Owner and Data Controller
Up Gesundheit GmbH
Wurzner Str. 154a
04318 Leipzig
Germany
Data Protection Officer: Stanislaw Schmidt (interim)
Competent regulatory authority: Sächsische Datenschutzbeauftragte
Devrientstr. 5
01067 Dresden
post@sdtb.sachsen.de
Owner contact email: data-protection@upfit.io
Types of Data collected
Among the types of Personal Data that Upfit collects, by itself or through third parties, there are:
Usage Data; Trackers; phone number; Data communicated while using the service; gender; email address; username; password; billing address; language; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Read only access; various types of Data; first name; device information; device logs; app information; Universally unique identifier (UUID).
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Upfit.
Unless specified otherwise, all Data requested by Upfit is mandatory and failure to provide this Data may make it impossible for Upfit to provide its services. In cases where Upfit specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by Upfit or by the owners of third-party services used by Upfit serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through Upfit.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Upfit (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Hosting and backend infrastructure, Tag Management, Handling payments, Collection of privacy-related preferences, Handling activities related to productivity, Contacting the User, Managing data collection and online surveys, Registration and authentication provided directly by Upfit, Registration and authentication, Advertising, Analytics, Data transfer outside the EU, Backup saving and management, Displaying content from external platforms, Beta Testing, Connecting Data, Interaction with live chat platforms, Infrastructure monitoring, Remarketing and behavioural targeting, Managing contacts and sending messages, Interaction with data collection platforms and other third parties, Commercial affiliation and Platform services and hosting.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Advertising
This type of service allows User Data to be utilised for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on Upfit, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers for identifying Users, behavioural retargeting i.e. displaying ads tailored to the User’s interests and behaviour, or to measure ads performance. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Google Ads conversion tracking (Google Ireland Limited)
Google Ads conversion tracking is an analytics service provided by Google Ireland Limited that connects data from the Google Ads advertising network with actions performed on Upfit.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
belboon (belboon GmbH)
Belboon is an advertising service provided by belboon GmbH.
Personal Data processed: Trackers; Usage Data.
Place of processing: Germany – Privacy Policy.
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Analytics
The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.
Google Analytics 4 (Google Ireland Limited)
Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of Upfit, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Trackers.
Place of processing: Ireland – Privacy Policy – Opt Out.
Google Analytics Demographics and Interests reports (Google Ireland Limited)
Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for Upfit (demographics means age and gender Data).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Place of processing: Ireland – Privacy Policy – Opt Out.
Google Analytics for Firebase (Google Ireland Limited)
Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google Ireland Limited.
In order to understand Google's use of Data, consult Google's partner policy.
Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.
Upfit uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.
Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.
Personal Data processed: Trackers.
Place of processing: Ireland – Privacy Policy.
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Backup saving and management
This type of service allows the Owner to save and manage backups of Upfit on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to Upfit.
Backup on Google Drive (Google Ireland Limited)
Google Drive is a service to save and manage backups provided by Google Ireland Limited.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
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Beta Testing
This type of service makes it possible to manage User access to Upfit, or parts of it, for the purpose of testing a certain feature or the entire Application.
The service provider may automatically collect data related to crashes and statistics related to the User's use of Upfit in a personally identifiable form.
TestFlight (Apple Inc.)
TestFlight is a beta testing service provided by Apple Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Google Play Beta Testing (Google Ireland Limited)
Google Play Beta Testing is a beta testing service provided by Google Ireland Limited.
Personal Data processed: email address; Trackers; various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
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Collection of privacy-related preferences
This type of service allows Upfit to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.
iubenda Cookie Solution (iubenda srl)
The iubenda Cookie Solution allows the Owner to collect and store Users’ preferences related to the processing of personal information and in particular to the use of Cookies and other Trackers on Upfit.
Personal Data processed: Trackers.
Place of processing: Italy – Privacy Policy.
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Commercial affiliation
This type of service allows Upfit to display advertisements for third-party products or services. Ads can be displayed either as advertising links or as banners using various kinds of graphics.
Clicks on the icon or banner posted on the Application are tracked by the third-party services listed below, and are shared with Upfit.
For details of which data are collected, please refer to the privacy policy of each service.
Amazon Affiliation (Amazon Europe )
Amazon Affiliation is a commercial affiliation service provided by Amazon.com Inc.
Personal Data processed: Trackers; Usage Data.
Place of processing: Luxembourg – Privacy Policy.
Awin (AWIN AG)
Awin is a commercial affiliation service provided by AWIN AG.
Personal Data processed: Trackers; Usage Data.
Place of processing: Germany – Privacy Policy.
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Connecting Data
This type of service allows the Owner to connect Data with third-party services disclosed within this privacy policy.
This results in Data flowing through these services, potentially causing the retention of this Data.
Zapier (Zapier, Inc.)
Zapier is a workflow automation service provided by Zapier, Inc. that automates the movement of Data between (third-party) services.
Personal Data processed: Data communicated while using the service.
Place of processing: United States – Privacy Policy.
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Contacting the User
Phone contact (Upfit)
Users that provided their phone number might be contacted for commercial or promotional purposes related to Upfit, as well as for fulfilling support requests.
Personal Data processed: phone number.
Mailing list or newsletter (Upfit)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Upfit. Your email address might also be added to this list as a result of signing up to Upfit or after making a purchase.
Personal Data processed: email address; Trackers; Usage Data.
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Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of Upfit and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Google Maps widget (Google Ireland Limited)
Google Maps is a maps visualisation service provided by Google Ireland Limited that allows Upfit to incorporate content of this kind on its pages.
Personal Data processed: Trackers.
Place of processing: Ireland – Privacy Policy.
YouTube video widget (Privacy Enhanced Mode) (Google Ireland Limited)
YouTube is a video content visualisation service provided by Google Ireland Limited that allows Upfit to incorporate content of this kind on its pages.
This widget is set up in a way that ensures that YouTube won't store information and cookies about Users on Upfit unless they play the video.
Personal Data processed: Trackers; Universally unique identifier (UUID); Usage Data.
Place of processing: Ireland – Privacy Policy.
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Handling activities related to productivity
This type of service helps the Owner to manage tasks, collaboration and, in general, activities related to productivity. In using this type of service, Data of Users will be processed and may be retained, depending on the purpose of the activity in question.
These services may be integrated with a wide range of third-party services disclosed within this privacy policy to enable the Owner to import or export Data needed for the relative activity.
Google Workspace (Google Ireland Limited)
Google Workspace is an integrated suite of cloud-based productivity, collaboration and storage services provided by Google Ireland Limited. Gmail or other G Suite services are not scanned by Google for advertising purposes. In addition, Google does not collect or use data inside these services for advertising purposes in any other way.
Personal Data processed: Trackers.
Place of processing: Ireland – Privacy Policy.
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Handling payments
Unless otherwise specified, Upfit processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. Upfit isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
Stripe ( Stripe Technology Europe Ltd)
Stripe is a payment service provided by Stripe Technology Europe Ltd.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
PayPal (PayPal Inc.)
PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: See the PayPal privacy policy – Privacy Policy.
Klarna (Klarna AB)
Klarna is a payment service provided by Klarna AB.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Sweden – Privacy Policy.
Payments processed via the Apple App Store (Apple Inc.)
Upfit uses a payment service provided by Apple Inc. that allows the Owner to offer the purchase of the app itself or in-app purchases.
Personal Data processed to complete the purchases are processed by Apple, as described in the privacy policy for the App Store.
Personal Data processed: device information; email address; first name; Trackers.
Place of processing: United States – Privacy Policy.
Payments processed via the Google Play Store (Google Ireland Limited)
Upfit uses a payment service provided by Google Ireland Limited that allows the Owner to offer the purchase of the app itself or in-app purchases.
Personal Data processed to complete the purchases are processed by Google, as described in the privacy policy for the Google Play store.
Personal Data processed: device information; email address; first name; Trackers.
Place of processing: Ireland – Privacy Policy.
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Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable Upfit to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Upfit.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Amazon Web Services (AWS) (Amazon Web Services, Inc.)
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy; Germany – Privacy Policy.
Google BigQuery (Google Ireland Limited)
Google BigQuery is a hosting and backend service provided by Google Ireland Limited.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
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Infrastructure monitoring
This type of service allows Upfit to monitor the use and behaviour of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of Upfit.
Uptime Robot (Buzpark Bilisim Tarim Urunleri Sanayi Tic. Ltd. Sti.)
Uptime Robot is a monitoring service provided by Buzpark Bilisim Tarim Urunleri Sanayi Tic. Ltd. Sti.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Turkey – Privacy Policy.
Bugsnag (Bugsnag Inc.)
Bugsnag is a monitoring service provided by Bugsnag Inc.
Personal Data processed: app information; device logs; Trackers; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Datadog (Datadog, Inc.)
Datadog is a monitoring service provided by Datadog, Inc.
The way Datadog is integrated means that it filters all traffic of Upfit, i.e., communication between the Application and the User's browser or device, while also allowing analytical data on Upfit to be collected.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Germany – Privacy Policy.
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Interaction with data collection platforms and other third parties
This type of service allows Users to interact with data collection platforms or other services directly from the pages of Upfit for the purpose of saving and reusing data.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
Direct marketing via popups (Upfit)
Upfit uses popups to interact with the User to propose services and products which may be provided by third parties or that are unrelated to the product or services provided by Upfit.
Personal Data processed: Trackers.
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Interaction with live chat platforms
This type of service allows Users to interact with third-party live chat platforms directly from the pages of Upfit, in order to contact and be contacted by Upfit‘s support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.
Crisp Widget (Crisp IM SARL)
The Crisp Widget is a service for interacting with the Crisp live chat platform provided by Crisp IM SARL.
Personal Data processed: Data communicated while using the service; Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: France – Privacy Policy.
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Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
SendinBlue Email (SendinBlue SAS)
SendinBlue is an email address management and message sending service provided by SendinBlue SAS.
Personal Data processed: email address; Trackers; Usage Data.
Place of processing: France – Privacy Policy.
Mailgun (Mailgun Technologies, Inc.)
Mailgun is an email address management and message sending service provided by Mailgun Technologies, Inc.
Personal Data processed: email address; Trackers.
Place of processing: United States – Privacy Policy.
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Managing data collection and online surveys
This type of service allows Upfit to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.
These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.
Google Forms (Google Ireland Limited)
Google Forms is a form builder and data collection platform provided by Google Ireland Limited.
Personal Data processed: Data communicated while using the service.
Place of processing: Ireland – Privacy Policy.
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Platform services and hosting
These services have the purpose of hosting and running key components of Upfit, therefore allowing the provision of Upfit from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
App Store Connect (Apple Inc.)
Upfit is distributed on Apple's App Store, a platform for the distribution of mobile apps, provided by Apple Inc.
App Store Connect enables the Owner to manage Upfit on Apple's App Store. Depending on the configuration, App Store Connect provides the Owner with analytics data on user engagement and app discovery, marketing campaigns, sales, in-app purchases, and payments to measure the performance of Upfit.
App Store Connect only collects such data from Users who have agreed to share them with the Owner. Users may find more information on how to opt out via their device settings here.
Personal Data processed: Trackers.
Place of processing: United States – Privacy Policy.
Google Play Store (Google Ireland Limited)
Upfit is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google Ireland Limited.
By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis.
Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.
Personal Data processed: Usage Data.
Place of processing: Ireland – Privacy Policy.
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Registration and authentication
By registering or authenticating, Users allow Upfit to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, Upfit will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.
Sign in with Apple (Apple Inc.)
Sign in with Apple is a registration and authentication service provided by Apple Inc. In cases where Users are required to provide their email address, Sign in with Apple may generate a private relay address on behalf of Users that automatically forwards messages to their verified personal email account - therefore shielding their actual email address from the Owner.
Personal Data processed: email address.
Place of processing: United States – Privacy Policy.
Gmail permissions to access User Data (OAuth addition) (Google Ireland Limited)
To provide its service, Upfit uses restricted scopes for Gmail which allow access to User Data related to this Google service (as indicated below). This access is provided by Google Ireland Limited under strict terms. Here's what this means for such User Data:
- The use of User Data is limited to providing or improving User-facing features. User Data will not be used for serving ads, including retargeting, personalised, or interest-based advertising.
- User Data will be transferred to third parties only if necessary, to provide or improve User-facing features and as necessary to comply with applicable law or as part of a merger, acquisition, or sale of assets with notice to Users.
- Humans will not read the Data unless:
- the Owner has obtained the User's affirmative agreement for specific messages;
- it is necessary for security purposes and/or to comply with applicable law, or;
- the use is limited to internal operations and the Data (including derivations) have been aggregated and anonymised.
Personal Data processed: Read only access.
Place of processing: Ireland – Privacy Policy.
Google OAuth (Google Ireland Limited)
Google OAuth is a registration and authentication service provided by Google Ireland Limited and is connected to the Google network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
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Registration and authentication provided directly by Upfit
By registering or authenticating, Users allow Upfit to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.
Direct registration (Upfit)
The User registers by filling out the registration form and providing the Personal Data directly to Upfit.
Personal Data processed: billing address; email address; gender; language; password; Usage Data; username.
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Remarketing and behavioural targeting
This type of service allows Upfit and its partners to inform, optimise and serve advertising based on past use of Upfit by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioural targeting activity.
Some services offer a remarketing option based on email address lists.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Google Signals (Google Ireland Limited)
Upfit uses Google Signals, a feature of Google Analytics, which will associate the visitation information that it collects from Upfit with Google information from accounts of signed-in Google-account users who have consented to this association for the purpose of ads personalisation. This Google information may include User location, search history, YouTube history and Data from sites that partner with Google – and is used to provide aggregated and anonymised insights into Users' cross device behaviours.
If a User falls under the described association, they may access and/or delete such Data via My Activity provided by Google.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on Upfit in a centralised fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google Ireland Limited)
Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie
Policy.
Further information about the processing of Personal Data
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Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by Upfit depends on the payment system used.
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sessionStorage
sessionStorage allows Upfit to store and access data right in the User's browser. Data in sessionStorage is deleted automatically when the session ends (in other words, when the browser tab is closed).
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Equal protection of User Data
Upfit shares User Data only with third parties carefully selected to ensure that they provide the same or equal protection of User Data as stated in this privacy policy and requested by applicable data protection laws. Further information on data processing and privacy practices by third parties can be found in their respective privacy policies.
Cookie Policy
Upfit uses Trackers. To learn more, Users may consult the Cookie Policy.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or enquire with the Owner using the information provided in the contact section.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Transfer of Personal Data outside of the European Union
Data transfer abroad based on standard contractual clauses
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
Data transfer to countries that guarantee European standards
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission's website.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Upfit or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, Upfit may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, Upfit and any third-party services may collect files that record interaction with Upfit (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Upfit and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through Upfit (or third-party services employed in Upfit), which can include: the IP addresses or domain names of the computers utilised by the Users who use Upfit, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using Upfit who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Upfit. The Data Controller, unless otherwise specified, is the Owner of Upfit.
Upfit (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by Upfit as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Read only access
Read all resources and their metadata—no write operations.
Legal information
This privacy policy relates solely to Upfit, if not stated otherwise within this document.