Progress Privacy Notice
Who We Are
Progress is part of UP Global Sourcing 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 Data Protection Regulation and 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 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 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 data protection 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 collect information in the below ways: -
- When 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 automatically collect some data about your visit via cookies. This data provides an optimised experience when you browse the site, including more targeted advertising, and also to indicate where the site might require improvement. (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
Data we receive from other sources
This is data that we receive about you from third parties, such as business partners, providers of technical services (e.g. analytics) or subcontractors.
Our business partners that may send us personal data about you include:
order and payment information made via the online shop is provided by Big Commerce; email marketing services are provided by Dot Digital and tracking and analytics services are provided by Facebook and Google.
How We Use Your Personal Data (Legal Basis for Processing)
UP Global Sourcing PLC takes 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) based on preferences you have selected, including information on promotions and advertising we consider you may be interested
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) and support optimisation of our site
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.
You have the right to access any personal information that UP Global Sourcing PLC 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
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to update/correct it as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You may have the right to request erasure of your personal data or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use. Please note, we do not process your data using automated decisions for marketing purposes.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the relevant request; this is to ensure that your data is protected and kept secure.
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 PLC 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 data protection 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
- 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)
- Payment Gateway services Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden. We offer Pay in 3, Pay Later & Pay Now. Payment is to be made to Klarna (your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna's privacy statement). For further information and Klarna's user terms you can find here. General information on Klarna you can find here.
- External Customer Support Services
- Webchat services
- Insurance Services
- Banking Services
- Telephony Services
- Legal Services
- Product Review Site (TrustPilot)
- 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 Google’s Privacy & Terms site / 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 TrustPilot 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.
- Facebook privacy notice
- Instagram privacy notice
- YouTube privacy notice
- Twitter privacy notice
- LinkedIn privacy notice
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 PLC takes 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 PLC, 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 PLC only 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.
Lodging A Complaint
UP Global Sourcing PLC only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection 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 PLCCompliance OfficerManor MillVictoria StreetManchesterOL9 0DDUNITED KINGDOM Email: email@example.comTelephone: 0161 934 2240
UK Data Protection Authority
Information Commissioners Office (ICO)Wycliffe HouseWater LaneWilmslowCheshireSK9 5AF Tel: 0303 123 1113Email – via their website – www.ico.org.uk
UP Global Sourcing UK Limited is a company under the group UP Global Sourcing Holdings PLC.
Dated: May 2022