Progress Privacy Notice
Who We Are
Progress is part of UP Global Sourcing UK Limited, which is a company under the group UP Global Sourcing Holdings PLC(‘we’ or ‘us’ or ‘our’) and we gather and process your personal information in accordance with this privacy notice and in compliance with the relevant UK GDPR law. This notice provides you with the necessary information regarding your rights and obligations, and explains how, why and when we collect and process your personal data.
UP Global Sourcing Holdings PLC’s registered office is at Manor Mill, Victoria Street, Manchester OL9 0DD, and we are a company registered in England and Wales under company number 05432142.We are registered on the Information Commissioner's Office Register of Data Controllers under registration number ZA269152, and act as the data controller. Our designated contact for data protection is our Compliance Officer, and contact details are available at the foot of this notice.
Information That We Collect
UP Global Sourcing Holdings PLC processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than already specified in this notice.
The personal data that we collect from is:
- Home Address
- IP Address
- Telephone Number(s)
- Product Registrations
- Images you may send us
- Financial Information (for returns)
- Legal and Insurance data
- Social Media profile information
- Country you access our website from
- How you use our website including which products you view
- Any personal data you include in any product reviews you leave for us
Special Category Data (i.e. health/medical information, details about religion, sexuality, gender etc)
Some of the products we sell, are designed to support you with specific health conditions, as such UK GDPR law stipulates that this infers health data. Whilst we do not process this data according to this category, we do identify it within our systems purely for the purposes of increased security. In addition, you may provide us with health-related data relating to returns and this data is kept separate, with higher levels of control, retention and security.
In addition, some of our products are designed to be used with mobile apps. Please check the privacy notice of those apps for how we use your data.
Where we process high risk data such as financial information, we have strict security controls on access, storage and retention.
We do not collect any data from public sources.
We collect information in the below ways: -
When you place an order on this or any of our websites
- You place an order on this, or any of our websites.
- If you visit our premises via our CCTV or visitor management (as part of Health and Safety).
- When you communicate via email/telephone with any of our staff (for instance customer services).
- When we record certain calls to our customer services department.
- When you visit our website, we collect some data via cookies (see our cookie notice).
- When you create an account on our website.
- When you fill out a website form or add your email address to our email database.
- When you place an order or communicate via any of our branded or partner websites (i.e. Amazon/EBay).
- When you approach us with Trade enquiries.
- When you engage in our live chat facility.
- When you leave product reviews on our website.
- When we engage with you for promotional campaigns.
- When you interact with us on our Social Media channels.
- When you enter into an Influencer agreement with u.
How We Use Your Personal Data (Legal Basis for Processing)
UP Global Sourcing UK Limitedtakes your privacy very seriously and will never disclosure, share or sell your data without your consent, unless required to do so by law or detailed herein as part a requirement to provide the services you have requested. We only retain your data for as long as is necessary and for the purposes specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw consent at any time.
To process your order other transactional contact (i.e. shipping confirmation) and provide customer service/support
Performance of a contract
To provide direct marketing (existing customers)
Legitimate Interests (marketing)
To provide direct marketing (not existing customers)
To offer you the facility to leave product reviews on both our site and TrustPilot
Legitimate Interests (research - feedback on our products)
To monitor usage of our website
Legitimate Interests (security)
Legitimate Interests (security)
To provide customer support
Performance of a contract
To contact you if you have left items in your cart without finalizing a sale
Performance of a contract
NB. where we process on the basis of Legitimate Interests, we conduct a Legitimate Interests test for necessity and balance against your rights and freedoms.
Sharing and Disclosing Your Personal Information
We do not share or disclosure any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. UP Global Sourcing UK LimitedPLC uses third parties to provide the services and business functions below, however all processors acting on our behalf only process your data in accordance with contractually agreed instructions from us and comply fully with this privacy notice, the UK GDPR laws and any other appropriate confidentiality and security measures.
We use partners to provide the following services:
- Undertake legally required accountancy services
- E-commerce activities
- Courier services provided by Evri (www.evri.com/privacy-policy) and Yodel (www.yodel.co.uk/privacy-cookies-policy / www.collectplus.yodel.co.uk/privacy-policy
- Email campaigns
- Product Review services
- Product Fulfillment services
- Customer Service Management services
- Payment Gateway services (we do not have access to any of this data and Paypal are the controller of your data in this instance – their Privacy Information can be found here within their privacy hub)
- Payment Gateway services (we do not have access to any of this data and Stripe are the controller of your data in this instance – their Privacy Information can be found here within their privacy hub)
- External Customer Support Services
- Webchat services
- Insurance Services
- Banking Services
- Telephony Services
- Legal Services
- Product Review Site (TrustPilot)
- External Influencer outreach through a PR agent
We use Google for analytics purposes. We only access aggregated data (so we don’t identify individual’s data), however Google acts a joint controller for this data and you should consult their privacy information for information on how they process your data.
Where any of our partners transfer your data outside of the EEA / UK we have undertaken due diligence to ensure that your rights are protected and that your data is kept secure.
We also use various social media channels to provide support and answers any questions you might have and Trust Pilot for your reviews.
We also allow links on our pages for you to like our products Facebook, Pinterest and Twitter. This means that these social media companies know you have been to our website and which products you have looked at.
We also sometimes run competitions on these social media channels, however we never take your personal data from these companies, except to send you prizes. You should be aware of the privacy notices of these social media channels to see how they manage your data.
Where you add your personal data to social media or where we share your data with TrustPilot, please be aware that these companies will then become the controller of your data, and they will use your data according to the information they provide within their own Privacy Notices.
For some email marketing services we rely on your consent, and as such please see details of the third party used and a link to their Privacy Notice:
DotDigital - https://dotdigital.com/terms/privacy-policy/
UP Global Sourcing UK Limitedtakes your privacy seriously and we take every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including:
- Strict Access Controls (physical and electronic)
- SSL certificates
- Full Privacy Governance structure
Consequences of Not Providing Your Data
You are not obligated to provide your personal information to UP Global Sourcing UK Limited, however, as this information may be required for us to provide you with our services/deliver your products/legitimate interests, we will not be able to offer some of our products or services without it.
How Long We Keep Your Data
UP Global Sourcing UK Limitedonly ever retain personal data for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.
Where you have consented to us using your details for direct marketing, we regularly review consent given and will keep such data until you notify us otherwise and/or withdraw your consent.
Rights of access, correction, erasure, and restriction
You have the right to access any personal information that UP Global Sourcing UK Limited processes about you and to request information about:
- What personal data we hold about you
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data for
- If we did not collect the data directly from you, information about the source
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please write to us at the address below.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please write to us at the address below. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Lodging a Complaint
UP Global Sourcing UK Limitedonly processes your personal information in compliance with this privacy notice and in accordance with the relevant UK GDPR laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority. We would be grateful if you would give us the opportunity to deal with any complaints in the first instance.
UP Global Sourcing UK Limited
Telephone: 0161 934 2240
UK Data Protection Authority
Information Commissioners Office (ICO)
Tel: 0303 123 1113
Email – via their website – www.ico.org.uk
Notification of Changes to this Notice
If we decide to change our Privacy Notice, we will post these changes on this website so that you know exactly what information we collect and how we use it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected we will tell you and you will have a choice as to whether or not we use your information in this different manner.
We want to make sure that we’re giving you the information that you want about privacy and security – let us know what you think. If you have any feedback, questions or concerns, please email us at email@example.com or by post to the address above.
Our website may contain links to let you visit other websites of interest with ease. Once you have used these links to leave our website, you should be aware that we do not have any control over that other website. As such, we cannot be responsible for the protection and privacy of any information that you provide whilst visiting these websites, and they are not governed by this Privacy Notice. We are not responsible for any products and/or services featured on any third-party websites; you should exercise caution and look at the Privacy Notice applicable to the website in question.
UP Global Sourcing UK Limited is a company under the group UP Global Sourcing Holdings PLC.
Dated: October 2022