Last updated: 18th June 2019
We take data protection very seriously and understand the importance of protecting your privacy and Personal Information. “Personal Information” is information that identifies you as an individual such as your name, date of birth, email address and IP address.
How do we collect information from you?
The majority of the Personal Information we hold you freely provide to us when you submit to us your purchase details or register with the site. If there is any information you would prefer us not to have, please omit this from any submissions sent to us. Some personal data is necessary for us to create an account for you and to fulfil any subsequent order, so in the instance where you do not want to share this Personal Information, we will be unable to provide our services to you.
What Personal Information do we collect?
Personal Information we collect and store about you may include the following:
General identification and contact information: your name; address; email; IP address; telephone details; gender; marital status; family status; date and place of birth; physical attributes including photos
- Information enabling us to provide product recommendations: age, sizes, location
- Information from Apps: User generated content submitted through contributing to online forums, commenting on blog posts, completing onsite forms or emailing any of our internal services teams
- Marketing preferences: defined when entering a competition or prize draw, submitting a survey response or other sales/marketing promotional activity
- Statistical information: aggregate statistical information about site visitors and users for internal use and for other lawful purposes such as salary comparison services. Where we utilise such information, we will do so using an anonymous format and not include any Personal Information.
What legal basis do we rely on to process your Personal Information?
- Consent: In some cases, UpCountry processes your data with your consent. For example, we rely on consent when linking your UpCountry account to your Social Network account. You have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn
- Processing required to fulfil a contract: UpCountry may process your data when we need to do this to fulfil a contract with you, such as deliver an item you have purchased from us
- Legitimate Interest: UpCountry can also process your data when it is deemed our legitimate interest to do so and when these interests are not overridden by your data protection rights. Examples may be to show you similar items or products we believe you may be interested in based on transactional history or previous browsing behaviour.
Our legitimate interests include:
- Ensuring the security and integrity of our Services at all times
- Enabling our Websites and Apps to operate effectively
- Protecting and maintaining the safety, health and welfare of our customers, employees and other individuals
- Promoting, marketing and advertising our products and services and/or sending promotional communications which are relevant and tailored to individual customers
- Understanding our customers activities, needs, behaviours and preferences
- Developing new products and services and improving existing products
- Managing complaints, queries, customer contacts or disputes
- Fulfilling our obligations to our customers, employees and shareholders
The basis for processing this information will be based on an applicable legal obligation. Other examples where UpCountry may process your data include complying with our legal and regulatory obligations, such as preventing, investigating and detecting crime, fraud or anti-social behaviour, this may include the need to work and share this information with law enforcement agencies.
Who do we share your Personal Information with?
UpCountry may make Personal Information available to the following:
- Our service providers: This includes, but is not limited to, external third-party service providers such as accountants and auditors, IT systems, support and hosting service providers, market research and analysis service providers, data storage and cloud providers and other outsourced providers that assist us in carrying out business requirements
- Governmental authorities and third parties involved in court action: UpCountry may share Personal Information with governmental or other public authorities and third-party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate. Examples would be to comply with applicable law, protect our operations, and to protect the rights of ourselves, our group, you or others
- Other third parties: Where appropriate, we may occasionally share Personal Information with other third parties. This will always be done under contract and in accordance with your instructions.
Friday Media Group utilise a number of services and third party products to aid us in providing you with the best on and offsite experience we can. Some of these services are non-negotiable and any request not to have your data shared with these services may mean we are unable to provide you with use of our site(s). In case of a query, please contact our DPO using the details provided below and we will be able to assist you further.
The following is a list of services we utilise and that details we hold about you may be shared with and why:
Business Intelligence/User Experience
To optimise our on-site conversion processes, providing you with smoother transaction experiences.
- To allow us to communicate with you on-site via web chat services.
- To guide our business decisions, providing you with a better product and experience.
- To visualise and analyse website usage data (including user journeys and paths).
- To optimise our sales and marketing campaigns, ensuring they are best tailored for your interests and purposes of using our services.
We work with the following Third Parties to facilitate the above:
- Google Analytics
- MySQL workbench
- Data Studio
Direct & Automated Marketing
We may share your data with Third Party processors for the following purposes:
- To contact you via Email; SMS; Social Media; Telephone and Mail regarding orders; offers; promotions; products or services.
- To enhance and improve our marketing/advertising campaigns to you, providing you with a more tailored service.
- To facilitate in providing you with an improved product or service.
- To enrich our data, with your consent, for the purposes listed above.
- To automate our internal marketing processes and services.
We work with the following Third Parties to facilitate the above:
- Google Adwords
How we use Personal Information?
- Provide marketing information to you (including information about other products and services offered by selected third-party partners) in accordance with preferences you have previously provided.
- Carry out market research and analysis, including satisfaction surveys
- Allow you to participate in contests, prize draws and similar promotions
- Enable social media sharing functionality
- Personalise your experience on UpCountry by presenting information and advertisements tailored to you
- Manage our infrastructure and business operations, and comply with internal policies and procedures
- Comply with applicable laws and regulatory obligations
- Establish and defend legal rights; protect our operations or those of any of our group companies or customers (you)
- Resolve complaints, and handle requests for data access or correction
- Communicate with you as part of our business and distribute important information regarding changes to our policies
We require your identification, contact and payment information to enable us (and Friday Media Group as the parent company) to enter into a contract with you. Without this information we are unable to do so and therefore this is a non-negotiable term of using our service. Your details will need to be passed to third parties in order for them to supply or deliver the product that you ordered, without whom we cannot fulfil the purchase. If you are not happy for us to do this then please do not use our services. We will retain your details for a reasonable period of time after you have completed the transaction in order to fulfil any contractual obligations such as refunds, guarantees etc and to meet any legal obligations for the retention of transactional data.
How can you manage or delete Personal Information?
Below are the ways in which you can take control of how we use your Personal Information:
When you register or make a purchase through UpCountry, you will create an account on the site, against which we will store your basic details such as name and address. On future visits, when logging in to your ‘My Account‘ area, it is protected by your password and may only be accessed by you. You can manage the content and information in your Account at any time, by logging in to your “My Account“. As part of the account creation process, you will also agree to our Terms and Conditions and can choose how we keep in contact with you. If you want to update your marketing preferences, you can do so at any time by logging into your account and updating your preferences.
Communications and Promotions:
You can decide to update your preferences or unsubscribe from marketing and promotional information that we may send to you by using the below methods:
- Using the preferences or unsubscribe functions at the bottom of any email we send
- Contacting us on the Contact Us page of UpCountry
- Emailing our DPO using the details found below
When you access our website online, we store some information about you. This is generally anonymous and used for statistical purposes. However, UpCountry uses a specific cookie to work with Google Universal Analytics and help us to understand how logged in users interact with our site. We do this by utilising a User ID we store against every user and combining this with the Google Analytics stored information. The information we collect helps us to provide a better experience and allows us to understand how you use UpCountry to fulfil your goals.
Deleting your Personal Information:
If you would like to permanently delete your account and all information held on you (that isn’t legally required to be kept for legitimate business purposes), you can send an email to our Data Protection Officer (DPO) with the subject line “Permanently delete my information and account”. Make sure to let us know who you are so we can identify the information to be permanently deleted.
UpCountry is committed to keeping your personal data safe and secure from unauthorised access to or unauthorised alterations, disclosure or destruction of information that we hold. We operate secure data networks protected by industry standard firewall and password protection. We have security measures in place to attempt to protect you to our fullest capability. To minimise any potential breach or misuse, only cleared employees have access to the Personal Information that you provide us.
UpCountry use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable. These providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, we will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including Personal Data, by these companies.
You have the following rights:
- The right to ask what personal data that we hold about you at any time (Friday Media Group retain the right to charge an administrative fee, fixed at £10, in cases where the request for information can be deemed excessive)
- The right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you free of charge
- The right to opt out of any marketing communications that we may send you
- The right to object to how your Personal Information is being used;
- And ultimately the right to request erasure of any data we hold on you in line with legal obligations to the contrary
If you wish to exercise any of the above rights, please contact our DPO using the contact details set out below.
Third Party Privacy Practices
UpCountry may make links to other websites available to our customers where we feel there is a benefit or service that our customers may find useful. When you click on such links, you may leave our Site. In some instances, pages we operate may contain information provided by third-party Employers.
Who to contact about your Personal Information
The data controller responsible for your information is UpCountry.
If you have any questions about this policy or our use of your Personal Information you can email: email@example.com or write to the Data Protection Officer, Friday Media Group Ltd, London Road, Sayers Common, West Sussex, BN6 9HS.
If you do not think we are handling your Personal Information adequately, you have the right to lodge a complaint with the Information Commissioner’s Office.
The Site is operated by Friday Media Group Ltd, registered in England. Registered number: 01874025. Registered address: London Road, Sayers Common, West Sussex, BN6 9HS