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.
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:
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:
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:
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:
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.
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 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:
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.
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.
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:
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:
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:
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
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 firstname.lastname@example.org 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