Privacy and Cookie Notice

1.            Who we are

We are Upp Corporation Limited, trading under the name of ‘Upp’, whose company registration number is 12442219 and whose registered office at Devonshire House, One, Mayfair Place, London, England, W1J 8AJ.

This Privacy and Cookie Notice (“Privacy and Cookie Notice”) sets out the basis on which we collect and use your personal data and describes your privacy rights.

Please read this notice carefully to understand what data we collect and how we will treat it. You agree that the collection and use of your information by us shall be in accordance with the terms of this Privacy and Cookie Notice.

2.            The type of information we collect about you

We may collect and process the following information about you:

  • Identification and Contact Data: This includes your name, username, title, date of birth and gender, your address and location data, email address, social media username (if given) and telephone number, voice identification data, identification documents (drivers licences, passports and other identification), your username and password, any correspondence and communications with you.
  • Service Usage Data: This includes details of any equipment we provide to you, orders made by you and services you have purchased, together with information regarding your use of our services, our network and our Website.
  • Technical Data: This includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Website and our network (e.g., the type of device, brand, model, operating system and browser).
  • Financial Data: This includes your bank account and payment card details and details of payments made by you.
  • Profile Data: This includes your interests, preferences, and any feedback you may provide.
  • Marketing and Communications Data: This includes your preferences in receiving marketing from us and our third parties, and any information we collect from carrying out research and surveys.

3.            How we collect information

You provide us with Identification and Contact Data when you correspond with us by via our Website, our systems, social media platforms, or when you communicate with our Customer Support online, by email, by telephone, in person at marketing events and/or at your premises, or by post and when you order Services from us.  

We automatically collect your Service Usage Data when you use our Services. When you (or someone using your Upp broadband service) use Upp network to connect to the internet, we keep a record of that. We will also collect Service Usage Data (such as the amount of time you spend online) automatically when you use our services.

We automatically collect Technical Data regarding your visits to our Website and the websites and other products and services you access through it. We collect this personal data by using cookies, server logs and other similar technologies. Please see the Cookie Notice section below for more information about how we use cookies and how to change your browser settings to refuse some or all cookies.

We collect Financial Data from youvia our Website, or when communicating with you via our Customer Support team, by email, on the telephone or by post and when you order Services from us.

We also collect Marketing Communications Data and Profile Data from you when you complete a feedback survey, when you correspond with us by via our Website, when you communicate with our Customer Support online, by email, by social media, when you take part in a competition, prize draw or other promotional activity on the telephone or by post.

4.            The purpose of collecting and processing such information and our legal basis for doing so

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Consent: Where you have given us clear consent for us to process your personal information for a specific purpose.
  • Contract: Where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
  • Legal obligation: Where our use of your personal information is necessary for us to comply with the law (not including contractual obligations).
  • Legitimate interests: Where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests).

For further details on when we collect personal information, what we collect as well as how we use it, please read the following sections:

Type of data The reason and the purpose of the processing Our legal grounds for processing
Identification and Contact Data To register you as a new customer; to provide the services including the performing of any necessary installation and maintenance work; to maintain your account with us and our relationship with you; to responding to any questions; to notify you about changes to our services; to notify you about changes to our terms or Privacy and Cookie Notice; or to asking you to leave a review. Consent; To perform our contract with you; Necessary to comply with our legal obligations.
Service Usage Data   We use this information to monitor your usage of our services, to provide you with Service usage information, to maintain records of your usage, to manage and improve our network and services to you, to provide billing information to you, to provide fraud detection and to prevent information security breaches. Consent; To perform our contract with you; Necessary to comply with our legal obligations; Necessary for our legitimate interests (to understand how customers use our service, to ensure service improvement and to protect our network and service); Necessary to comply with our legal obligations.
Technical Data   We use this information to provide, maintain and improve our services and for quality and training purposes; to monitor and record our communications with you; to administer and protect our business, network and Website (including data analysis, testing, system maintenance, support and reporting faults) and to enhance our network security. Consent; To perform our contract with you; Necessary for our legitimate interests (for training and quality purposes, for operating our business, to provide network security, to prevent fraud; Necessary to comply with our legal obligations.
Financial Data   We use this information to process your order and provide our services including, to make the services available to you, to manage payments and charges, to provide billing information to you and to collect and recover money owed to us. Consent; To perform our contract with you; Necessary for our legitimate interests (to recover money due to us).
Profile Data We use this information to ensure we are providing services to you in most effective manner and to improve our service and offering to you. Consent; To perform our contract with you; Necessary for our legitimate interests (maintain and develop our service provision and to better understand how customers use our services).
Marketing Data We use this information to better understand your preferences and in order to improve our service and offering to you and to send you product or service information. Consent; To perform our contract with you; Necessary for our legitimate interests (maintain and develop our service provision and to better understand how customers use our services).

5.            How we store and look after your information.

We have strict security measures in place to prevent your personal data from being accidentally lost, altered, disclosed, used or accessed in an unauthorised way. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to see this information. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or you have chosen) a customer ID, password(s) or log-ins to allow you to can access certain parts of our Website, you are responsible for keeping these confidential. We also use multi-factor authentication protecting access to our databases.  You are responsible for how our services are used from your account and for keeping your account information secret. Please keep this information safe, and do not share it with others.

6.            How long we keep your data for

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Unless we are required to hold your information for longer to comply with applicable law, we will delete your personal data with 18 months of the end of your Contract with us.   

7.            Who we share your data with

We share your data with third parties who process data on our behalf. These include third party service providers and suppliers who provide some of the services on our behalf under contracts with us including:

  • Third parties we may engage to install, provide, and maintain your Service.
  • Credit reference agencies (to carry out credit checks) and debt recovery agencies (if you do not pay your bills);
  • Analytics, search engine providers or research service providers which assist us in the improvement and optimisation of our Website and our services;
  • IT and system administration service providers;
  • Professional advisers including lawyers, auditors and insurers; and
  • Third parties to whom we may choose to sell, transfer or merge parts of our business with.

Our Website may include links to third party websites and social media platforms who may collect personal information about you. We don’t control those third parties or social media platforms so you need to review the privacy notices of those websites and platforms to understand how they will process your personal data.

We will share your personal data with third parties where we are required to by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

8.            International Transfers

When we process your personal information, this may involve processing and transferring it outside the United Kingdom and European Economic Area (EEA).

Whenever we transfer your personal information out of the United Kingdom or the EEA, we will ensure that we have sufficient procedures in place to ensure that the same degree of protection is given to such information as would have been in the United Kingdom.

9.            Marketing Communications

If you have opted-in by giving us your consent for us to do so, we may use your Identity and Contact Data, Service Usage Data, Technical Data, Usage Data, Profile, and Marketing and Communications Data to form a view on what services and offers may be relevant for you and to send you recommendations about services that we think may be of interest or to invite you to participate in prize draws or competitions and to keep you up to date about our services and coverage.

You can ask us to stop sending you marketing communications at any time by logging into My Account via our Website and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you or by contacting us at any time.  We will still send you service-related communications as necessary if you opt out of receiving marketing communications.

10. Your Rights as a Data Subject

You have various rights in relation to your personal data which are set out below:

  • Your right of access: You have the right to ask us for copies of your personal information. This is commonly known as a “data subject access request”.
  • Your right to rectification: You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
  • Your right to erasure: You have the right to ask us to erase your personal information when we no longer need it. we may not be able to comply with your request of erasure, for example, if we are required to retain your personal data for legal reasons. We will let you know if this is the case.
  • Your right to restriction of processing: You have the right to ask us to restrict the processing of your information in certain circumstances.
  • Your right to object to processing: You have the right to object to the processing of your personal data where we are processing your personal data for direct marketing purposes. You also have the right to object where we are relying on a legitimate interest but you feel the processing impacts on your fundamental rights and freedoms.
  • Your right to data portability: You have the right to ask that we transfer the information you gave us to another organisation, or to you.

We will respond to all legitimate requests within 30 days of receipt and will do our best to ensure a satisfactory resolution within that time period. Occasionally it may take us longer than a month if your request is a complex one or you have made a number of requests. In this case, we will notify you and keep you updated.

11.          Cookie Notice

Our Website uses cookies – these are small files of letters and numbers which we store on your browser or the device you use to access our Website. Some of the cookies we use are essential (our Website won’t work without them) and others make our Website work more efficiently and help us to recognise you when you return to our Website.

11.1        What type of cookies do we use?

These are the main ways of classifying cookies, although there are cookies that will not fit neatly into these categories or may qualify for multiple categories.

  • Duration Cookies

Session cookies – These cookies are temporary and expire once you close your browser (or once your session ends).

Persistent cookies — This category encompasses all cookies that remain on your hard drive until you erase them, or your browser does, depending on the cookie’s expiration date. All persistent cookies have an expiration date written into their code, but their duration can vary.

  • Provenance cookies

First-party cookies — As the name implies, first-party cookies are put on your device directly by the website you are visiting.

Third-party cookies — These are the cookies that are placed on your device, not by the website you are visiting, but by a third party like an advertiser or an analytic system.

  • Purpose cookies

Strictly necessary cookies — These cookies are essential for you to browse the website and use its features, such as accessing secure areas of the site. Cookies that allow web shops to hold your items in your cart while you are shopping online are an example of strictly necessary cookies. These cookies will generally be first-party session cookies. While it is not required to obtain consent for these cookies, what they do and why they are necessary should be explained to the user.

Preferences cookies — Also known as “functionality cookies,” these cookies allow a website to remember choices you have made in the past, like what language you prefer, what region you would like weather reports for, or what your username and password are so you can automatically log in.

Statistics cookies — Also known as “performance cookies,” these cookies collect information about how you use a website, like which pages you visited, and which links you clicked on. None of this information can be used to identify you. It is all aggregated and, therefore, anonymized. Their sole purpose is to improve website functions. This includes cookies from third-party analytics services as long as the cookies are for the exclusive use of the owner of the website visited.

Marketing cookies — These cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad. These cookies can share that information with other organizations or advertisers. These are persistent cookies and almost always of third-party provenance.

11.2        Which cookies do we use?

Cookie name Cookie Type Description/Purpose Lifespan
_ga Statistics cookie Analytics / Performance 1 year
_ga_[property ID] Statistics cookie Analytics / Performance 1 year

All these cookies record your data anonymously and this means none of your data is attributed to you as an individual.

11.3        How to block cookies

You can block cookies by activating the setting on your browser which allows you to refuse the setting of all or some cookies. If you want to stop cookies being stored on your computer in future, you should check your browser manufacturer’s instructions by clicking “Help” in your browser menu. However, if you block all cookies (including essential cookies) you may not be able to access all or certain parts of our Website. Unless you’ve set your browser to refuse cookies, our system will issue cookies as soon you visit our Website.

If you want to delete any cookies that are already on your computer, you should check the instructions for your file management software to locate the file or directory that stores cookies.

You can learn about and opt out of a number of commercial third-party cookies (including some used by us) at www.networkadvertising.org. Some of the opt-outs used by our commercial service providers require a cookie to be placed on your computer. This “opt-out” cookie is only used to tell the relevant cookie servers not to send you any more cookies. If you keep deleting cookies (including “opt-out” cookies) from your temporary internet files, you might need to repeat the opt-out process, the next time you visit our Website.

12.          Changes to this Privacy and Cookie Notice

This Privacy and Cookie Notice was updated on 5 March 2021. We will review this notice on a regular basis. We will let you know if there are any significant changes to this Privacy and Cookie Notice and in any event, any changes we may make will be posted on this page.

12.          Contact

If you wish to contact us in relation to this Privacy and Cookie Notice, please do so using the contact details below and we will do our best to resolve the issue as soon as possible.

Contact: The Data Protection Office

Email: [email protected]

Postal Address:  Devonshire House, One, Mayfair Place, London, England, W1J 8AJ

If we do not resolve the issue to your satisfaction, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues www.ico.org.uk.

© 2021. Upp

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LEGAL DISCLAIMER Upp Corporation Limited is a limited liability company registered in England and Wales with registration number 12442219 whose registered office address is Devonshire House, One, Mayfair Place, London, England, W1J 8AJ.

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