UPGRADE Privacy Policy

Welcome to our Privacy Notice. Here we tell you what kind of personal data we collect about you, how we use it and what are your rights as a data subject. This Privacy Notice applies to you if you are:

• Our customer or a potential customer
• A Visitor to our website
• A representative or contact person of our corporate customer or business partner

UPGRADE (“we”, “us”, or “UPGRADE”) is the data controller of the data described in this Privacy Notice.

Please also note that the UPGRADE website may contain links to other websites. Our Privacy Notice applies only to our website, so if you click on a link to another website, you should familiarize yourself with their privacy notice.

To make it easier for you to find the information you need, we have divided this notice into the following sections:

1. Information we collect
2. Why do we collect data?
3. How do we use your cookies?
4. Marketing activities
5. How do we secure your personal information?
6. Data Disclosure
7. Your privacy control
8. Changes to the privacy policy
9. Contact us

Information we collect

When you use our website, we collect certain information from you. This information may include:

• Your name and contact information (such as your email address and phone number)
• Your payment information (such as your credit card number and billing address)
• Information about your transactions on our website (such as the products you purchase and the dates of your purchases)
• Information about your device and browsing activity (such as your IP address, browser type, and operating system)
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Why do we collect data?

We collect this information for the following purposes:

• To provide our services to you, including processing your transactions, maintaining and improving our services, and communicating with you
• To provide personalized services to you, such as recommending products, generating personalized content, and customizing search results
• To carry out customer surveys and research
• To comply with applicable laws and regulations

How do we use your data?

We use the information we collect from you for the purposes described above. We may also use your information for other purposes, such as:

• To send you marketing communications, such as email newsletters and promotional offers
• To analyze your browsing behavior and interests to improve our website and services
• To improve our customer service
• To protect our rights and property

When you make a payment or payment subscription on our website, your transaction and payment details will be submitted to our payment service partner, who provides the payment function. Similarly, we will share the details of your order with our logistics partner to deliver the product to you or collect the product from you.

If you choose a deferred payment option and therefore apply for credit, our payment service providers may carry out credit checks to ensure your creditworthiness. Please refer to the relevant partner's privacy notice for more information on their data processing activities.

We collect and process your data to fulfill the contract between us and to provide you with our services. We also use your data for marketing and customer survey purposes, based on our legitimate interest to advertise our products and services to you and develop our business. If you subscribe to our newsletter, the legal basis for processing your data concerning this is your consent, and you may revoke it by unsubscribing to our newsletter.

We may also collect additional identifying information from you, such as your ID copy or ID number, if we are subject to a legal obligation requiring us to do so, or if it is necessary for fraud prevention activities carried out in our legitimate interest. In addition, we and our payment service partners may use fraud prevention technologies to ensure that we are entering into a legitimate transaction with you and to block possible attempts to make purchases with stolen identities or payment information. When we do this, it is based on our legitimate interest to avoid fraud and criminal behavior in our business, and the data collected from you may be matched with public information or databases to deduct the fraud risk level in the specific case.

If you consent to our marketing or otherwise submit your details to us:

• We will collect your contact information, such as your name, email address, and phone number.
• We will also collect information about your consent status.
• We use this information to send you marketing communications, such as emails about new products, special offers, and other promotions. You can opt out of marketing communications at any time by unsubscribing from the emails or contacting us.
• From time to time, we may also organize different kinds of campaigns or competitions, where you can provide us with your contact details and possibly other information relating to the specific campaigns in connection with your participation. For example, we may ask you to provide your shipping address if you win a prize.
• We use this information to carry out the campaign or competition activities and to contact you in relation to your participation.

When you visit our website:

• We collect certain technical and other information from your device. This information includes your IP address, browser and device details, and the source of your visit.
• We use this information to provide you with the website and the services included in it.
• The legal basis for this collection is our legitimate interest in providing you with a website and services that are tailored to your needs.
• We may also collect information about your website usage by using cookies.
• We use this information to improve our website and to provide you with a better user experience.

You can learn more about cookies and how to control them in our Cookie Policy

If you are a representative or contact person of our corporate customer or business partner, or an individual entrepreneur collaborating with us, we collect the following information about you:

• Name and contact details
• If you are an individual entrepreneur, data that is necessary to identify you as our contractual counterparty
• Position and other information about your connection to our customer/business partner
• Possible details about our interactions and your preferences

We collect this information from you directly when you communicate with us, or from your organization and its other representatives.

We use this information to manage our relationship with you, execute the contract with our corporate customer or business partner, and communicate with you in relation to this.

The legal basis for data processing is our legitimate interest in managing the contractual relationship and cooperation with our customer or business partner.

If we are obligated to report transactions related to our collaboration to tax authorities, we may also need to collect your personal tax identification number.

The basis for the collection and purpose of processing this data is complying with a legal obligation we are subject to.

How do we use your cookies?

We use cookies to make your experience on UPGRADE more enjoyable. Cookies are small files stored on your computer or mobile device when you visit our website. They allow us to remember your preferences and settings, and to track how you use our website.

We use the following types of cookies:

• Strictly necessary cookies: essential for the website to function and cannot be disabled in our systems. They are usually only set in response to your actions, such as setting your privacy preferences, logging in, or filling in forms.
• Functional cookies: allow us to remember your choices (such as your login, language, or region) and provide enhanced, more personalized features and content. We may also use them to provide services you have asked for, such as watching a video or commenting on a blog. The information these cookies collect is anonymous and cannot track your browsing activity on other websites.
• Performance cookies: collect information about how you use our website, such as which pages you most visited, how long you spend on each page, and what errors occur. This helps us to improve the performance of our website and make it easier to use.
• Targeting cookies: used to deliver tailored advertising on our website and other websites. They remember the websites you have visited and the pages you have viewed, and this information is used to show you relevant advertising.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer.

If you choose to decline cookies, you may not be able to fully experience the features and functionality of our website.

Marketing activities

We may use your data for marketing purposes. This includes sending you emails, text messages, or other communications about our products, services, and offers. We may also use your data to create targeted advertising for you on other websites.

We will only send you marketing communications if you have:

• Gave us your consent to do so.
• Previously purchased our products or services.
• Engaged with our business in a way that suggests you may be interested in our products or services.

You can always opt out of receiving marketing communications from us by clicking on the "unsubscribe" link at the bottom of any email or text message we send you. You can also contact us at info.upgrade.me to request that we stop sending you marketing communications.

How do we secure your personal information?

We build security into our services to protect your information

We take the security of your personal data very seriously. We store your data for as long as necessary for the purposes described in our privacy policy, or for as long as required by law. We apply both technical and organizational measures to keep your data secure. These measures include:

• Using secure data centers with physical access controls
• Using encryption to protect your data in transit and at rest
• Only granting access to your data to employees who need it to do their jobs
• Regularly reviewing our security measures to ensure they are up to date

You can be confident that your data is safe with us.

Data Disclosure

We take the privacy of your data very seriously. We only share your data with third parties when it is necessary to provide you with the services you have requested or to comply with a legal requirement. For example, we may share your data with:

• Our logistics and payment services partners for delivering your products and processing your payments.
• Our IT service providers, to helping us maintain our website and systems.
• Our marketing partners, send you marketing communications about our products and services.

We may also disclose your data to third parties if:

• We are required to do so by law, for example in response to a request from a government agency.
• We believe it is necessary to protect our rights, property, or safety, or the rights, property, or safety of our customers or others.
• We are involved in a merger, acquisition, or sale of all or part of our business, in which case your data may be transferred to the new owner.

You can always opt out of receiving marketing communications from us by clicking on the "unsubscribe" link at the bottom of any email we send you.

You can also contact us at info@upgrade.me to request that we delete your data.

Your privacy control

You have the following rights with respect to your personal information:

• Access: You have the right to request a copy of the personal information we hold about you.
• Correction: If you believe that your personal information is inaccurate or incomplete, you have the right to request that we correct it.
• Deletion: In certain circumstances, you have the right to request that we delete your personal information.
• Restriction: In certain circumstances, you have the right to request that we restrict the processing of your personal information.
• Objection: In certain circumstances, you have the right to object to the processing of your personal information.
• Withdrawal: If you have given us your consent to process your personal information, you have the right to withdraw your consent at any time.
• Portability: In certain circumstances, you have the right to request that we transfer your personal information to another organization.

You can exercise these rights by contacting us at the contact information provided at the end of this privacy notes page.

Changes to the privacy policy

We may update this privacy notes page from time to time. Any changes to this privacy notes page will be effective immediately upon posting on our website. We encourage you to periodically review this privacy notes page for the latest information on our privacy practices.

If you have any questions about this Privacy Notice, the personal data we hold of you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.