PRIVACY POLICY

Updated 1 November 2023

UPPERSETUP respects the right to privacy and wants to protect the privacy of those who view or interact with our website [www.uppersetup.com]

Please read the following statement; it will help you to understand how we use the personal data that you may provide to us through the use of our website.

Please note that we may update this Privacy Policy from time to time. We will include a review date at the top of the page so you will know when we make changes.

Unless stated otherwise, this Privacy Policy applies to all of UPPERSETUP’s externally facing applications, services, tools, websites and other data processing activities where UPPERSETUP is acting as a data controller (or any local equivalent).

This Privacy Policy is incorporated into our Terms of Use (the "Terms") by reference and, together with the Terms, constitutes a binding agreement between you and UPPERSETUP. It describes our information handling practices when you access and use our Platform and Services. This Privacy Policy is meant to help you understand the personal information we collect, how we collect, process, use, store, share, and protect it.

About Us

In this Privacy Policy “we”, “our”, and “us” refers to UPPERSETUP TECHNOLOGY LTD. The responsible entity for collecting, processing, using, storing, and protecting your Personal Information is:

  • Name: UPPERSETUP TECHNOLOGY LTD
  • Address: CO-Working GA-00-SZ-L1-RT-208, Level 1, Gate Avenue - South Avenue, Dubai International Financial Centre, Dubai, UNITED ARAB EMIRATES Operating incorporated under the laws of the UAE, registered Licence CL7070
  • Email: [email protected]

If you have any questions regarding this Privacy Policy or wish to make privacy rights requests, please reach out to us using the contact information provided above. If you believe that your privacy rights have been violated, we encourage you to contact us to resolve the matter informally. We are committed to addressing your concerns and ensuring the protection of your personal data in compliance with the applicable data protection laws of the United Arab Emirates (UAE), including regulations set forth by the Telecommunications Regulatory Authority (TRA). If, aŌer contacting us, you are not satisfied with the resolution of your privacy-related issue, you have the right to approach the appropriate data protection supervisory authority in the UAE for further assistance. Please visit the Telecommunications Regulatory Authority's website for more information on how to file a complaint or inquiry regarding data protection (TDRA).

By accessing or using the Platform and Services, you agree to the Terms, including this Privacy Policy, with limitations on damages, loss of profit, dispute resolution, and the application of the law of UAE.

Please reach out to us if you have any questions or require further information about this Privacy Policy. We are committed to protecting your privacy and ensuring a secure experience when using our Platform and Services.

What personal data do we collect?

Personal Information is data that identifies an individual or relates to an identifiable individual, and the definition varies based on applicable law in your location. This includes information you provide, information collected automatically, and information obtained from third parties.

Information You Provide:To access and use the Platform and Services, you will be required to provide certain Personal Information, including but not limited to:

  • Identification Information: Full name, date of birth, phone number, home address, Company name, registration number, legal address, email address.
  • Formal Information: Government-issued identity documents (e.g., passport, ID, driver's license), tax identification number, and other information for legal compliance and for the provision of services.
  • Financial Information: Payment method information (e.g., credit or debit card details, bank details).
  • Transactions Information: Details of transactions made on the Platform.
  • Correspondence Information: Survey responses, information provided to support or research teams, email records.
  • User Information: User-generated content submitted to the Platform.

Information We Collect Automatically:We may collect certain information automatically when you interact with the Platform and Services, including but not limited to:

  • Information about how you access and use the Platform and Services.
  • Device type and unique device identification numbers.
  • Device event information (e.g., crashes, system activity, browser type).
  • Interactions with the Platform and Services, including pages accessed and links clicked.
  • Broad geographic location (e.g., country or city-level).

This Privacy Policy does not cover the use of similar technologies by third parties. Third-party websites, content, advertising, or references may use such technologies. We do not control thirdparty technologies or their usage, and we are not responsible for third-party privacy policies.

Information We Collect from Third Parties:From time to time, we may obtain information about you from third-party sources as required or permitted by applicable law, including:

  • Public databases.
  • Marketing partners and resellers.
  • Advertising networks and analytics providers.

For which purposes and on which legal basis do we use your personal data?

UPPERSETUP uses your personal data only where required for specific purposes. Please view the table below for (i) a list of the purposes for which UPPERSETUP uses your personal data and (ii) an overview of the legal basis for each such purpose.

PurposeLegal basis
Providing Platform and Services, responding to inquiries, and offering customer support.Justified on the basis of UPPERSETUP’s legitimate interests of ensuring proper communication within the organization and with you.
Legal and regulatory compliance, and protection of property and rights.Necessary for the compliance with a legal obligation to which we are subject.
Communication regarding transactions and important changes.Justified on the basis of UPPERSETUP’s legitimate interests of ensuring proper communication within the organization and with you.
Prevention of money laundering, fraud, and other abuses.Compliance with a legal obligation.
Platform and Services improvement, marketing, advertising, and personalized content.Justified on the basis of our legitimate interests for ensuring that we can conduct and increase our business.
Recruiting processes, statistical analysis, market research, and product development.Justified on the basis of UPPERSETUP’s legitimate interests of ensuring that it recruits the appropriate employees and to gain market insights and insights in business and society in general or, where required, the consent of the relevant subjects.
Development, testing, and improvement of new products and services.Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.
Any purpose with your consent.Justified on the basis of UPPERSETUP's legitimate interests of ensuring proper communication within the organization and with you.

Legitimate interest means that UPPERSETUP has reasonable grounds to process your personal information. Where the above table states that we rely on our legitimate interests for a given purpose, we are of the opinion that our legitimate interests are not overridden by your interests, rights or freedoms, given (i) the transparency we provide on the processing activity, (ii) our privacy by design approach and (iii) the rights you have in relation to the processing activity. If you wish to obtain further information on this balancing test approach, please contact [email protected].

We will process your personal data for the purposes mentioned above based on your prior consent, to the extent such consent is mandatory under applicable laws. To the extent you are asked to click on/check "I accept", "I agree" or similar buttons in relation to a privacy statement, doing so will be considered as providing your consent to process your personal data, only in the countries where such consent is required by mandatory law.

Will we share your personal information with third parties?

We are a multi-territory firm and therefore data is processed in all offices for the legitimate interest to ensure efficient running of the business.

We share your Personal Information with third parties under the following circumstances:

  • When required by applicable law.
  • With our subsidiaries, affiliates, and service providers for business purposes (especially Ipravo Management FZE DMCC).
  • With professional advisors for financial, technical, compliance, and legal audits.
  • For fraud and crime prevention, regulatory compliance, and legal claims.
  • Aggregated Personal Information for monitoring Platform and Services usage.
  • With financial institutions to process authorized payments.
  • With companies we plan to merge with or be acquired by.

Information posted in public areas of the Platform may be accessible and used by others. We may also disclose your Personal Information when directed by you, required by law, or for fraud or criminal investigation.

In connection with the above, we may transfer your personal data outside the UAE, including to a jurisdiction which is not recognised by the UAE as providing for an equivalent level of protection for personal data as is provided for in the UAE. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include entering into a contract governing the transfer which contains the ‘standard contractual clauses’ approved for this purpose by the UAE public authority. Further details of the measures that we have taken in this regard are available by contacting us using the contact details below.

Security

UPPERSETUP attaches great importance to your right to privacy and the protection of your personal data. We want you to feel secure that when you deal with UPPERSETUP, your personal data are in good hands. We have protocols, controls and relevant policies, procedures and guidance to maintain these arrangements taking into account the risks associated with the categories of personal information and the processing we undertake. We maintain strong security measures to protect your Personal Information, including physical, electronic, and procedural safeguards. However, your cooperation is essential to maintain security. If you use third-party services (e.g., Stripe) for payments, their privacy policies apply.

Which rights do you have with respect to the processing of your personal data?

You have the right, subject to certain exemptions:

  • to obtain a copy of any personal data we hold about you,
  • to request rectification or erasure of such data,
  • to request restriction of processing or to object to processing,
  • and data portability.

If you become aware that information we maintain about you is inaccurate, or if you would like to update or review your information, you may contact us using the contact information below. We will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate. We may limit or deny access to personal information where providing such access would be unreasonably burdensome or inappropriate under the circumstances. All requests to change personal information will be handled in accordance with applicable legal requirements. If you would like to change your information you should contact us at [email protected].

Cookie Policy

UPPERSETUP does not currently use cookie files or other similar programmes that could have an impact on your personal data. If we add any changes, the use of cookie files will be reflected in this Policy.

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