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Privacy Notice EN English

Up.Direct Website Privacy Notice

This privacy notice is intended to provide you with information about how we process your personal data in our interactions with you. 

UP.Direct is a Data Controller and is part of Ultimate Products UK Limited, which is a company under the group Ultimate Products PLC (‘we’ or ‘us’ or ‘our’). 

If you have any concerns or outstanding questions after reviewing this statement, then we encourage you to contact us by Ultimate Products UK Limited, Compliance Department, Manor Mill, Victoria Street, Manchester, OL9 0DD. UNITED KINGDOM or emailing data-protection@upplc.com


Our Commitment to You

We are committed to protecting your personal data in line with the UK Data Protection Act (2018) and the UK GDPR. In doing so we will ensure that personal data is:

  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have told you about.
  • Kept securely.
We process personal data in several ways, and this privacy statement outlines what data we collect, why we collect it and how we treat it whilst we are holding it. Please review the section which details how we might interact with you.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • To object to the processing of your personal information if we are relying on a legitimate interest (whether ours or a third party’s) and you feel that your particular circumstances warrant such an objection. Additionally, you may object to the use of your personal information if it is being processed for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please write to us at the address below.

How we identify our lawful bases

We only use personal data where we have a lawful basis under UK data protection law. The lawful basis we rely on depends on the purpose for which we use the data.

Where we rely on legitimate interests, we have considered whether the processing is necessary and balanced our interests against your rights, freedoms and interests. Our legitimate interests may include: 

  • Operating and improving our website,
  • Responding to business enquiries, 
  • Preventing fraud, maintaining security, 
  • Improving customer service, 
  • Managing business accounts and promoting our products to business contacts where permitted by law.
Where we rely on consent, you can withdraw your consent at any time. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.

You are included in our marketing promotions

If you are an end consumer or sole trader, we may process personal information when you interact with our website, on social media or through marketing mailing campaigns. This may include:
  • Information such as your IP address may be collected, with your consent when you visit our websites. Your IP address is a unique identifier for your computer or other access device; this helps us to understand where customers originate from and helps us to understand where to focus our future product marketing.

This helps us to understand:

  • The country you access our website from
  • How you use our website including which products you view
You can find out more about the tracking that we might undertake by viewing our cookie policy on our website.

It may also include:

  • Social Media profile information including your content which contains our products and has been shared publicly by you
  • Contact information in relation to email based enquiries or in signing up to one of our mailing lists. This may include where you have provided information as part of a potential purchase.
  • Where you create an account on our website and provide us with information about yourself
  • If you contact us for any enquiry we may keep a record of that correspondence.
We also sometimes run competitions and/ or giveaways on these social media channels; however, we never take your personal data from these companies, except to send you prizes. You should be aware of the privacy notices of these social media channels to see how they manage your data.

Data Sharing:

To support these services, we may share your data with or receive data from selected third parties. Where we do, we ensure that we have legally binding arrangements with them which ensures that your personal data remains protected.

Where you add your personal data to social media or where we share your data with TrustPilot, please be aware that these companies will then become the controller of your data, and they will use your data according to the information they provide within their own Privacy Notices.

We may share your data for the following purposes:
  • Dot Digital and Yotpo who provide email marketing support. 
  • BOUTIQUE who provides support to our marketing team as a digital marketing agency.
  • Website analytics purposes to capture how you use and interact with our website, such as Google, Microsoft, and Facebook (and their affiliates) etc.

Lawful Basis & Retention Periods:

We may use your business contact details to send you information about our products, services, offers, events or updates where permitted by law.

For business contacts at corporate subscribers, such as limited companies or LLPs, we may send B2B marketing emails where PECR does not require prior consent. In those cases, our UK GDPR lawful basis is usually our legitimate interests in promoting our products and services to business contacts who may reasonably expect to hear from us in a business context.

For sole traders, certain partnerships, or where we are unsure whether the recipient is an end-consumer or business, we will only send electronic marketing where:

  • You have given consent
  • The soft opt-in applies
  • Another PECR-compliant route applies.
We will identify ourselves in our marketing communications and provide a clear way to unsubscribe or opt out. You can object to our use of your personal data for direct marketing at any time by using the unsubscribe link in our emails or by contacting data-protection@upplc.com. We will hold your data for marketing purposes when you have consented to us using your data for this purpose until you opt out. 

Where we process on the basis of Legitimate Interests, we conduct a Legitimate Interests test for necessity and balance against your rights and freedoms. 


You have completed a purchase

Once you have completed a purchase and depending on the circumstances, we may collect, store, and use the following categories of personal information about you:

  • Name/ Home information will be retained for the duration of the time that you hold an account with us, or for no longer than 12 months from your last order. This is necessary to enable payment, process refunds and help us monitor fraudulent activity on accounts.
  • Product Registration to ensure that any guarantees can be managed effectively (applicable to end-consumers only)
  • Images you may send us in managing any queries or for further internal investigations to improve customer satisfaction and product
  • Legal and Insurance data in the event of any claim
  • Any personal data you include in any product reviews you leave for us
  • Address - without this we won’t know where or whom to send your order to. We also use this information to identify whether we can deliver to you, at what cost and via which partner route.
  • Email – to send a confirmation of your orders via email, as well as other service-related communication and may also respond this way if you have a general enquiry. If you have agreed to receive marketing communications, these may also be sent by email.
  • Telephone Number(s) - if there are any problems with your order or anything needs to be checked, we need to be able to contact you as quickly as possible.
  • Financial Information – a payment card or a Paypal, Google Pay, Stripe or Klarna account is required in order to process your order. 
Depending on your purchasing activity, your information may be transferred from our external third party systems into our internal management platforms. Once this happens, your account may be reviewed to determine whether you meet the criteria for further support from our Sales team. Where appropriate, and following this assessment, a member of the Sales team may contact you. Please note that this evaluation is carried out on a case by case basis and does not guarantee that a dedicated Sales Representative will be assigned.

Further to this, when you create a company account with us, you may be assessed for credit suitability using the company details you have provided at sign up. Here, your business’ suitability will be checked with Allianz, a third party we utilise for financial and insurance protection services. If we deem your business suitable to receive credit, a member of our sales team will contact you to confirm your eligibility, credit amount, payment terms and financial information.

If you are a sole trader, some personal data may be utilised to complete this process. This data will only be used by our Accounts team and Allianz during the checking stage, and then our Sales team if you are deemed eligible for credit. No personal information outside of any provided at sign up will be utilised to conduct this assessment, and this data will be retained in our systems for as long as you have an active account with us. Our lawful basis for this activity is contractual obligation, as processing is necessary for the performance of a contract or to take steps at the request of the data subject before entering into a contract. This process is not applicable to end-consumers.

Data Sharing:

To support these services, we may share your data with or receive data from selected third parties. Where we do, we ensure that have legally binding arrangements with them which ensures that your personal data remains protected.
We may share your data for the following purposes:

  • Payment Gateway services e.g PayPal, Stripe or Klarna who process the payment services on our behalf. We do not have access to any of this data and the payment services providers are the controllers of your data in this instance
  • Product Fulfilment services for using our warehousing systems to ensure that product logistics are completed
  • Courier services to ensure your product is delivered to your chosen address
  • Customer Support and Management services
  • Product Review Sites (TrustPilot and Google Reviews)
  • Image recognition and language translation tools to support EU customer service operations
  • Webchat services
  • Financial and Insurance Services
  • Legal Services

Lawful Basis & Retention Periods:

We process your personal data in relation to a purchase or post-sale support in order to fulfil a contract with you.  

Some of these services which are not required to directly support the purchase (such as image, translation tools, webchat and insurance) are provided in our legitimate interest, to ensure that our customer service levels remain high. Where we process on the basis of Legitimate Interests, we conduct a Legitimate Interests test for necessity and balance against your rights and freedoms. 

We may obtain legal services to pursue or defend potential legal claims where necessary to meet our legal obligations.


You have purchased a product which records Health Data

Some products or customer service interactions may involve health-related information. Health data is special category data under UK data protection law and requires additional protection.

We do not actively seek health information unless it is necessary, such as:

  • Responding to a product query, 
  • Handling a return, 
  • Managing a safety issue, 
  • Supporting a legal claim
  • Third-party app providers where you choose to connect a product to an associated application.

Where a third-party app provider acts as an independent controller, its own privacy notice will explain how it processes your information.

If you provide health-related information to us, we will use it only for the relevant purpose and will apply additional safeguards, including restricted access, separate storage where appropriate and limited retention.

Our lawful basis under Article 6 UK GDPR is: legitimate interests, to provide a service and customer service support.

Our special category condition under Article 9 UK GDPR is: explicit consent which will be collected and stored by our customer service team and/or app developers where applicable. 

Where we rely on your explicit consent, you may withdraw that consent at any time by contacting us using the details provided in this notice. Withdrawal of consent will not affect the lawfulness of processing carried out before consent was withdrawn.

We do not use health-related information for marketing, profiling or automated decision making.

We will retain health-related information only for as long as necessary to fulfil the purpose for which it was collected, resolve any related enquiries, comply with legal obligations, or establish, exercise or defend legal claims. 

Use of Artificial Intelligence (AI) and Automated Decision-Making

We use trusted third-party service providers and, where appropriate, internally developed AI systems to help operate and improve our website and services. These tools support website performance, security, customer experience, content personalisation and analysis of how our website is used. Where these technologies are used, outputs are subject to appropriate human oversight and review. Decisions that could have a significant impact on individuals are not made solely through automated processing. 

Some of our third-party providers may also use AI and automated technologies as part of the services they provide to us, and we recommend consulting their privacy notices for further information. 

To provide these services, AI and automated tools may process personal data such as device information, website activity and order-related information. Where required by law, we will obtain your consent before using these technologies.

You have the right to object to certain processing of your personal data, including certain AI-assisted processing, where provided under applicable data protection law by contacting us at data-protection@upplc.com. 

We use AI technologies in the following areas:

Website Improvement and Analytics

To improve website navigation, understand how visitors use our website, enhance user experience and identify trends in customer behaviour.

Lawful basis: Legitimate interests.

Marketing and Personalisation

To tailor marketing content, improve advertising campaigns, personalise communications and better understand customer engagement.

Lawful basis: Consent (where tracking/marketing cookies apply); legitimate interests for non-tracking analytics or service communications.

Customer Service and Support

To help manage customer enquiries and provide automated support services.

Lawful basis: Performance of a contract & Legitimate interests.

Delivery and Order Fulfilment

To support order processing, delivery planning, forecasting and customer support functions.

Lawful basis: Performance of a contract.

Security and Fraud Prevention

To identify suspicious activity, prevent fraud and protect our website, customers and business systems.

Lawful basis: Legitimate interests.

Search Optimisation, Privacy and Compliance

To improve the accuracy of search results, manage customer preferences and support our legal and regulatory obligations.

Lawful basis: Legitimate interests and, where applicable, compliance with legal obligations.

We take appropriate steps to ensure that all AI and automation providers implement suitable security and privacy safeguards. Where personal data is processed, we ensure that only the minimum amount of information necessary is used. The same principles apply to our internal use of AI and automation technologies.


You visit one of our properties or communicate with our offices

We may process personal data when you visit one of our offices or communicate with one of our teams, for example:

  • You visit our premises, and your personal data is captured via our CCTV system
  • You visit our premises, and we collect your details in our visitor management (as part of Health and Safety)
  • You communicate via email/telephone with any of our staff (for instance customer services or our sales team), where calls may be recorded for internal training purposes.
  • You approach us with Trade enquiries.

Data Sharing:

To support these services, we may share your data with or receive data from selected third parties. Where we do, we ensure that have legally binding arrangements with them which ensures that your personal data remains protected.

We may share your data for the following purposes:

  • Our CCTV systems are in operation across our premises; data is retained for 30 days and is only retained for longer if there is need to support an investigation.

Lawful Basis:

We process your personal data in relation to trade enquiries to fulfil a contract with you.  

We process personal data in our ‘legitimate interest’ to support our security through our CCTV, communications and visitor monitoring. Where we process on the basis of Legitimate Interests, we conduct a Legitimate Interests test for necessity and balance against your rights and freedoms. 


You apply for employment with us

We will process personal data when you apply for a role with us directly. 

For example:

  • You will provide contact details to us to help us to manage the recruitment process.
  • You will provide career details with us (e.g. your CV) to help us in the selection process.
If you are not selected for an interview, your personal information will be deleted from our systems within 6 weeks. Should you gain an interview but not be selected for the role we will keep your details on file for 12 months.

Data Sharing:

To support these services, personal data will be shared within our HR department. If you are successful after the first recruitment stage, your personal information may be shared with a third party to conduct a psychometric analysis test. To send this test to you for completion, contact details (name, email address) must be shared with the third party. The results of this psychometric test have human oversight, and automated decision making is not utilised. Results are only used by our HR department to determine your suitability to the role you have applied for. 

Lawful Basis:

We process your personal data to enter into a contract with you. Where we conduct psychometric tests, this is done under our legitimate interests to ensure all potential candidates are suitably qualified before entering a contract with us. Where we process on the basis of Legitimate Interests, we conduct a Legitimate Interests test for necessity and balance against your rights and freedoms. Data held for this purpose will follow the same retention period as stated above for other employment related data.

Transfer

If you are selected to be employed by us, transfers of your data may be made to third-party partners that we use to support employment-related services, such as payment service providers. In such cases, where these partners are located outside of the EEA or UK, we have conducted due diligence to ensure your rights are protected and that your data is transferred lawfully and kept secure.

Safeguarding Measures

Ultimate Products UK Limited takes your privacy seriously and we take every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including:

  • Firewall
  • Encryption
  • Strict Access Controls (physical and electronic)
  • SSL certificates
  • Full Privacy Governance structure

International transfers

Some of our service providers may process personal data outside the United Kingdom. Where we transfer personal data internationally, we will do so in accordance with UK data protection law.

Where applicable, we rely on one or more of the following transfer mechanisms:
  • UK adequacy regulations;
  • the UK International Data Transfer Agreement;
  • the UK Addendum to the EU Standard Contractual Clauses;
  • Binding Corporate Rules;
  • another lawful transfer safeguard or exception permitted by UK data protection law.
You can contact us at data-protection@upplc.com for more information about the safeguards relevant to your personal data.

Consequences of Not Providing Your Data

You are not obligated to provide your personal information to Ultimate Products UK Limited, however, as this information may be required for us to provide you with our services/deliver your products/legitimate interests, we will not be able to offer some of our products or services without it.


Data retention

How Long We Keep Your Data

Ultimate Products UK Limited only ever retain personal data for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.

Where you have consented to us using your details for direct marketing, we regularly review consent given and will keep such data until you notify us otherwise and/or withdraw your consent.


Your Rights

Rights of access, correction, erasure, and restriction

You have the right to access any personal information that Ultimate Products UK Limited processes about you and to request information about:

  • What personal data we hold about you
  • The purposes of the processing
  • The categories of personal data concerned
  • The recipients to whom the personal data has/will be disclosed
  • How long we intend to store your personal data for
  • If we did not collect the data directly from you, information about the source

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.


No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.


What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.


Right to withdraw consent

In circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please write to us at the address below. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.


Lodging A Complaint

Ultimate Products UK Limited only processes your personal information in compliance with this privacy notice and in accordance with the relevant UK GDPR laws. If, however, you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority. We would be grateful if you would give us the opportunity to deal with any complaints in the first instance.

If you wish to exercise any of your rights listed above, please write to:

 

Ultimate Products UK Limited

Compliance Department

Manor Mill

Victoria Street

Manchester

OL9 0DD

UNITED KINGDOM

Email: data-protection@upplc.com

 

Ultimate Products Europe Limited

Compliance Department

19 Baggot Street Lower

Dublin 2, Dublin City

Dublin,

D02 X658

Ireland

Email: EU-Data-Protection@upplc.com


UK Data Protection Authority

Information Commissioners Office (ICO)

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

 

Tel: 0303 123 1113

Email – via their website – www.ico.org.uk


Notification of Changes to this Notice

If we decide to change our Privacy Notice, we will post these changes on this website so that you know exactly what information we collect and how we use it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will tell you and you will have a choice as to whether or not we use your information in this different manner.


Feedback

We want to make sure that we’re giving you the information that you want about privacy and security – let us know what you think. If you have any feedback, questions or concerns, please email us at data-protection@upplc.com or by post to the address above.


Links

Our website may contain links to let you visit other websites of interest with ease. Once you have used these links to leave our website, you should be aware that we do not have any control over that other website. As such, we cannot be responsible for the protection and privacy of any information that you provide whilst visiting these websites, and they are not governed by this Privacy Notice. We are not responsible for any products and/or services featured on any third-party websites; you should exercise caution and look at the Privacy Notice applicable to the website in question.


Ultimate Products UK Limited is a company under the group Ultimate Products PLC.

Dated: July 2026


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