Privacy and Cookie Policy

The basics:

Who are we?

We are Upgrade Academy(we, our, us) and in these Terms we are described in different ways depending on the activity we engage with concerning your data. We process your personal data if you are a business, and we have a lawful and reasonable basis to do so. We process your personal data if you are a customer of our App or Website and we have a lawful and reasonable basis to do so.

What is the purpose of this policy?

We are committed to protecting the privacy of our customers and business partners. We have written this Privacy Policy (policy) to ensure you have all the information you need about how we collect and process your personal data, and how we make sure it is kept safe. When we collect and process your personal data, we are regulated under the General Data Protection Regulation (EU) 2016/679 (the GDPR) which applies across the EEA and the Data Protection Act 2018.

Who does this policy apply to? 

This policy applies to anyone who uses:
 • our Websites  • our Apps (which means the marketplace booking application and Connect app on Android or iOS)

How do we update this policy?

We understand that things change, so we will continue to review the effectiveness of this policy and make sure it is achieving its goals. We might update the policy from time to time and will post the most recent version on this page. If we make a change to this policy that we consider material, we will notify you via the Platform. 
If you have any questions about this policy or how it works, please get in touch and we would be happy to chat! 

The details - how we are collecting and using your data, and why:

What personal data do we collect and why?

We use a few different methods to collect your personal data. Sometimes you provide us with this data and other times it will be collected automatically when you visit and/or use the Platform.
We collect personal data for a number of reasons, including to meet our legal obligations, manage our operations, improve our organisation and deliver our services to you. Under data protection law we can only use your personal data where we have a legal basis to do so (e.g., legal duty, contract, legitimate interest, consent, etc).

The legal basis, the purpose and the retention period which we apply to our main processing activities are set out below:

Purpose 1: To set up and administer your requested account.
 • Lawful Basis: Fulfilling our contract with you. • Retention period: 5 years in the event of inactivity of the account.

Purpose 2: Processing your comments, reviews or survey responses.
 • Lawful Basis: When it is our legitimate interest to provide good customer service. • Retention period: Until the deletion of your account in accordance with the applicable law. 

Purpose 3: Delivering any emails, surveys, newsletters and alerts that you have signed up to.
 • Lawful Basis: Your consent. • Retention period: Until consent is withdrawn.

Purpose 4: Delivering our services to you.
• Lawful Basis: Fulfilling our contract with you.
• Retention period: 10 years from performance of the contract, or at least until the expiry of the statutory period of limitation that applies to the subject matter of the contract.

Purpose 5: Delivering our services to you.
• Lawful Basis: Your consent.
• Retention period: Until consent is withdrawn.

Purpose 6: Facilitating your booking and delivering the services to you.
• Lawful Basis: Fulfilling our contract with you.
• Retention period: Maximum 10 years after the end of each tax year in which the transaction occurs.

Purpose 7: Responding to complaints, questions and feedback and providing information about your requested service.
• Lawful Basis: Fulfilling our contract with you.
• Retention period: 90 days from the date of call recording.

Purpose 8: Responding to complaints, questions and feedback and providing information about your requested service.
• Lawful Basis: Fulfilling our contract with you.
• Retention period: 30 days after the end of the Live Chat Session.

Purpose 9: Receiving feedback about our services.
• Lawful Basis: Fulfilling our contract with you and our partners.
• Retention period: 30 days after submission.

Purpose 10: Resolving the litigation and investigation.
• Lawful Basis: Fulfilling our contract with you/our legal duty.
• Retention period: 10 years from the end of the investigation/litigation (unless there are grounds to keep for longer).

Purpose 11: Administering the Platform and other systems and protecting them.
• Lawful Basis: Legitimate interest.
• Retention period: Maximum 1 year from entry.

Purpose 12: To improve the Platform and services, using data analytics.
• Lawful Basis: Legitimate interest.
• Retention period: Up to 2 years .

Purpose 13: Showing you content and features that are personal to you and your interests.
• Lawful Basis: Your consent.
• Retention period: Until consent is withdrawn.

Purpose 14: Understanding your preferences for marketing, automated decision-making, profiling, cookies and any other processing activities that you can opt-out of.
• Lawful Basis:Your consent.
• Retention period:Until consent is withdrawn.

Purpose 15: Developing and carrying out marketing activities.
• Lawful Basis: Legitimate interest.
• Retention period: Until consent is withdrawn.

Personal Data:

Type of personal data: Contact information 

• Description: Information about how you use the Platform and services.
• Purpose: Understanding how we can improve the Platform and services, using data analytics.
Showing you content and features that are personal to you and your interests.
• Lawful basis: Fulfilling our contract with you.
When you consent to it.
When it is in our legitimate interest to:
• verify your compliance with our agreements and for defending legal claims
• monitor, improve and protect the Platform, products and services, and personalise these based on your use
• develop our business
• improve our service offering 

Type of personal data: Preferences and consents

 • Description: Your marketing and communication preferences.
• Purpose: Understanding your preferences for marketing, automated decision-making, profiling, cookies and any other processing activities that you can opt-out of.
To send information about your requested services (i.e., appointment reminders).
Developing and carrying out marketing activities.
• Lawful basis: When you consent to it.
When it is in our legitimate interest to:
• notify you about our services and special offers we think you would be interested in
• tailor and personalise ads based on the information you provide and your use of the Platform
• conduct market research and consumer surveys
• use cookies and similar technology 

Do we use cookies and other tracking technologies?

A cookie is a small file of letters and numbers that is stored on your browser or the hard drive of your computer. As with other commercial websites and apps, the Platform uses standard technologies including cookies and similar tools to enhance your user experience, improve our systems and provide tailored offers to you. You cannot actually see cookies as they sit in the background of our systems, but they are probably present on most sites you visit. 
For more information on the cookies we use, please take a look at our Cookie Policy.

What marketing activities do we conduct?

We want you to know all about us, our Partners and the services available. To do this, we undertake marketing activities which sometimes involve using your personal data - such as sending you newsletters via email or showing you online adverts.
You will not receive marketing from us by email or text unless you have given us permission, or unless you have used our services before. These messages might contain information about our services, offers, competitions and other important information.
Third parties
We may disclose your personal data to a select group of third parties. But we treat the security and method of processing your personal data very seriously, and we will never sell your personal data. 

How will my reviews be used?

Any personal data you upload to publicly visible areas of the Platform (such as review sections), may be collected by third parties, and we have no control over this and are not responsible for how they may use this information. We recommend you are careful about the information you disclose in these areas. 

What happens to information you provide via social media?

Parts of the Platform may allow you to submit your own content, such as reviews and photos of your experience. It is important to remember that these submissions can be viewed by the public, and we are not responsible for any actions taken by other individuals if you post personal data on one of our social media platforms. We recommend you are cautious about providing certain information (e.g., card details or your address) and that you refer to the privacy and cookie policies of the social media platforms you use.