This Privacy Policy is based on article 13 of the General Data Protection Regulation and contains the rights and obligations of the undertaking regarding the external parties whose personal data is processed, mainly in the context of online sales and marketing of goods and services.
This is the Privacy and Cookie Policy of Upperstage Eng Ltd, with registered offices in Nicosia, Cyprus and registered at the Cyprus Registrar of Companies with number HEΗΕ 155422 (hereinafter “COMPANY” or “UPPERSTAGE”).
Please read this Privacy Policy carefully, because it contains essential information about how your personal data is processed and which cookies are used. By using the website, accessible through the following link https://albumselection.com (hereinafter: “the Website”); by contacting us by mail/phone, by subscribing for our newsletter, you declare that you have read this Privacy Policy and that you expressly agree to its content as well as to the processing itself.
1.1 UPPERSTAGE is compliant and further complies with this Privacy Policy to the European Regulation 2016/679 of 27 April 2016 on the protection of personal data. (hereinafter “GDPR”).
1.2 UPPERSTAGE is the data controller who determines the purposes and the means of the processing.
2.1. In the context of its activities, UPPERSTAGE processes (collects, stores, uses) your Personal Data. This concerns:
Category 1 - based on cookies: your IP address, the browser type and version and details about your visit to our Website such as: (surfing behaviour, the data and time you visit the website, the amount of time spent using the website, the number of times you visit the website);
Category 2 - on visiting the Website and using our services: your IP address, your date of birth (age 18+), your activity on our site, browser type and version, time zone and language setting and location;
Category 3 - by registration or through one of the forms on our Website: your name, date of birth, address, e-mail address, IP address, profile name, password, login details and (if applicable) your profile picture;
Category 4 - when subscribing to our newsletter: your email address;
Category 5 - when purchasing a service: your name, date of birth, email address;
Category 6 - when using our Website and services: special category of data: sexual orientation or preferences.
2.2. UPPERSTAGE can obtain your personal data through different means:
a. by visiting the website without
logging in or registering and using our services;
b. by registration on the Website (creating an account)
or one of the forms on our Website;
c. by placing cookies and similar technologies on your device.
More information on the use of cookies and similar techniques can be found in article 9.
3.1. General purposes:
UPPERSTAGE will use the obtained personal data solely for the purposes mentioned below:
Category 1: to maintain and improve our Website and the inclusion of Personal Data in anonymous statistics, from which the identity of the specific person cannot be traced, with your explicit, prior consent on your first visit to our Website as a lawful ground;
Category 2: to verify your age (18+) and present our Website and its content to you, to provide information to you, services that you request, based on the legal obligation and performance of a contract requested by you;
Category 3: to manage your account on our Website, based on the performance of a contract requested by you;
Category 3 and 4: direct marketing, newsletters, promotions and offers by UPPERSTAGE itself, on the basis of our legitimate interest with regard to existing customers or your explicit, prior consent if you are not yet a customer of UPPERSTAGE. You can indicate at any time that you no longer wish to receive our newsletters through the opt-out option in our newsletters or by contacting us directly by mail or telephone;
Category 5: to deliver and invoice services ordered by you, with the performance of a contract that you have requested as a lawful ground and for which the processing of your Personal Data is necessary based on a legal obligation or based on the legitimate interest of UPPERSTAGE;
Category 6: to provide some of our services to you only when you have given your prior explicit consent. Sexual preferences belong to sensitive data for which we maintain high technology security standards.
You are not obliged to provide us with your personal data, however you must understand that the delivery of certain services is not possible in case you refuse to provide us with certain personal data.
On rare occasions, UPPERSTAGE may be required to disclose your Personal Data in order to comply with a court order or other mandatory laws or regulations. UPPERSTAGE will reasonably endeavour to inform you of this in advance, unless it is subject to legal restrictions.
In case of whole or partial reorganization or cession of UPPERSTAGE’s activities, whereby UPPERSTAGE reorganizes, transfers, ceases her business activity or in case the enterprise goes bankrupt, your personal data may be transferred to new entities or third parties.
UPPERSTAGE will try, if reasonably possible, to inform you upfront in case it transfers your personal data to a third person. You must be aware that this is not always technically possible nor commercially.
UPPERSTAGE will not sell, retain, hand out your personal data nor place them at disposal of third parties, except in the situations provided for in this policy or unless your explicit and prior consent.
UPPERSTAGE may transfer or disclose personal data to its employees, independent contractors and to countries outside the European Economic Area. We will ensure that the information transferred is in accordance with this privacy policy. The independent contractors are certified by the EU-US Privacy Shield (Digitalocean, Amazon AWS).
We will store and process your personal data during the period necessary depending on the purposes of the processing as well as depending on the contractual relationship between you and UPPERSTAGE. At any time you can request UPPERSTAGE to delete your personal data.
Your personal data will be stored and processed for the use of our services and the maintenance of your customer account. If you delete your account, some data will be stored to comply with legal obligations such as information for tax, accounting and auditing obligations. Financial information shall be kept for a period of 10 years.
Sensitive data will only be retained 1 month after your last visit to the Website.
If you have a question about the retention period of personal data, you can contact us through several ways (see article 6.6. privacy policy).
6.1. Access right and right to obtain a copy:
You have the right to freely obtain at any moment access to your personal data, as well as to be informed about the purpose of the processing by UPPERSTAGE.
6.2. Right to correct, delete and restrict:
You have the choice to share your personal data with UPPERSTAGE. You also have the right to request UPPERSTAGE to correct, delete or complement your personal data. You acknowledge that a refusal to share data or a request to delete these data will make the delivery of certain services and/or products impossible.
You can also request the processing of your personal data to be restricted.
6.3. Right to object:
You have the right to object to the processing of your personal data at any time when you have serious and legitimate reasons to do so.
You also have the right to object at any time to the use of your personal data for direct marketing purposes. In such case specific reasoning will not be required.
6.4. Right to data portability:
You have the right to receive your personal data, which you have provided to the controller, in a structured, commonly used and machine-readable format and/or have the right to transfer this data to another data controller.
6.5. Right to withdraw consent
When the processing is based on prior consent, you have the right to withdraw this consent.
6.6. Exercise of rights:
You can exercise your rights by contacting us by email support@albumselection.com or through the button ‘Contact us’ on the Website, with inclusion of your ID.
6.7. Automated decision-making and profiling:
You shall have the right not to be subject to a decision based solely on automated processing of your personal data, including profiling.
6.8. Right to file a complaint:
You have the right to file a complaint with the Office of the Commisioner for Personal Data Protection
P.O.Box 23378, 1682 Nicosia, Cyprus Tel Tel: +357 22818456 Fax Fax: +357 22304565
This does not affect a provision before the civil court. If you have suffered damages caused by the processing of your personal data you can file a claim for damages.
7.1. We have adopted safety measures which are suited on both a technical and an organizational level to avoid the destruction, the loss, the forgery, the adjustment, the non-authorized access or the notification of the personal data by accident to a third party, as well as the non-authorized processing of these data.
7.2. UPPERSTAGE shall not be liable in any way for direct or indirect damages caused by a wrongful or improper use of the personal data by a third party.
7.3. At all times you shall comply with safety standards, for instance by avoiding all non-authorized access to your login and access code. You are solely responsible for the use of the Website on your computer, IP-address and identification data, as well as for the confidentiality.
8.1. In order to process your personal data we provide access to your personal data to our employees and individual contractors, such as DigitalOcean, Amazon AWS, Cloudflare CDN, Zendesk.
8.2. We guarantee a similar level of protection by imposing contractual obligations to our employees that are similar to this Privacy Policy.
Our Website uses cookies and similar technologies. This helps us to provide you with a better user experience when you visit our Website and also allows us to optimize our Website. Without your prior consent, we only place the purely functional cookies that are necessary for our Website to function correctly. For all other cookies, we first ask for your consent.
If you discover that other cookies are placed through our Website, we thank you to notify us immediately so that we can make the necessary changes.
We give you as much information as possible about cookies placed by third parties. However, if you would like to know more, please refer to the privacy statements of these parties on their respective websites. Please note that we have no influence on the content of those statements, nor on the content of the cookies of these third parties.
On your first visit to our Website, you will be asked to accept our cookies. You can then manage your choices yourself at any time.
In case you have any more questions or remarks regarding the processing of personal data, please contact us per email support@albumselection.com or by using the “Contact us” button on the Website.
More information on cookies can also be found via the following link: http://www.allaboutcookies.org/.
More information on online behavioral advertising and online privacy can be found via the following link: http://www.youronlinechoices.eu/.