Privacy Policies

1. General

● The brand “The Upstreamers“ (“we” or “us”) takes the privacy of your information very seriously. Our Privacy Policy is designed to tell you, the user of our services, about our practices regarding the collection, use and disclosure of personal information which may be provided to us via our website and other digital products we provide or collected through other means such as an online form, email, or telephone communication.

● In this notice references to the “Site” are references to any website or other means by which you provide personal data to us or access our services.

● This notice is governed by the EU General Data Protection Regulation (the “GDPR”) from 25 May 2018.

2. Basis on which we process personal data

● the processing is necessary in pursuit of a “legitimate interest”, a legitimate interest in this context means a valid interest we have or a third party has in processing your personal data which is not overridden by your interests in data privacy and security;

● you have consented to the processing for the specific purposes described in this notice;

● the processing is necessary in order for us to comply with our obligations under a contract between you and us.

3. Personal data we collect

● Personal information we hold if you have interacted with us – made a general enquiry or request and also when you participate in brand assessment (“Communication Information”);

● Some of the data we collect we may store at https://www.typeform.com/

● Details of your visits to the Site, the resources and pages that you access (“Technical Information”).

4. Cookies

● A cookie is a piece of data stored locally on your computer and contains information about your activities on the Internet. The information in a cookie does not contain any personally identifiable information you submit to our Site.

● On our Site, we may use cookies to track users’ progress, allowing us to make improvements based on usage data. A cookie helps you get the best out of the Site and helps us to provide you with a more customized service.

● Once you close your browser, our access to the cookie terminates. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. To change your browser settings, you should go to your advanced preferences.

● We are required to obtain your consent to use cookies.

● If you choose not to accept the cookies, this will not affect your access to the majority of information available on our Site. However, you will not be able to make full use of our online services.

5. Data Retention

Our current data retention policy is to delete or destroy (to the extent we are able to) the personal data we hold about you in accordance with the following:

● Personal data held on marketing or business development records - for the time it is needed by you and us for business purposes

● For any category of personal data not specifically defined in this notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data or (if later) the end of the relevant contract, arrangement or interaction with that person.

● The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).

● If you wish to request that data we hold about you is amended or deleted, please refer to clause 9 below, which explains your privacy rights.

6. Sharing your information

6.1. We do not disclose any personal data you provide to any third parties other than as follows:

● We may host personal data (only Technical Information) with third party hosting partners;

● Certain third party suppliers including technical support providers may have access to personal data (only Technical Information);

● If we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);

Other than as set out above, we shall not disclose any of your personal information unless you give us permission to do so. If we do supply your personal information to a third party, we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.

7. Email and Other Communications

7.1. If you inquire for partnership or if you perform a test we may from time to time contact you about our products and services.

7.2. When we send email and other electronic communications we will comply with applicable regulations including the Privacy and Electronic Communications Regulations 2003. In particular, we will identify the nature of the message and the sender clearly and you will have an opportunity to refuse receiving any further communications from us.

8. Security

8.1. We will take all reasonable steps to ensure that appropriate organizational measures are conducted in order to safeguard the information we collect from you.

8.2. We will ensure that our employees are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees of third parties working on our behalf are aware of their privacy and data security obligations.

8.3. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site. Once we have received your information, we will use the procedures and security features referred to in this notice to try to prevent unauthorized access.

9. Your privacy rights

9.1. All subject access requests and other requests or notifications in respect of your personal data rights must be sent to us in writing to The Upstreamers, Bulgaria, Sofia, Hristo Belchev 23 str, Email: i.ivanova@hubahead.com

9.2. We will endeavor to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).

10. Notification of changes to the contents of this notice

We will post details of any changes to our policy on the Site to help ensure you are always aware of the information we collect, how we use it, and in what circumstances, if any, we share it with other parties.

11. Contact us

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so via the following email address: The Upstreamers, Bulgaria, Sofia, Hristo Belchev 23 str, Email: i.ivanova@hubahead.com

This Private Policy has been accepted by The Upstreamers; the present edition is finally updated at 27th of March 2023