Petra Privacy Policy

UP Global Sourcing UK Ltd & UP Global Sourcing Holdings PLC – Privacy Policy

What is the purpose of this document?

UP Global Sourcing UK Limited is part of UP Global Sourcing Holdings PLC (‘we’ or ‘us’ or ‘our’). We are committed to protecting the privacy and security of your personal information and are a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required, under UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018 (DPA), to notify you of the information contained in this privacy notice.

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.

This Privacy Policy describes how we collect and use personal information about you in accordance with UK GDPR laws. It applies to all customers, potential customers, users of this website, job applicants and employees in respect of whom we hold personal data. This policy does not form part of any contract to provide services or any other contract. We may update this policy at any time.

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).

How may your personal information be collected?

We may collect personal information about you in a number of different ways, such as when you:

• visit our websites;
• register with and buy products or services from our websites;
• take part in promotions and competitions;
• contact us via our customer services team in regards to returning products, faulty items and claims;
• register for a product warranty or guarantee;
• apply to join our team via our recruitment methods; and
• visit our premises.

We may also collect personal data which is publicly available on websites. We may use third-party applications which source their data from publicly available websites.

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, address and postcode– 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 address– we can 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.
• Telephone numbers– 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.
• Payment card number, expiry date, issue number and name of card holder– 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.
• IP addresses– when you visit our site, we will automatically receive your IP address; a unique identifier for your computer or other access device.
• Username and password– if we collect these details, it is so that we can keep your information safe and have it to hand each time you visit us.
• Joining our team – you may need to supply us with details including your name, address, date of birth, employment status, educational background and other sensitive personal data (related to your health, race, religion or ethnic origin) through your application and via the recruitment process.
• Sensitive personal data – by supplying us with any sensitive personal data, you expressly consent to us using it and sharing it with third parties so that we can provide you with the goods or services that you requested in the way set out in this Privacy Policy.
• CCTV footage and details of visitors at our premises – We operate CCTV at our premises and we ask you to sign the visitors book.

We may also collect any other personal information obtained through electronic means such as telephone recordings and emails.

Using your Information

We may need the categories of information above for the reasons set out in this section. Primarily this will be where we are taking steps at your request prior to entering into a contract and to perform a contract we have entered into with you, and in some cases we may use your personal information to pursue legitimate interests of our own, provided your interests and fundamental rights do not override those interests.

Collecting personal information helps UP Global Sourcing UK Limited better understand your needs, so that we can provide you with a better service. We use your information to:

• Ensure that you receive your orders – without this information we could not get our products and services to you.
• Provide customer care and correspondence– as part of our customer care procedures we may follow-up, either by letter, phone, email or app messenger service, customers who have purchased goods or services from us or who have contacted us, posted comments about us on the internet to resolve a complaint, investigate any concerns, or to discuss faulty goods.
• Personalise our service and your shopping experience– from time to time, we may personalise your shopping experience utilising new technology; using your past purchases and browsing habits to present special offers and new products and services from our range of brands that we think may be of interest to you in order to improve your shopping experience.
• Improve our website– to help us improve your experience and continue to design our website, we may collect information about the way you use and access our website. Our web system collects information about each visitor, including IP address, the length of time spent on the website and the order in which pages are visited. We may employ third-party experts to help us look at this information, however we make sure that anyone we employ treats all information with the same sensitivity and security that we do.
• Prevent fraud– in order to protect both us and our customers from fraud and theft, we may need to look at the information that you provide to make identity checks, as well other information in our customer records and order history. This may be passed to other group companies and financial and other organisations (including law enforcement agencies) involved in fraud prevention and detection, to use in the same way.
• IT Security – in order to monitor your use of our information and communication systems to ensure compliance with our IT policies and to ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
• Recruit – in order to consider you for roles within our company we will need to discuss your application and personal information with relevant employees. Only employees involved within the recruitment process (mainly the HR team) will have access to your information and will keep it secure. If you are not selected for an interview, your personal information will be deleted from our systems within 6 weeks. Should you gain an interview but not be selected for the role we will keep your details on file for 12 months.
• Security and health and safety – visitors to our premises will likely be caught on CCTV and will be asked to sign the visitors book; this is for crime prevention, security and health and safety purposes.

Keeping your Information Secure

We keep your information secure at all times (see below for details as to how) and you should do the same whenever you use our services or websites.

• Payment card security– we use technology including Paypal and Realex to make sure that the details you provide when placing an order are kept private and secure, making shopping on our website safe. Once payment information has been received, your payment card is processed through our secure systems by only team members who have suitable access and permission.
• Security in our offices– access to your information is restricted in our offices and warehouses. Only employees who need the information to perform a specific role are granted access to personally identifiable information, so that we can provide a service to you. The servers that store this information are kept in a secure environment.
• Security– information security is very important to us and we have taken many steps to ensure that your experience with us is secure and that all of your information is kept safe. In order to prevent unauthorised access or disclosure of your information, we have put in place suitable physical, electronic and managerial procedures to protect and secure information that is collected online.
• Regular archiving and deletion – we annually review and audit our procedures to ensure that they remain at the highest standards of security and only those necessary employees have access. As part of this, we will only keep personal information active for legitimate business reasons and usually delete data when it has been inactive for 12 months or longer.
• Password– you should choose a password that is not obvious or known to anyone else and should never give it to a third party, as you will be responsible for all activity and charges incurred through use of your password whether authorised by you or not.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

We may process your personal information without your knowledge or consent where this is required or permitted by law.

Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in any of the following circumstances:

1. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
2. Where we have notified you of the decision and given you 21 days to request reconsideration.
3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

You will not be subject to decisions which have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

Data sharing

In the event we need to share your data with third parties we require third parties to respect the security of your data and to treat it in accordance with the law.

Why might you share my personal information with third parties?

We may share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

“Third parties” includes third-party service providers (including contractors and designated agents) who are not part of UP Global Sourcing UK Limited.  The following activities are carried out by third-party service providers: administration, IT services, sales and marketing, delivery services, payment services, product manufacturers. Pension providers, Health care providers and Medical advice providers for employees only.

How secure is my information with third-party service providers?

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

Safeguarding Measures

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:

• 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 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. 

Data retention

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

UP Global Sourcing UK Limited only processes your personal information in compliance with this privacy policy 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

Compliance Officer

Manor Mill

Victoria Street

Manchester

OL9 0DD

UNITED KINGDOM

Email: data-protection@upplc.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

Notification of Changes to this Policy

If we decide to change our Privacy Policy, 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.

Feedback

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 data-protection@upplc.com or by post to the address above.

Links

Our website may contain links to let you to 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 Policy. 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 Policy 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