1. We are committed to safeguarding the privacy of our website visitors; in this policy we explain how we will treat your personal information.
2. By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
3. Collecting personal information
3.1 We may collect, store and use the following kinds of personal information:
3.2 Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.
4. Using personal information
4.1 Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.
4.2 We may use your personal information to:
4.3 If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.
4.4 Your privacy settings can be used to limit the publication of your information on our website, and can be adjusted using privacy controls on the website.
4.5 We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.
4.6 Under European privacy laws there is a concept of “legitimate interests” as a justification for processing your personal information. Our legitimate interests for processing your personal information are:
We want to be able to help you so we use personal data to provide clarification or assistance in response to your communications.
Your privacy is of huge importance to us. All emails or other forms of communication directly from us to you will include clear instructions on how to unsubscribe.
5. Disclosing personal information
5.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors in so far as it is reasonably necessary for the purposes set out in this policy.
5.3 We may disclose your personal information:
(a) to the extent that we are required to do so by law;
(b) in connection with any ongoing or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
5.4 Except as provided in this policy, we will not provide your personal information to third parties.
6. International data transfers
6.1 Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
6.3 Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
6.4 You expressly agree to the transfers of personal information described in this Section 5.
7. Retaining personal information
7.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
7.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.4 Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
8. Security of personal information
8.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
8.2 We will store all the personal information you provide on our secure (password- and cloud-based) servers.
8.3 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
9. Amendments
9.1 We may update this policy from time to time by publishing a new version on our website.
9.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
9.3 We may notify you of changes to this policy [by email or through the private messaging system on our website].
10. Your rights
10.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the payment of a fee (currently fixed at GBP 10); and
(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
10.2 We may withhold personal information that you request to the extent permitted by law.
10.3 You may instruct us at any time not to process your personal information for marketing purposes.
10.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes
11. Third party websites
11.1 Our website includes hyperlinks to, and details of, third party websites.
11.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
12. Updating information
12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
13. Cookies
13.1 Our website uses cookies.
13.2 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
13.3 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
13.4 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
13.5 We use session and persistent cookies on our website to:
A full list of our cookies and the explanation of their purpose can be found in our cookies policy.
13.7 Most browsers allow you to refuse to accept cookies. Links to information on how to do this can be found in our cookies policy.
13.8 Blocking all cookies will have a negative impact upon the usability of many websites.
13.9 If you block cookies, you will not be able to use all the features on our website.
13.10 You can delete cookies already stored on your computer. Links to information on how to do this can be found in our cookies policy.
13.11 Deleting cookies will have a negative impact on the usability of many websites.
14. Our details
14.1 This website is owned and operated by UP3 Services Limited.
14.2 UP3 Services Ltd is registered in England and Wales under registration number 09967591 and our registered office is The Ministry, 79 – 81 Borough Road, London, SE1 1DN.
14.3 Our principal place of business is at our registered office at the address above in 14.2
14.4 You can contact us by writing to the business address given above, by using our website contact form, by email to hello@up3.co.uk or by telephone on +44 (0)20 3432 1432.
15. How to Complain
15.1 If you have any concerns about our use of your personal information, you can make a complaint to us at: The Data Protection Officer, UP3 Services Ltd, The Ministry, 79-81 Borough Road, London, SE1 1DN.
15.2 You can also complain to the ICO if you are unhappy with how we used your data. The ICO’s address is Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. ICO Helpline: 0303 123 1113. ICO website: https://www.ico.org.uk.