1. Introduction and general terms
This policy covers services are provided by Stay Upstream Limited (“Upstream”, “we”, “us” or “our” in this policy). Upstream’s business is to provide businesses with an online database of companies, together with their business contacts and other relevant information.
Stay Upstream Limited, 3.02 Clerkenwell Workshops, 27-31 Clerkenwell Close, London EC1R 0AT
Telephone: +44 (0)20 3861 4459
Upstream is registered with the Information Commissioners Office under registration reference ZA247174.
Upstream is committed to protecting and respecting your privacy. This policy explains the basis on which personal information we collect from you will be processed by us. Where we decide the purpose or means for which personal data supplied by you is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.
This policy explains the following:
- What personal information we may collect about you;
- Ground for processing;
- Who we share your information with;
- How we will use that information;
- Who we may disclose that information to; and
- Your rights regarding the information.
2. WHY WE COLLECT YOUR INFORMATION?We provide our clients (ie subscribers) with an online database of companies and associated contact details helping them connect and ultimately build relationships with businesses they are interested in working with in a more effective manner. You and others may post information about yourself online and we collect such publicly available information. If you are a contact in a business that we believe is likely to benefit from using services of our clients, we may collect and process personal data on you as part of efforts to sell, promote and market these services to you.
3. What information will UPSTREAM collect about me?
We collect and process the following information which may include your personal data.
The majority of the personal information we collect about you comes from publically available online information. This may include your name, gender, address, telephone number (direct and mobile), e-mail address, job title. We may also collect information on the phone or face to face.
All data collected and processed by Upstream is ‘corporate’ or ‘business to business’ data.
We may also collect technical information about your computer and/or device that may identify you, including your IP address and behaviour when you receiving emails (eg. whether you read the email, open it and forward it on to third recipients). We generally collect this from cookies.
4. GROUNDS OF PROCESSING
On some occasions, Upstream processes your data with your consent. 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.
- Legitimate interest
Generally, Upstream processes your personal information when it is our legitimate interest to do so and when these interests are not overridden by your data protection rights. As applicable, we will use information about you for delivering, selling and supplying our good and services to our customers, understanding our customers’ behaviour, activities, preferences, and needs, promoting, marketing and advertising our products and services, improving existing products and services and developing new products and services, responding to enquiries and contacting you about matters requiring your attention. We may use third parties to assist us with this.
- Necessary to fulfil a contract
Upstream may process your data when we need to do this to fulfil a contract with you.
- Necessary because of a legal obligation
Upstream may process your data to comply with our legal and regulatory obligations eg preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.
5. Data Sharing
We will share your information with the following:
- Our companies
Access to personal information within Upstream and our group of companies is restricted to those individuals who have a need to access the information for our business purposes.
- Suppliers, subcontractors
- Our service providers
This includes external third-party service providers, such as accountants, auditors, experts, lawyers and other outside professional advisors; IT systems, support and hosting service providers; technical engineers; data storage and cloud providers and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.
- Other third parties
We may share personal information with other third parties namely subscribers to our database. We do this because we believe that by doing so, you are more likely to receive relevant business introductions that will be of interest to you in a corporate capacity. This will ensure you are less likely to receive irrelevant introductions, sent in the wrong way at the wrong time.
We are committed to real transparency about this element of our data processing, so may speak to you about it on the phone or send you an email explaining/confirming that we are processing your personal data and it will be shared with third parties.
We are committed to giving you the opportunity to ask for us not to disclose your information to these third parties. If you object, please tell us on the phone, reply to an email we’ve sent you or write to us at the address above.
- Government authorities
In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
6. How we will use information we collect about you and who will we share it with
We will use information about you for delivering, selling and supplying our goods and services to our customers, understanding our customers’ behaviour, activities, preferences, and needs, promoting, marketing and advertising our products and services, improving existing products and services and developing new products and services, responding to enquiries and contacting you about matters requiring your attention. We may use third parties to assist us with this.
We process personal data to comply with our necessary legal and regulatory obligations. These include preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.
We use various forms of marketing to provide you with promotional materials about our services, as well as the services of other companies in our group of companies. We may use third-party providers to assist us with this.
We will not process your information for the purposes of marketing unless you give your consent or you have given it already.
We process information to understand how visitors use our website and to compile statistical reports regarding that activity.
For these activities, we use an online customer management system called Intercom. Please consult their privacy policies for more information at https://www.intercom.com/terms-and-policies#privacy.
This processing is necessary for us to pursue our legitimate interests of improving our services, and providing a better and more personalised experience to our users. We may use third party analytics providers.
7. Consumer Control & Opt-Out Options
If you do not wish to receive promotional or other marketing material from us please contact us using the above contact details.
8. Your rights in relation to personal data which we process relating to you
You have the following rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest.
To make a request, please contact us using the above contact details, addressed to the contact above.
Ask for a copy of data we are processing about you and have inaccuracies corrected
You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.
We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).
Object to us processing data about you
You can ask us to restrict, stop processing, or to delete your personal data if:
- you ask us to stop processing your information;
- you consented to Upstream processing the personal data, and have withdrawn that consent;
- Upstream no longer needs to process that personal data for the reason it was collected;
- Upstream is processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of Upstream, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;
- the personal data was unlawfully processed; or
- you need the personal data to be deleted in order to comply with a legal obligation.
Obtain a machine-readable copy of your personal data, which you can use with another service provider
- If we are processing data in order to perform our obligations to you, or because you consented, if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
- If you request, Upstream will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.
Make a complaint to a Supervisory Authority
- If you are unhappy with the way we are processing your personal data, please let us know.
If you do not agree with the way we have processed your data or responded to your concerns, you have the right to lodge a complaint with the Information Commissioner’s Office. Further information, including contact details, are available at https://ico.org.uk
9. Data Retention
We review the personal data that we store on a cycle of 90-120 days. If the data is still correct, we will keep it. If it is out of date, we will remove it.We typically retain your data for ten years from your last transaction with us to satisfy our regulatory obligations.Please note that Upstream reserves the right to remove from our database, and data which includes any content that we consider to be illegal or offensive.
We do not knowingly solicit data from or market to children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at the above details. We will delete such information from our files within a reasonable time.
Upstream 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 will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information.
Our security measures include:
- Hashing and encryption of our services and data;
- Regular review of information collection;
- Encryption of our services and data;
Restricted access of data to employees, contractors and agents; and internal policies setting out our data security. Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
We will notfiy you of any changes to this policy by email, notice on the website or account message.
13. International Data Transfers
Your Personal Information which you supply to us is generally stored and kept inside the European Economic Area, however due to the nature of our global business and the technologies required, your Personal Information may be transferred to third party service providers outside the EEA, in countries where there may be a lower legal level of data protection.
Last updated: May 2018