protections in place.

WHAT DOES OUR PRIVACY POLICY COVER?

 
Introduction

Data Controller

Types of Personal Data We Collect

How We Collect Your Personal Data

Links to Third-Party Sites

Our Use of Your Personal Data

Purposes for Processing Your Personal Data

Changes in Data Processing

Sharing Your Personal Data

Marketing and Promotional Communications

Our Use of Cookies

Ensuring Data Security

Data Retention

Your Legal Rights

Accessing Your Personal Data

Glossary

INTRODUCTION

We strongly recommend reading this Privacy Policy alongside any additional privacy policies or fair processing policies UpGradAd may provide on specific occasions when collecting or processing Personal Data about you. This will ensure you have a comprehensive understanding of the reasons and methods behind our data usage.

This Privacy Policy complements other notices and policies and does not supersede them. We routinely review our Privacy Policy, and the most recent version was last updated on August 14th, 2023.

DATA CONTROLLER

UpGradAd is the entity responsible for your Personal Data. We have appointed a Data Protection Officer (“DPO”) to oversee any questions related to this Privacy Policy or our privacy practices. If you have inquiries about this policy or wish to exercise your legal rights, please reach out to our DPO using the contact details below:

Contact Number: 0161 546 6818
Email Address: hello@upgradad.com

To maintain accurate and current Personal Data, please notify UpGradAd of any changes during your engagement with us.

TYPES OF PERSONAL DATA WE COLLECT

In certain cases, UpGradAd may process your Personal Data without requiring your explicit consent, as permitted or required by law. The categories of Personal Data we collect and process are as follows:

Identity Data: Includes details like your first name, last name, username, marital status, title, date of birth, and gender.

Contact Data: Covers information such as billing address, delivery address, email address, and phone numbers.

Financial Data: Comprises bank account and payment card details.

Transaction Data: Encompasses specifics about payments made by you, payments to you, and products/services purchased.

Technical Data: Encompasses internet protocol (IP) address, browser type, time zone setting, device information, and similar technical details.

Profile Data: Involves your username, password, purchase history, preferences, feedback, and survey responses.

Usage Data: Encompasses information on how you use our website, products, and services.

Marketing and Communications Data: Includes your preferences regarding marketing communications from UpGradAd and third parties, as well as your communication preferences.

Aggregated Data: We collect, use, and share data such as statistical or demographic information for various purposes. While Aggregated Data may be derived from Personal Data, it does not identify you directly. However, if combined with Personal Data to identify you, this combined data will be treated according to this Privacy Policy.

We do not collect Special Categories of Personal Data (sensitive data) about you, which includes details about race, religion, health, etc. We also do not collect information on criminal convictions and offences. UpGradAd is not intended for children, and we do not knowingly collect data related to children.

HOW WE COLLECT YOUR PERSONAL DATA

UpGradAd employs various methods to collect data from and about you:

Direct Interactions: You provide Identity, Contact, and Financial Data when you fill out forms or correspond with us through mail, email, or other means. This includes situations when you apply for our services, create an account, subscribe to our services, participate in surveys, or give feedback.

Automated Technologies: Our website collects Technical Data through cookies, server logs, and similar technologies as you interact with it. Technical Data may also be collected from other websites using our cookies.

Third Parties: We receive Personal Data from third parties and public sources as outlined below:

Analytics providers (e.g., Google) located outside the EU.

Advertising networks located within the EU.

Search information providers based within the EU.

Providers of technical, payment, and delivery services that offer Contact Data, Financial Data, and Transaction Data.

Data brokers or aggregators within the EU providing Identity Data and Contact Data.

Publicly available sources within the EU, such as Companies House and the Electoral Register, offering Identity Data and Contact Data.

Advertising networks located outside the EU.

Third-Party Links: Our website may contain links to third-party websites, plug-ins, and applications. Clicking on these links may allow third parties to collect or share data about you. We are not responsible for these third-party websites’ privacy statements, so we advise you to read their policies upon leaving our website.

UpGradAd employs various methods to collect data from and about you:

Direct Interactions: You provide Identity, Contact, and Financial Data when you fill out forms or correspond with us through mail, email, or other means. This includes situations when you apply for our services, create an account, subscribe to our services, participate in surveys, or give feedback.

Automated Technologies: Our website collects Technical Data through cookies, server logs, and similar technologies as you interact with it. Technical Data may also be collected from other websites using our cookies.

Third Parties: We receive Personal Data from third parties and public sources as outlined below:

Analytics providers (e.g., Google) located outside the EU.

Advertising networks located within the EU.

Search information providers based within the EU.

Providers of technical, payment, and delivery services that offer Contact Data, Financial Data, and Transaction Data.

Data brokers or aggregators within the EU providing Identity Data and Contact Data.

Publicly available sources within the EU, such as Companies House and the Electoral Register, offering Identity Data and Contact Data.

Advertising networks located outside the EU.

Third-Party Links: Our website may contain links to third-party websites, plug-ins, and applications. Clicking on these links may allow third parties to collect or share data about you. We are not responsible for these third-party websites’ privacy statements, so we advise you to read their policies upon leaving our website.

OUR USE OF YOUR PERSONAL DATA

UpGradAd will use your Personal Data only when permitted by law. The most common circumstances in which we process your Personal Data are:

Performance of Contract: We process your data when it’s necessary to fulfil or enter into a contract with you.

Legitimate Interests: We process your data based on our legitimate business interests, provided your rights and interests do not override those interests.

Compliance with Legal Obligations: We process your data to comply with a legal obligation. Without your Personal Data, we might not be able to perform a contract or provide a service. While consent is not our primary legal basis for processing Personal Data, we do seek your consent before sending third-party marketing communications via email or text message. You can withdraw this consent at any time by contacting us.

PURPOSES FOR PROCESSING YOUR PERSONAL DATA

We’ve summarised the ways in which we plan to use your Personal Data and the legal bases we rely on for each purpose. Note that in some instances, we may use your Personal Data for multiple legal grounds. Please feel free to contact us for more information on the legal basis for a specific processing activity.

Purpose/Activity

Types of Data

Legal Basis for Processing

Registering you as a new customer.

(a) Identity Data
(b) Contact Data

Performance of a contract with you.

Processing and delivering your orders, including payment management.

(a) Identity Data
(b) Contact Data
(c) Financial Data
(d) Transaction Data
(e) Marketing and Communications Data

Performance of a contract with you. Necessary for our legitimate interests (debt recovery).

Managing our relationship with you, including updates and surveys.