Privacy Policy
Trust is what allows us to have meaningful relationships with one another. It is about having faith, learning from interaction, and being open to adjusting positions. Trust is nurtured by honest and open communication and provides a foundation for confidence and partnership. Trust goes hand in hand with responsibility. Only with great leadership and by respecting and exceeding expectations can we succeed. Trust and responsibility are two important values of Upthrust.
We understand that your trust in Upthrust is our most important asset (hereinafter referred to as “we” or “us”). Therefore, we take our responsibility and handle your privacy with great care.
Our aim is to process your personal data in a legal, appropriate, and transparent manner. In this privacy declaration, we explain:
- Which of your personal data we collect from you as a natural person.
- The way Upthrust uses and processes this personal data.
- Your privacy rights and how you can exercise them.
This privacy declaration is applicable to:
- Our website https://upthrust.eu
- All (commercial) relations between Upthrust and its customers, prospects, and business partners.
How can you contact us?
If you have questions about this privacy statement, or the way Upthrust collects, uses, or processes your personal data, please contact us via e-mail: dpo@customercollective.eu
We may collect, store and use the following kinds of personal data:
- Personal identification data (first name, last name, phone number, (company) address, e-mail address, etc.).
- Personal details (gender, education, etc.).
- Data collected through media usage (mobile, desktop, social media, chatbot, etc.).
- Interests in our product offering through download of content made available on our media (website, chatbot, etc.).
- Information provided via forms (message box on contact page, download form, how can we help, feedback, etc.).
- Electronic identification data (IP address, cookies, connections, etc.): Upthrust automatically collects information regarding your use of the website. As such, Upthrust shall, for example, automatically log web pages you have consulted on our site, which web browser you use, which website you visited through which you have reached our website, and what your IP address is. It allows Upthrust to draw up statistics regarding the use of the website and to send more targeted communication. Upthrust also collects information via cookies: the description can be found in a separate cookie policy.
When do we collect your personal data?
When you:
- Subscribe to the newsletter.
- Subscribe to marketing content series.
- Visit the website.
- Complete website forms.
- correspond with Upthrust through our online channels (social media, website, chatbot, etc.).
- Request a quote.
- Give us your business card.
How do we use and on what legitimate ground do we process your personal data?
- We may process personal data in order to comply with legal and regulatory requirements.
- Processing based on our Legitimate Interests and Contractual relations:
For all personal data related to our customers and subcontractors, we process personal data based on our legitimate interests and our contractual relations. This includes:
- Sending direct marketing and advertising, updates, and promotional offers: We use your personal data to provide you with information about our products and services that we believe may be of interest to you. This processing is based on our legitimate interest in promoting our business and maintaining a relationship with you as a customer or subcontractor.
- Conducting customer satisfaction studies, surveys, and market research: We may use your personal data to conduct surveys or studies aimed at improving our products and services. This processing is based on our legitimate interest in understanding our customers’ needs and preferences to enhance our offerings.
- Drawing up a quote: When you request a quote from us, we process your personal data to prepare and deliver the quote to you. This processing is necessary for the performance of our contract with you or in anticipation of entering into a contract.
- Performing our contracts duly and properly (administration, issuing invoices, collecting payments): We process your personal data to fulfill our contractual obligations, such as administering your account, issuing invoices, and collecting payments. This processing is necessary for the performance of our contract with you.
- Processing for Applicant Follow-Up: For pursuing the correct follow-up of our applicants, we process your personal data to evaluate during the hiring process. This processing is necessary for our legitimate interest in assessing candidates for employment opportunities within our organization.
- Processing based on Consent
If you give consent to receive information, we will process your data for sending targeted marketing and advertising, updates, and promotional offers. If you do not want to receive any publicity at all, you can at any time exercise your right to object to direct marketing.
How long do we store your personal data?
Unless a longer storage period is required or justified by law, Upthrust shall only store your personal data for the period necessary to achieve and fulfill the purpose in question. Once that purpose no longer exists, we delete the data.
- Your personal data will be held during the duration of our contractual relationship and up to 10 years thereafter.
- Personal data of prospects will be held for a period of 5 years unless there has been contact with the prospect, at which case a new 5-year period will start. Prospects can always request to have their personal data removed.
- Personal data of applicants will be stored for a period of 2 years following the closure of the hiring process. Unless there is specific consent of the applicant to remain in our database after this period of 2 years, all personal data will be removed.
How do we secure your personal data?
At Upthrust, we are committed to upholding trust and responsibility in handling your privacy. We prioritize the security of your personal data by implementing robust measures to safeguard it against unauthorized access, accidental loss, or disclosure.
1. Compliance with Data Protection Regulations:
We adhere strictly to the applicable Data Protection laws and its implementation measures. Our commitment to compliance ensures that your personal data is processed in accordance with legal requirements and industry standards.
- Organizational and Technical Measures:
We employ a combination of organizational and technical measures to protect your personal data. This includes the development and implementation of comprehensive policies, procedures, and IT security measures. Our staff is trained regularly to ensure they understand and adhere to these measures.
- Supplier and Partner Engagement:
We establish contractual arrangements with our suppliers and partners who handle your personal data or with whom we share information. These agreements ensure that they also maintain the highest standards of data protection and security.
- Continuous Improvement:
We are committed to continually reviewing and enhancing our security measures to adapt to evolving threats and technology. This proactive approach ensures that your personal data remains secure and protected.
Where do we transfer your personal data to? (third parties)
Your personal data is used internally and won’t be shared with third parties for commercial purposes unless you gave Upthrust explicit consent to do so. However, to guarantee an optimal experience, personal data might be shared with or disclosed to:
- Companies related to Upthrust in order to support our internal administrative business processes.
- Professional advisors, service providers, and suppliers, who are authorized to use personal data only as necessary to provide services to Upthrust (IT providers, HubSpot, Salesforce, etc.).
- Other third parties for purposes to which you have consented.
Whenever we share your personal data internally or with third parties in other countries, we ensure the necessary safeguards are in place to protect it. In case of transfer to a country outside the European Economic Area whose local regime is considered inadequate by the European Commission, Upthrust relies, amongst others, on:
- EU Model clauses, which are standardized contractual clauses used in agreements with service providers to ensure personal data transferred outside of the European Economic Area complies with EU data protection law. We may provide you with a copy of these clauses upon request.
- Data transfers that are necessary for reasons of public interests.
- Your explicit consent.
- Data Privacy Framework that protects personal data transferred to the United States.
What are your rights to privacy and how can you exercise them?
We maintain a high level of transparency about data we use. You are entitled (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:
- Request access to the personal data we process about you: this right entitles you to know whether we hold personal data about you and, if we do, to obtain information on and a copy of that personal data.
- Request a rectification of your personal data: this right entitles you to have your personal data be corrected if it is inaccurate or incomplete.
- Object to the processing of your personal data: this right entitles you to request that Upthrust no longer processes your personal data.
- Request the erasure of your personal data: this right entitles you to request the erasure of your personal data, including where such personal data would no longer be necessary to achieve the purposes.
- Request the restriction of the processing of your personal data: this right entitles you to request that Upthrust only processes your personal data in limited circumstances, including with your consent.
- Request portability of your personal data: this right entitles you to receive a copy (in a structured, commonly used, and machine-readable format) of personal data that you have provided to Upthrust, or request us to transmit such personal data to another data controller.
To the extent that the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time by either clicking the unsubscribe link you will find in our e-mail communication or by addressing your request to privay@uphtrust.eu Please note that this will not affect our right to process personal data obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent.
When you wish to exercise any of your rights, you can contact us at dpo@customercollective.eu this is your primary point of contact in relation to privacy matters. We may charge a fee for administrative costs if a request is manifestly unfounded or excessive, in particular because of the repetitive character. Upthrust will properly answer your request within one month after we received your request. Upthrust will need to verify your identity in as much detail as possible, in case someone else tries to exercise your rights. You may, therefore, be asked to provide additional information to confirm your identity when making such a request.
How can you submit a complaint?
If you feel that the privacy statement isn’t respected as it is described, do not hesitate to contact us via dpo@customercollective.eu We will be happy to look into it.
Should you not be satisfied with the way we have responded to your concerns you have the right to lodge a complaint with the supervisory authority ( www.gegevensbeschermingsautoriteit.be).