UPHOOM’s PRIVACY AND COOKIES POLICY

Last updated: September 19th, 2023

This Privacy Policy (“Policy”) elucidates how UPHOOME LLP., operating as “UPHOOME,” gathers, utilizes, shares, and processes your Personal Data in the context of your usage or access to this website (collectively, the “Site”) or the utilization of any of our services, including communication platforms, and any other associated services owned by us (collectively referred to as the “Services”). The Policy also delineates your rights pertaining to your personal data and provides information on how you can contact us to obtain further insight into our data practices or to exercise your rights.

UPHOOME LLP. employs the Site sells products offered therein and located at 28 City Road, London, United Kingdom, EC1V 2NX. Therefore, UPHOOME LLP. serves as the controller responsible for your personal data, encompassing its processing and protection. In this Policy, the terms “UPHOOME,” “Company,” “we,” “us,” or “our” denote UPHOOME LLP.

Before accessing or utilizing our Services, we kindly urge you to carefully review our Terms and Conditions and this Policy. If you are unable to agree with either this Policy or the Terms and Conditions, we respectfully request that you refrain from accessing or using our Services.

We hold your privacy in high regard and are dedicated to preserving the security of your personal data. This Privacy Policy also articulates your rights in regard to your personal information and offers guidance on how you can reach out to us for further details regarding our data practices or to exercise your rights.

Periodically, we may amend this Privacy Policy to mirror alterations in our data processing procedures. In cases where substantial changes impact your privacy rights, we will provide advance notice and make these modifications conspicuous on our website or through alternative communication channels, such as email. You will have the opportunity to review these changes before deciding whether to continue using our Services. Should you disagree with the revised Privacy Policy, we kindly ask that you discontinue your use of our Services.

Moreover, we may furnish real-time disclosures or supplemental information concerning specific facets of our data handling practices within specific areas of our Services. These notifications may supplement this Policy or offer you additional choices related to the processing of your personal information.

We sincerely appreciate your trust in UPHOOME with your personal data and thank you for taking the time to peruse our Privacy Policy. Your privacy is of utmost importance to us.

What Personal Information We Collect and How We Use It

We hold a strong commitment to safeguarding the privacy of visitors to our digital properties and users of our products and services, and we are dedicated to upholding this commitment through our adherence to this Policy. When you make use of our Services, we gather personal information. In accordance with the EU General Data Protection Regulation, the Data Protection Act 2018, and the United Kingdom General Data Protection Regulation (collectively referred to as “GDPR” within the context of this Privacy Policy), personal information mentioned in this Policy is referred to as “personal data” as defined in the GDPR. Throughout this Policy, the terms “personal data” and “personal information” may be used interchangeably. For individuals residing in the EU or the United Kingdom, “personal data” pertains to any information that, either on its own or in conjunction with other data, serves to identify or render an individual identifiable. It is important to note that personal information does not encompass data that has been irrevocably anonymized or aggregated to the extent that it can no longer be employed by us or any other party, either individually or when combined with other data, to identify you.

The specific kinds of personal information we collect from you are contingent upon your interactions with our Site and utilization of our Services. When we mention “personal information,” we are referring to data that can identify, be related to, describe, or be associated with you. Below are the sections that delineate the categories and precise types of personal information we gather:

1. Purpose: Account Creation and Management
– Information Collected: To facilitate the creation and management of your account, as well as to provide our Services, we collect contact information, which includes your email address and password, used for registration on our website.

2. Purpose: Order Fulfillment and Loyalty Program Management
– Information Collected: For the purpose of processing and managing orders, along with overseeing our loyalty program, we collect:

- - Identity and contact information, such as your name, phone number, and shipping address.
  - Financial information or payment account details for various operations, including delivery, returns, refunds, sales tax calculations, and payment processing.
  - Transaction specifics, including return and refund particulars, gift card numbers, and order history within our Services. This information is utilized to execute essential functions, such as processing payment and return requests, as well as providing you with updates on order status and shipping logistics.
  - Location data at an IP address-based level, which allows us to tailor your experience by displaying the appropriate local website, language preferences, or user interface.

3. Purpose: Customer Service and Support, Service-Related Communications
– Information Collected: For the provision of customer service and support, as well as to deliver service-related communications, we collect the following:

- - Photographs that you upload to our Services, as per our Terms and Conditions. These photos are used to offer product advice and enable you to voluntarily showcase to potential customers how items may appear when purchased or worn.
  - Records of your communication history with us through various channels, including email, social media, instant chat, and our customer service platform. These records are utilized to address your inquiries and keep you informed about your account and the Services.

4. Purpose: Marketing, Advertising, and Promotional Activities
– Information Collected: For marketing, advertising, and other promotional endeavors, we collect:

- - Contact information such as phone numbers and email addresses for telemarketing and email marketing purposes. You can opt out of receiving our marketing emails by using the unsubscribe link provided at the bottom of any of our emails or by contacting us at customercare@uphoome.com.
  - Non-directly identifiable device identifiers, operating system details, and cookie information. This information is used for the purpose of directing and evaluating the effectiveness of the advertising we offer.
  - Data pertaining to your interactions with our Services, including browsing activities, adding items to your shopping cart, saving products, placing orders, and making returns. We use this data for market research, statistical analysis, and the display of personalized advertising, which is tailored to your on-site activities and inferred interests.
  - Contact and identity details, such as names, email addresses, and phone numbers, when you voluntarily participate in competitions, market surveys, events, or other marketing campaigns organized by us.
  - Your consent to share your personal data with third-party advertisers.
  - Postal addresses for sending advertising gifts via traditional mail to the addresses of individual customers who have previously made purchases on the website. Please note that no advertising materials will be sent to individuals who are included in national lists of Objections or Mailing Preference Services. These lists will be reviewed and updated in accordance with applicable national legal requirements.

5. Purpose: Product/Service Enhancement and Personalization
– Information Collected: For the purpose of enhancing our product or service and providing personalization, we collect the following:

- - Your device information and usage data on our website, which is used for fault analysis, troubleshooting, system maintenance, and configuring default preferences such as language and currency settings.
  - When you choose to provide such data voluntarily, we may collect general personal information that does not personally identify you. This includes details like wrist size, finger size, and preferences regarding jewelry colors. Such information is employed to make recommendations on jewelry sizes, styles, and personalization, as well as to offer fit prediction services.
  - Sharing your personal data within and across our corporate organization to fulfill business needs and enhance personalization.
  - Recording your “like” records and votes when prompted to express your preference between two items, enabling us to provide preference setting options.
  - Displaying information that you opt to post in public areas of our Services, such as customer reviews.
  - Collecting your approximate or precise location data, based on factors such as your IP address, granted location permissions in your browser, or provided addresses. This information is used to offer location or delivery-related personalization and recommendation features. You can update your Location Services settings directly in your browser.

6. Purpose: Fraud Prevention and Investigation
– Information Collected: To prevent and investigate fraud and other illegal activities, we gather:

- - Information automatically collected through the Services, including browser type, device details, operating system, and account settings. This data is used for fraud prevention, detection, and reducing credit risks.
  - Log-in data for risk management and reporting of fraudulent activities.
  - Billing addresses to verify payment information.

7. Purpose: Legal and Compliance Requirements
– Information Collected: To comply with legal or regulatory requirements, we collect:

- - Identity information, such as ID- or passport-related details, for customs clearance purposes.
  - Transaction history and specific identity information for the resolution of legal disputes, regulatory investigations, and compliance with lawful requests from competent law enforcement agencies or courts.

8. Other Purposes
– We may utilize your information for any other purpose previously disclosed to you before you provide us with your personal information or which is reasonably necessary to deliver the Services or other related products/services as requested, subject to your permission or direction.

Our communications are crafted to inform you about the advantages we can provide, granting you access to our finest offers. We leverage the information we possess about you to customize the content and strive to ensure that the offers remain highly pertinent to your interests. It’s important to note that, under Data Protection Legislation, this practice could be categorized as profiling. If you prefer that we do not utilize your data for this purpose, please get in touch with us at customercare@uphoome.com.

Please be aware that when you engage with us via email or through forms on our Services, or when you publicly share content via our Services, we kindly request that you refrain from transmitting any sensitive information related to yourself or others. We neither collect nor store sensitive information or special categories of data.

Information collected from Affiliates

When an Affiliate signs up to join a program, we collect some information to inform merchants such as email, personal information, payment details and social network information. The information would help UPHOOME evaluate affiliate background and potential, along with process specific activities within the site and contact affiliates if needed.

Sharing Your Personal Information

We may disclose and share your personal information with the following parties as outlined below:

1- Within Our Organization: Our company is part of a corporate structure encompassing various legal entities, business processes, management systems, and technical platforms. To maintain business operations and ensure continuity of personalization, we may share your personal information with our affiliated group companies and, on occasion, other entities within our corporate group. This is done in pursuit of our legitimate interests, such as providing you with a personalized user experience across our digital platforms, delivering Services, and fulfilling actions based on your requests or preferences.

2- Service Providers: We may share your personal information with the following categories of third-party service providers:

- - IT system and software service providers: These include providers of website hosting services (including cloud storage), mobile app or software optimization services, customer relationship management software, email service providers, and system maintenance services.
  - Payment service providers: Third-party services responsible for processing payments.
  - Marketing and advertising services: Entities that assist in reaching potential new customers through various communication channels, as well as affiliated companies that promote our products on their websites
  - Order fulfillment service providers: Providers of logistics, warehousing, distribution, return and exchange services, and order status notifications for your purchased items.
  - Customer service providers: Entities that aid in customer service and support.

We strive to ensure that our third-party service providers can only use your data for the contractual purposes for which it was provided to them and to the extent necessary for such purposes, in accordance with our written instructions (where they act as our data processors).

3- To Ensure Legal and Regulatory Compliance: We reserve the right to disclose your personal information when necessary to fulfill a legal obligation or when we have a reasonable belief that disclosure is essential to safeguard our rights, comply with a judicial proceeding, adhere to a court order, respond to a regulator’s request, or address any other legal process served upon us. Additionally, we may make such disclosures if we reasonably believe that it is essential to enforce our agreements or policies or if we believe that disclosure will contribute to the protection of the rights, property, or safety of the Company or our customers.

4- Co-Branded Services and Features: Some portions of our Services may be presented as part of co-branded services and features. If you voluntarily utilize or participate in a co-branded service or feature, we will share your personal information with our co-branded partners. The co-branded partners will be clearly identified in connection with the co-branded feature or service, along with the respective co-branded partner’s privacy policy. Any use of your personal information by a co-branded partner will be subject to that partner’s privacy policy. If you desire to opt out of any future use of your personal information by a co-branded partner, you must directly contact the co-branded partner.

5- Consent: We may disclose your personal information for any purpose with your explicit consent.

6- Company Transactions: In the event of a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether in the form of a going concern or as part of bankruptcy, liquidation, or a similar proceeding, we may disclose personal information, including account details, Wallet balance, or points information, to a buyer, potential buyer, corporate affiliate, or other successor. This disclosure aligns with our legitimate interests and the necessity to facilitate corporate transactions. By using our Services, you acknowledge and consent to our assignment or transfer of rights pertaining to your personal information.

Please be aware that we may disclose aggregated or anonymized information about our Services’ users without any limitations. Such information is presented in a manner that does not identify any specific individual.

Cookies, Interest-Based Advertising, Ad Choices

1- Cookies: Cookies are small web files that a site or its provider transfers to your device’s hard drive via your web browser, allowing the site or provider to recognize your browser and retain specific information. We typically employ both first-party and third-party cookies for various purposes on our Services, which include:

- - Ensuring Proper Functionality: Strictly Necessary Cookies are crucial as they enable you to use our Services. For instance, they grant access to secure areas on our platform. These cookies are essential for the proper functioning of our Services and cannot be disabled. They do not gather information for marketing purposes.
  - Enhancing User Experience: Functional Cookies help us remember your choices, enabling us to customize our Services with enhanced features and personalized content. For example, they can retain your name or preferences on our platform. We do not utilize functional cookies for targeting you with online marketing. While you can disable these cookies, it may reduce functionality during your use of our Services.
  - Analyzing Performance: Performance or Analytic Cookies collect passive data on your interaction with our Services, including the webpages you visit and links you click. This information aids us in improving and optimizing our Services. We do not employ these cookies for online marketing purposes, and they can be disabled.
  - Targeted Advertising: Advertising or Targeting Cookies serve to make advertising messages more relevant to you. They perform functions such as preventing the same ad from repeatedly displaying, ensuring proper ad presentation for advertisers, and, in some cases, selecting ads based on your interests. Our third-party advertising partners may use these cookies to create a profile of your interests and deliver relevant ads on other sites. You have the option to disable these cookies. Please be aware that you can manage your cookie preferences, including disabling specific types of cookies, as outlined below.

2- Your Choices: Your web browser may offer you the ability to reject certain or all browser cookies and even delete cookies from your browser. To manage your preferences concerning cookies utilized on our Services, please follow the steps outlined below:

- - For First-Party Cookies: You can use the browser through which you are accessing this Site to enable, disable, or delete cookies. To do this, refer to the instructions provided by your browser, typically found within the “Help,” “Tools,” or “Edit” settings. It’s important to note that if you choose to disable cookies in your browser settings, you might lose access to secure areas of the Site, and certain parts of the Services may not function correctly. You can discover more details on adjusting your browser’s cookie settings at https://www.allaboutcookies.org
  - For Third-Party Cookies: If you want to opt in or out of third-party advertising networks and similar entities that utilize advertising cookies, please access the “Manage Cookies” link located in the footer of our website or visit https://www.aboutads.info/choices. For additional information about third-party advertising networks and similar entities employing these technologies, kindly review https://www.aboutads.info/consumers. You retain the option to withdraw your consent or modify your preferences at any time by clicking the “Manage Cookies” link within the Site footer or the App menu. Residents of the European Union and the U.K. can also opt out of online behavioral advertising provided by member organizations of the European Interactive Digital Advertising Alliance by visiting https://www.youronlinechoices.eu.

We do not have control over the collection or utilization of your information by third parties for the purpose of serving interest-based advertising. However, these third parties might offer you options to decline the collection or usage of your information in this manner. Furthermore, most web browsers provide support pages that address how to configure your cookie preferences. Additional details can be found for the following browsers at the provided links:

– Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB
– Internet Explorer: https://support.microsoft.com/en-us/help/260971/description-of-cookies
– Mozilla Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
– Safari (Desktop): https://support.apple.com/en-us/HT201265
– Safari (Mobile): https://support.apple.com/en-us/HT201265
– Android Browser: https://support.google.com/nexus/answer/54068?visit_id=637188034605491433-3067478416&hl=en&rd=1
– Opera Mobile: https://help.opera.com/en/mobile/android/

3- Web Pixels: To assess the effectiveness of our marketing campaigns and the achievement of other objectives for our Services, we occasionally employ conversion pixels. These pixels consist of a brief line of code that informs us when you click on a specific button or reach a particular webpage (e.g., a thank you page after subscribing to one of our services or completing a form). Web pixels are also utilized to analyze usage patterns on our Services. The use of pixels enables us to record that a particular device, browser, or application has visited a specific webpage.

4- Analytics: We may enlist the services of third-party providers to track and analyze the usage of our Services. At present, we utilize Google Analytics for this purpose. Google Analytics is a web analytics service that tracks and reports on Site traffic. For more details regarding Google’s privacy practices, please refer to the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. Google Analytics offers an Opt-out Browser Add-on that allows visitors to prevent the collection and utilization of their data by Google Analytics, accessible at: https://tools.google.com/dlpage/gaoptout. If Google Analytics is structured to collect personal data, the cookie banner on our Site will provide you with the option to consent to Google Analytics, and Google Ireland Ltd. will be the data controller, located at Gordon House, Barrow Street, Dublin 4, Ireland. We have implemented Google Analytics with the “AnonymizeIP” function, which ensures that your IP address is truncated before being sent to servers in the U.S. In rare cases, this truncation may occur after the transfer to the U.S. Google employs this data to assess your use of our Services, generate reports on activities within our online services, and provide us with other services related to the Site, App, and internet usage.

5- Behavioral Remarketing: We utilize remarketing services to display ads to you on third-party websites after you’ve visited our Services. To achieve this, we group visitors based on their actions on our Services, such as the duration of their visits. This allows us to understand your preferences and deliver personalized advertising even while you’re browsing other websites within the Google advertising network. We employ the following tools and services for this purpose:

- Google Ads Remarketing Service, provided by Google. You can opt out of this by visiting the Google Ads Settings page: https://www.google.com/settings/ads. If Google Ads collects personal data, Google Ireland Ltd., located at Gordon House, Barrow Street, Dublin 4, Ireland, will be the data controller.
- Bing Ads, a service operated by Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. Please refer to Microsoft’s privacy statement for more details on how Microsoft processes your information: https://privacy.microsoft.com/en-US/. When you access our Site via Bing Ads advertisements, a cookie is placed on your computer, and a Universal Event Tracking tag is integrated into our Site. This tag, combined with the cookie, stores data about your Site usage, such as the duration of your visit, accessed areas, and the ads that led you to the Site. Additionally, Microsoft may track your usage across multiple electronic devices through cross-device tracking. The collected information is transmitted to a Microsoft server in the United States. If Bing Ads collects personal data, our Services’ cookie banner will offer you the option to consent to Bing Ads.
- Facebook Ads: Using Facebook Business Tools, we may display interest-based ads to you on Facebook. You can modify your preferences or disable ad personalization for ads served by Facebook by visiting Facebook’s Ad Preferences, in addition to the Your Choices section below. We do not share your personal information with Facebook. We may also show ads to audiences with similar characteristics as yours. To accomplish this, a list of email addresses is encrypted and hashed, then uploaded or transmitted from our site. Facebook matches the hashed data against its own users, creating a lookalike audience and deleting the uploaded list. We do not have access to the identity of individuals in the “lookalike” audience unless they choose to interact with our ads.
- Other Tracking Technologies: We may also employ Tracking Technologies to collect “clickstream” data, such as your Internet access service’s domain name, device type, IP address used for internet connection, browser type and version, operating system and platform, average time spent on our Site, web pages visited, content searched for, access times, and other relevant statistics. We may also assign unique identifiers to the device or other credentials you use to access the Site for the same purposes. Our Site may utilize Java scripts, which are code snippets embedded in various parts of websites and applications to facilitate various operations, including accelerating the refresh speed of specific functionality or monitoring the usage of different online components. We also employ entity tags, which are HTTP code mechanisms enabling parts of websites to be stored or “cached” within your browser to enhance website performance. Additionally, we use HTML5 local storage to store and retrieve data within your browser to improve data retrieval on HTML5 pages when revisiting a website.
- Do Not Track: Some internet browsers, such as Internet Explorer, Firefox, and Safari, offer the option to transmit “Do Not Track” or “DNT” signals. As uniform standards for “DNT” signals have not been universally adopted, our Site currently does not process or respond to “DNT” signals.
- Location Information: You can adjust your device settings to prevent the transmission of information about your physical location to us or third parties by (a) disabling location services within your device settings or (b) denying certain websites permission to access location information by modifying relevant preferences and permissions in your browser settings.

Keeping your Information Safe

To bolster the security of your information, we have implemented an SSL certificate. It’s essential to recognize that, despite our diligent efforts to maintain a secure online environment, the internet inherently carries certain risks. For an additional layer of security, we strongly advise the following:

Employ a secure method to create a strong password and regularly update it.
Refrain from sharing your password with others.
Always log out of the website, particularly when using a shared computer.
Avoid using identical passwords across various websites or applications, as this practice can heighten the risk of falling victim to credential stuffing attacks and other malicious cyber activities.
Maintain the security of your devices by using the latest operating system version and installing necessary anti-virus software.
Exercise caution when dealing with potentially fraudulent emails that may appear to originate from us. Authentic emails from us will have email addresses ending in ‘@uphoome.com’.

If you suspect any compromise of your account’s security or personal data, please promptly reach out to us at customercare@uphoome.com. Your vigilance plays a pivotal role in safeguarding your information.

Your Rights to the Information We Hold

We place utmost importance on your awareness of personal information and are dedicated to safeguarding your rights, including the rights to access, rectify, delete, cancel your account, and withdraw your consent to the processing of your personal data. Our aim is to empower you with full control over your privacy and security.

1. Access, Rectification, Portability, and Deletion of Your Personal Information: You have the right to rectify or update your personal data, object to the processing of your personal data, request us to limit the processing of your personal data, or seek the portability of your personal data. To ensure the privacy and security of your personal data, we may require additional information from you to verify your identity and your entitlement to access such data. This process enables us to locate and furnish you with the personal data we maintain upon your request.

Please be aware that in certain cases, applicable laws or regulatory requirements may grant us the authority or mandate us to decline the provision or deletion of some or all of the personal information in our possession.

To exercise these rights, kindly reach out to us at customercare@uphoome.com. Should you choose to discontinue your association with us or cease using our services, you can request the closure of your account and the deletion of all personal information.

2. Withdrawal of Consent: You possess the right to withdraw your consent for the processing of your personal data, as well as the right to access, correct, or delete the personal information we collect, subject to specific exceptions.

Please note that there may be circumstances where applicable laws or regulatory obligations permit or necessitate us to refuse the provision or deletion of some or all of the personal information in our possession.

3. Unsubscribe from Our Marketing Communications: If you no longer wish to receive marketing emails or non-transactional promotional materials via your email account, you can simply click on the unsubscribe link provided at the bottom of any of our email messages to you. Alternatively, you may contact us at customercare@uphoome.com.

4. Lodging Complaints: If you believe that we have infringed upon or violated your privacy rights, we encourage you to get in touch with us at customercare@uphoome.com so that we may endeavor to address and resolve any concerns to your satisfaction. This does not preclude your right to lodge a claim or complaint with your local data protection authority, regardless of your place of residence. Further information about data protection authorities and their contact details can be found at https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en.

Kindly note that we may need to retain certain information for our own record-keeping and research purposes. Additionally, we may be required to send you service-related communications pertaining to your website user account, even if you have opted not to receive marketing communications.

Retention

We will keep your personal data, along with any communications exchanged with us, only for the duration required to fulfill the purposes outlined in this Policy. This includes retaining personal data to meet our legal responsibilities, settle disputes, ensure information security, and enforce our legal rights, terms, and policies.

Third-Party Websites

Our website may include links to third-party websites. Please note that this Privacy Policy does not extend to these third-party websites. We advise you to review the privacy policies of any other websites you visit, as we do not assume responsibility for the privacy practices employed by these external sites.

Children

Our Services are not intended for, and we do not knowingly collect personal information from, individuals under the age of 16 or minors (as defined by applicable law). If you are a minor, please refrain from completing our forms or submitting any personal information about yourself to us. In the event that a minor has furnished us with personal information without parental or guardian consent, we kindly request the parent or guardian to reach out to us at customercare@uphoome.com immediately for the removal of the relevant personal information and to unsubscribe the minor.

Upon becoming aware that a minor has provided us with personal information, we will take swift action to delete such data from our records. We also encourage you not to upload photographs featuring other individuals, especially minors.

Transfer of Your Personal Data

When you utilize our Services, it is possible that your personal data may be processed or transferred to destinations outside of the United Kingdom, including the United States and/or China. These countries or jurisdictions may have data protection regulations that provide less robust protection compared to the laws of your own jurisdiction.

For such transfers, we rely on appropriate safeguards as permitted under the GDPR, such as Standard Contractual Clauses. Alternatively, we may transfer personal information in accordance with Article 49 (1) (b) of the GDPR to fulfill our Services obligations as outlined in the Terms & Conditions. If you prefer that your information not be transferred, processed, or maintained outside of your home country or jurisdiction, we recommend discontinuing your access to or use of the Services. For additional information about these transfers and the protective measures we employ for such transfers, please feel free to reach out to us at customercare@uphoome.com.

Contact

Should you have any questions about our privacy practices or this Privacy Policy, or if you would like to exercise any of the rights available to you, please email us at customercare@uphoome.com