Privacy policy

What information we collect about you
We collect and process your personal information when you interact with us (for example, the information that you provide by filling in forms on our website, or through correspondence with us by phone, email or in any another way . This includes the information you provide when you register to use the Website, when you subscribe to our services. The information you provide may include your name, address, email and phone number , personal description and photo, age, date of birth and sex, as well as other information, as appropriate. For example, as is described below, we may process, with your consent, in some cases sensitive personal data.
We will not collect or process sensitive personal data relating to you (for example, information about racial or ethnic origin, political opinions, religious confession or philosophical beliefs, health, sexual life or orientation . If you voluntarily provide us with personal data (including personal data sensitive) by interaction on your Website u we not stru or through correspondence with us by phone, email or in any other way, voluntarily and not at our request, we will delete such personal data in our systems if we do not consider that their processing is necessary for a legitimate purpose, unless you have made this data public (for example, in a message forum that is publicly visible), in which case we will delete the data on the Website so required by law or if we want to keep.

Each time you visit the Website , we automatically collect the following data:
• technical data, for example this may include the Internet Protocol (IP) address used to connect your computer to the internet, login information, browser type and version, time zone setting, browser extension types and versions (plug-ins), system and operating platform, device type and mobile device brand; this data may be collected and processed on our behalf through third party cookie files;
• data about your visit, for example, this may include complete Uniform Resource Locators (URLs), sequence of clicks to, through and from the Website (including date and time), information or products you have viewed or searched for (including top articles read, top categories accessed, page response times, download errors, duration of visits to certain pages (including average time spent on certain pages, viewing certain content or videos), average number of articles viewed on websites ours, page interaction information (such as scrolling, mouse clicks and scrolling), methods used to navigate the page, user behavior data
• in some cases, we obtain your personal data (such as name, address, email address and telephone number, personal description and photo, age, date of birth and sex) from third parties, such as business partners, subcontractors of technical, payment and delivery services, advertisers, analysis service providers, market research service providers, credit information agents, known and / or close to you, agents acting on behalf of your or third party production companies. We also to get your personal data from registers and other sources available and accessible to the public.
If we obtain your personal data from a third party, we will provide you with all relevant information about the processing as soon as possible, but in any case not later than one month after obtaining your personal data, including regarding the categories of personal data that are the object of the processing, the purpose of the processing and its legal basis.

How we use personal data and what is the legal basis of the processing
General aspects:
We may process your personal data in case we have to execute a contract that we have concluded with you; whether we must comply with a legal obligation (for example, the laws applicable in labor relations, accounting, auditing, monitoring of equal opportunities); when necessary for our legitimate interests (or those of a third party) and for your interests (for example, detecting and preventing fraud or ensuring IT and network security), unless your fundamental rights prevail over you of these interests; whether it is necessary to protect your vital interests (or other people's vital interests); and / or if necessary for the public interest or for official purposes.
We process your personal information for a variety of technical, administrative and operational reasons, such as to ensure that the content is presented in the most efficient manner for you and your computer; to improve the Website, including its functionality; for administration; for internal operations, including for the purposes of troubleshooting, data analysis, testing, research, statistics and research; for advertising and marketing, including for specific marketing purposes, so that we provide content, including personalized content, that may be of greater interest to you; and as part of our efforts to keep the Website u it safe.
In some cases, we will process your personal data only with your consent . In these cases, we will ask for your consent separately, in a transparent manner, when providing your personal data. You will then be able to withdraw your consent at any time by sending an email to gdpr@uppmobile.com . However, the withdrawal of the consent will not affect the legality of any processing that took place before its withdrawal.

If we request personal data to comply with legal or contractual obligations, the provision of such personal data by you is mandatory. This means that, if such personal data is not provided, we will not be able to manage the contractual relations or comply with the obligations imposed on us. In all other cases, the provision of personal data is optional and you are under no obligation to provide them.
Most commonly, we will use your personal information in the following situations:
Users and customers :
In order to provide services, deliver goods and make payments based on relevant contracts (including subscriptions), we may process your personal data, such as identification data, contact data, bank data. This processing is based on the performance of a contract to which users (especially subscribers) are part of or a legal obligation to us is required.
We process personal data so as to we can provide information about the goods or services we think you need. If you are an existing customer, we will only contact you via email, SMS or push notifications through Mobile Applications (as applicable) with information about goods and services similar to those that were the subject of a previous sale or negotiation with you. for sale, unless you have chosen otherwise. If you are a new customer, we will only contact you electronically if we have your prior agreement. If you do not want to use your data in this way, select the appropriate box in the form where we collect your data from the registration form. If you have a Mobile App installed and you do not want to receive push notifications, you can change the settings on your mobile device or through the Mobile App.
We will not share your personal data with third parties for marketing purposes without your explicit consent.
We may also use your personal data to measure or understand and provide content relevant to you; to allow you to participate in the interactive features of our service, when you choose to do so. to measure or understand the effectiveness of the advertising we provide to you and others and to provide you with relevant advertising; and to make suggestions and recommendations for you and others .

Fulfillment of applicable legal obligations
UppMobile processes personal data whenever it is necessary to comply with the legal obligations in force, including in the following situations:
• Verifying your identity;
• Conducting checks in order to prevent money laundering, fraud prevention and detection and other verification obligations required by law;
• Disclosure of your personal data as a result of a legal objection (for example, to a public authority or court).

How and to whom we disclose your personal data We do not sell your personal data to third parties.
• Within the Company, only a limited number of staff, such as those in the Sales, Legal, IT departments have access to your personal data according to the principle of need to know ("on a need to know basis"). These staff members are subject to confidentiality obligations regarding personal data. Appropriate technical and organizational measures are taken to protect personal data.
• Personal data may be disclosed to government authorities and / or bodies enforcement if this is required by applicable law or is necessary for the exercise of our rights, including the conditions of use, or to protect our legitimate interests (including the legitimate interests of third parties) in accordance with the applicable laws.
• Your personal data may also be disclosed to third parties, including:
• service providers that provide administrative, professional and technical support to the Company for IT support, security and commercial resources;
• business partners, suppliers and subcontractors for the execution of all the contracts we conclude with you (including subscriptions to our services);
• agencies advertising and advertising networks that require your information to select and serve relevant ads to you. We do not disclose personally identifiable information to advertisers, but we will provide aggregate information about our Users (for example, we can report that 500 men / women under the age of 30 clicked their ad in a certain day). We may also use such aggregate information to help advertisers to reach the kind of audience you are targeting. We may use the personal information we have collected from you to comply with the wishes of the advertising agencies by displaying their advertising messages to the target audience;
• providers of services of analysis and search engines that help us in improving and optimizing website
• The Company may disclose also personal data of external consultants (eg, lawyers, accountants, auditors), if it is necessary.

Storage of your personal data and transfers abroad
Your personal data we collect are stored in the European Union ("EU") and in the European Economic Area ("EEA"). However, information collected by third parties through cookies (for example, through Google Double Click for Publishers) will generally serve traffic from a data center that is closest to where it comes from. traffic. This means that such information, including ad traffic, can be managed by servers located in the EEA and may be transferred outside the EEA .
In addition, your personal data may be transferred and stored to a location outside the EU and the EEA. When your personal data is transferred from your own country to another country, the laws and rules that protect your personal data in the country to which your information is transferred may be different (or may offer less protection) than those in the country. where you work.
We intend not to transfer your personal data outside the EEA unless there are adequate safeguards, including: (i) a decision on the adequacy issued by the European Commission regarding the country or countries of destination; (ii) a "privacy shield" certification; (iii) appropriate corporate rules; (iv) an approved code of conduct, together with the obligatory and enforceable commitments of the data operator or the person empowered by the data operator in the country outside the EU and the EEA; (v) an approved certification mechanism, together with the mandatory and enforceable commitment of the data operator or the person empowered by the data operator in a country outside the EU and the EEA to apply the appropriate guarantees; or (vi) EU standard contract terms approved by the European Commission.

YOUR RIGHTS
You may ask us to confirm whether or not your personal data is processed by us, provide you with a copy of your personal data and / or correct it. In certain circumstances, you have the right to ask us to delete your personal data or, based on the right to portability, ask us to transfer some of your personal data to you or other entities. You also have the right to object to the processing of your personal data (for example, the use of processing for direct marketing purposes or certain decisions made only through automated processing (including profiling). we have requested the consent for the processing of personal data, you have the right to withdraw this consent without negative effects on you. If we process your personal data because we have a legitimate interest in doing so (as explained above), You also have the right to object to this processing, and you also have the right to restrict the processing of your personal data under certain circumstances.
Please note that your rights described above may be limited in certain situations and are subject to applicable laws and regulations regarding the protection of personal data; for example, your right to object to the processing of your personal data may be limited if we can demonstrate that we have compelling legitimate reasons to process your personal data that prevail over your interests. In addition, the right to delete personal data may be limited if we are unable to perform the contractual obligations assumed to you or if we have a legal obligation or a legitimate interest to keep the data. You will need to prove your identity and provide us with other details to help us respond to your request. We will not charge a fee to answer your request unless this is permitted by law and, if such a fee is charged, it will be reasonable and proportionate to your request.

How long we keep your personal data
We intend to keep your personal data only for as long as necessary, in accordance with our Data Retention Policy, for a period not exceeding the period required to accomplish the purposes listed in this Information Note and / or required by applicable law in accordance with the applicable statutory minimum retention periods and / or as necessary to exercise our legitimate rights (and the legitimate rights of other persons). For example, if you are a Business Partner, we will keep your personal data during the contractual relationship with you. If we have a continuous business relationship with you as a Business Partner (for example, if we can use the same personal data in separate contractual relationships with you), we will continue to keep this personal data until the termination to our business relationship and for the minimum retention period required by law, subject to our Data Retention Policy. In the case of Application Users, we will keep your personal data for the period during which the Mobile Application is downloaded or the period indicated by the relevant legislation, subject to our Data Retention Policy. Please keep in mind that we may process any of your personal data that has become anonymous without prior notice.

If we process your personal data based on your consent, such personal data will only be processed for the period provided by your consent, unless you withdraw or limit your consent before this period expires. In such cases, we will cease processing the respective personal data for the relevant purposes, subject to any legal obligation to process such personal data and / or our need to process such personal data for the exercise of our legitimate rights. (including the legitimate rights of other persons).

Data security
We keep your data on our servers and on servers hosted by third parties. We use appropriate technical and organizational measures designed to protect your personal data and prevent unauthorized access. We have entered into contractual relations with third parties offering hosting services and these contracts include obligations regarding the organizational and technical security of personal data. All payment transactions will be encrypted (for example, using the TLS protocol). You are responsible for maintaining the confidentiality of all means of authentication (eg password) you used for the access part of the website ui . Data transmission over the internet is not completely secure. Although we will do our best to protect your data, we cannot guarantee the security of your transmitted data; any transmission is at your own risk. Once we receive your data, we will use strict procedures and security features to try to prevent unauthorized access.

Confidentiality of data of minors
We assume the obligation to protect the confidentiality of personal data of minors who have not reached the age of 16 years. If you are under the age of 16, please first obtain permission from your parents or guardian to provide us with this personal data. As a result, we reserve the right to take reasonable steps to verify this fact, including contacting your parents or guardian to confirm their consent.

Cookies and social media widgets
Our website u use cookie files to your distinguished from other users of our website . This helps us to give you a good experience when browsing and also allows us to improve our Website. This processing is based on your consent expressed on the Website or through the settings in your browser.
Our website appliances can includes social communication functions, such as button Facebook, Twitter, Instagram, LinkedIn or Youtube. This functions may collect information about you, such as your IP address and websites that visit, and can set a cookie file to allow it to work properly. The processing of this information through interactions with these features is governed by the information note / privacy policy of the company that provides them .

Links to other websites
Our website may provide links to websites that the Company does not control. Once you click on a third party link, you will be redirected to the third party website. If you visit any of these linked websites, you must review their privacy policies. We are not responsible for the policies and practices of other companies. Our company does not control and assume no responsibility for the content, privacy policies and information notes or practices of third party websites or services.

Contact
If you have questions or concerns regarding the processing of your personal data or if you want to exercise your rights, please contact responsable person for privacy at gdpr@uppmobile.com. Please do not disclose sensitive personal data (for example, information on racial or ethnic origin, political opinions, religious or other beliefs, health or union membership), social security numbers or information related to the criminal record when you contact us.