Privacy Policy

Progress Privacy Notice

 

Who We Are

Progress is part of 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 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 Holdings PLC 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: -

  • Name
  • Home Address
  • Email
  • 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 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
  • 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 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

 

 

How We Use Your Personal Data (Legal Basis for Processing)

UP Global Sourcing Holdings 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.

 

Purpose

Legal Basis

To process your orders 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)

Your consent

To offer you the facility to leave product reviews on our site

Legitimate Interests (feedback on our products)

To monitor usage of our website

Legitimate Interests (security)

CCTV

Legitimate Interests (security)

Recorded Calls

Consent

To provide customer support

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.

 

Your Rights

You have the right to access any personal information that UP Global Sourcing Holdings 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 form 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 Holdings 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
  • 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)
  • External Customer Support Services
  • Webchat services
  • Insurance Services
  • Banking Services
  • Telephony Services
  • Legal Services

 

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.

 

Social Media

 

We also use various social media channels to provide support and answers any questions you might have. We never add anyone’s personal data into any social media channel or use their audience or category advertising features, however we act as joint controllers as they determine how your data is managed.

 

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:

 

Facebook privacy notice

Instagram privacy notice

YouTube privacy notice

Twitter privacy notice

LinkedIn privacy notice

Pinterest

 

 

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/

 

 

Safeguarding Measures

UP Global Sourcing Holdings 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: -

 

  • Firewall
  • Encryption
  • 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 Holdings 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 Holdings PLC only ever retains personal information 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 Holdings 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 Holdings PLC

Compliance Officer

Manor Mill

Victoria Street

Manchester

OL9 0DD

UNITED KINGDOM

 

Email: data-protection@upgs.com

Telephone: 0161 934 2240

 

UK Data Protection Authority

 

Information Commissioners Office (ICO)

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

 

Tel: 0303 123 1113

Email – via their website – www.ico.org.uk

 

Dated: September 2021

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