Progress Privacy Notice
Who We Are
UP Global Sourcing UK Limited’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.
It is important that you read this policy, together with any other privacy notice/ policy we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
Data protection principles
We will comply with UK GDPR. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
Information That We Collect
UP Global Sourcing UK Limited 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 policy. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
The kind of information we may hold about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Depending on the circumstances, we may collect, store, and use the following categories of personal information about you:
- Name/ Home Address - without this we won’t know where or whom to send your order to. We also use this information to identify whether we can deliver to you, at what cost and via which partner route.
- Email – to send a confirmation of your orders via email, as well as other service related communication and may also respond this way if you have a general enquiry. If you have agreed to receive marketing communications, these may also be sent by email.
- IP Address - when you visit our site, we will automatically receive your IP address; a unique identifier for your computer or other access device
- Telephone Number(s) - if there are any problems with your order or anything needs to be checked, we need to be able to contact you as quickly as possible.
- Financial Information –a payment card or a Paypal, Google Pay or Klarna account is required in order to process your order. Payment card information will be retained for the duration of the time that you hold an account with us, or for no longer than 12 months from your last order. This is necessary to enable payment, process refunds and help us monitor fraudulent activity on accounts.
- Correspondence-– if you contact us we may keep a record of that correspondence.
- Product Registration
- Images you may send us
- 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 collect information when you:
- Place an order on this, or any of our websites
- Visit our premises via our CCTV or visitor management (as part of Health and Safety)
- Communicate via email/telephone with any of our staff (for instance customer services)
- 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)
- Create an account on our website
- Fill out a website form or add your email address to our email database
- Begin to checkout to purchase an item and enter your email addresss.
- Place an order or communicate via any of our branded or partner websites (i.e. Amazon/EBay)
- Approach us with Trade enquiries.
- Engage in our live chat facility
- Leave product reviews on our website
- Engage with you for promotional campaigns
- 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, provided by Big Commerce
- Email marketing services provided by Dot Digital
- Tracking and analytics services are provided by Facebook and Google.
How We Use Your Personal Data (Legal Basis for Processing)
UP Global Sourcing UK Limited takes your privacy very seriously and will never disclose, 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 (to existing customers) based on preferences you have selected, including information on promotions and advertising we consider you may be interested
Legitimate Interests (marketing)
To complete customers’ orders successfully (to customers who have begun an order, i.e. abandoned cart emails)
Legitimate Interests (marketing)
To provide direct marketing (not existing customers)
To offer you the facility to leave product reviews on both our site and Trust Pilot
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.
Sharing and Disclosing Your Personal Information
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 answer any questions you might have and TrustPilot for your reviews.
We also allow links on our pages for you to like our product’s 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 UK Limited 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 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 Limited 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.
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
If you wish to exercise any of your rights listed above please write to
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 Policy
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.
UP Global Sourcing UK Limited is a company under the group UP Global Sourcing Holdings PLC.
Dated: October 2022