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PRIVACY POLICY FOR UPRIGHT SOLUTIONS APS

Last Updated: 8 July 2024

1. GENERAL INFORMATION

1.1. Upright Solutions Aps, company registration number 41116552 having its registered address at Richard Boones Vej 8, 1.tv., 2450 Copenhagen SV, (“Upright” “we” or “us”). This document contains a policy statement regarding Upright collection, use and processing of Personal Data (“Privacy Policy”). This Privacy Policy applies to the www.upright.co and various webs pages operated by Upright which include a link to this Privacy Policy (“Website”) as well as the Ethical Application (the “Service”). This Policy informs you of how we process Personal Data when you use our Website and the Application.

1.2. All definitions in this Privacy Policy shall be interpreted in accordance with applicable data protection laws which refers to the Danish Data Protection Act (no. 502 of 23 May 2018) and the General Data Protection Regulation (Regulation no. 2016/679) and the Directive on Privacy and Electronic Communications (Directive 2002/58/EC), as well as the national implementations and related national legislation.

2. PROCESSED DATA, PURPOSE & GROUND FOR PROCESSING

2.1. Provision of the Services

2.1.1. Personal Data processed We will process the following personal data on behalf of our Customer’s, when we contract with customers and when their Users are added to the Customer’s Application:

(a) Name;

(b) Users' first name;

(c) Users' last name;

(d) Users' phone number;

(e) Users' email;

(f) Users' job title;

(g) Users' IP-address;

(h) Users' Location data;

(i) Information about your use of the Services;

(j) Content that you or users post, upload and/or contribute to the Services; and

(k) Technical data, which may include the URL you are accessing the Website from, your IP address, unique device ID, network and computer performance, browser type, language and identifying information and operating system.The processing of the personal data above is necessary to enter into the agreement with us and is necessary to maintain the contractual relationship between the Customer and us.

2.1.2. Purpose of processing

We will process the personal data set out above for the following purposes:

(a) To administrate your account, to enable and provide the Services and integration with third party services, and to provide, personalize and improve your experience with the Services, and to otherwise provide the Services according to the terms of use;

(b) To inform you about updates of the Services or the terms of use;

(c) To improve and develop the Services or new services and products and to analyze your use of the Services;(d) To ensure the technical functioning of the Services and to prevent use of the Services in breach of the terms of use; and(e) To enforce the terms of use, including to protect our rights, property and safety and also the rights, property and safety of third parties if necessary.

2.1.3 Legal basis for processing

Contractual performance: By entering into a contract with us you accept our processing of your personal data in order for us to be able to fulfill our contractual obligations with you.

Legitimate interest: The processing of your personal data is also conducted on the basis of the legitimate interest of Upright. We have a legitimate interest for the processing as we log data when you use our Services to be able to maintain sufficient IT-security, and to protect the Website and the Services from cyber threats. We also log data for the purposes of maintaining and improvement of our Website and Services.

If you object to the Processing of your Personal Data that is Processed based on the legitimate interest of the controller, we will cease to Process your Personal Data for these purposes if we have not been able to provide you with sufficient support for our Processing.

2.2. Website

2.2.1. Personal Data processed

Upright collects the following data: Personal identification information (first name, last name, title, company, email address). You directly provide Upright with most of the data we collect. We collect data and process data when you (i) Register for a demo, sign-up for a newsletter, an event, or to access specific content on our website and (ii) Voluntarily complete a survey or provide feedback to us.

  • 2.2.2. Purpose of processing

We will process the personal data set out above for the following purposes:Business to business relationship and marketing, such as:

  • Respond to your requests for information;Send you dedicated newsletters or invite you to events you may be interested in;
  • Email you with information about our products, news, events or services we think you might like.

2.2.3 Legal basis for processing

When required, we obtain and rely on your consent to send you business to business marketing communications. Where we obtain your information in the context of a transaction, we may later contact you to conduct business to business marketing.

Our Company would like to send you information about products and services of ours that we think you might like. If you have agreed to receive marketing, you may always opt out at a later date, by following the unsubscribe link or instructions provided in any email we send.

3. USE OF THIRD PARTIES

3.1. From time to time we may work with third parties to provide the Services. These third parties would typically include providers of our IT systems (emails, storage, CRM, accounting etc.). Specific sub-processors are listed in Data Processing Agreements entered into with Upright’s customers.

3.2. When you provide us with contact information on our website, we may store this information with subcontractors.

3.3. In such cases as listed above, these third parties would only have access to your information to perform the tasks on our behalf and cannot use the data for any other purpose, and be bound by similar data protection requirements as Upright is.  

4. DISCLOSURE OF PERSONAL DATA

4.1. Except as provided above in Section 3, we do not share and disclose your personal data.

4.2. When visiting our Website and using the Services you may be directed to other websites where the personal data collected is not in our control. The privacy policy of the other website will govern the personal data obtained from you on that website.

5. RESPONDING TO LEGAL REQUESTS AND PREVENTING HARM

We may access, preserve and share your personal data in response to a legal request (like a search warrant, court order or a subpoena or the like), or when necessary to detect, prevent and address fraud and other illegal activity, to protect ourselves, you and other users, including as part of investigations.

6. COOKIES, PIXELS AND OTHER SYSTEM TECHNOLOGIESWe collect information by using technology such as cookies, pixels and tags (on your browser or device). For information about how we use this type of technology, please see our cookie policy.

7. SECURITY & RETENTION

7.1. We store your personal data securely and take all reasonable steps to protect your data.

7.2. When we collect personal information on our Customer’s behalf, we  store such personal data as long as needed to perform the Services and as long as there is a customer relationship, and retain such data in line with the Data Processing Agreements entered with our Customers.

7.3. When we collect personal data on our own behalf, we will keep it for as long as we have a relationship with you and 1 month thereafter (unless agreed otherwise with you).  7.4. We will store anonymous data for improvement of the Service.

8. YOUR RIGHTS

8.1. You have the right to request access and further information concerning the processing of your personal data, or request that we correct, rectify, complete, erase or restrict the processing of your personal data. You have the right to obtain a copy of the personal data that we process relating to you free of charge once (1) every calendar year. For any additional copies requested by you, we may charge a reasonable fee based on administrative costs.

8.2. If the processing is based on the legal grounds consent or fulfillment of contract you have the right to data portability. Data portability means that you can receive the personal data that you have provided to us, in a structured, commonly used and machine-readable format, and have the right to transfer such data to another data controller or processor.

9. CONTACT INFORMATION

9.1. To exercise your rights, or if you have any questions regarding our processing of your personal data, please contact us at the following address:

[email protected]

or:

Upright Solutions Aps, Richard Boones Vej 8, 1.tv., 1561 Copenhagen SV, Denmark.

In your letter/email please state your full name and e-mail address.

9.2. If you have any complaints regarding our processing of your personal data, you may file a complaint to the competent data protection authority. You can find out more about the local data protection authorities under the following link http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

10.  CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be updated from time to time. If we make changes to this Privacy Policy we will do our best to notify you by e-mail where possible and update it on this page.

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