Upstream S.M.S.A. and its affiliated companies (hereinafter “Upstream” or “we”) are committed to protecting the personal data of its website visitors and of the end users of our services made available through the Upstream platform to businesses (the “Clients”). Please read carefully this policy in order to understand how we collect and use your personal data as well as your rights relating to the processing of your personal data by Upstream. We reserve the right to update or revise this policy at any time, so please check this page on a regular basis for any changes. If you are an end user of our services by accessing or using the services from a Client, please note that the use of the services from a Client is governed by the written terms of service and the written privacy policy posted by the Client on the Client’s site.

1. What personal data do we collect about you and for which purposes?

Through the Upstream website:

You are not required to provide us with any personal information in order to browse in our website. However, you may provide us with your personal information a) when you submit your interest to receive one of our reports, to request a demo, to subscribe in our newsletters, to contact us and b) when you want to apply for a job.

In order to receive one of our reports, request a demo and request to contact us, you will need to provide us with your first name, surname, email, company’s name and job title (Industry and Country are optional). In case you prefer to be contacted over phone when requesting your demo, you can provide us with your phone number as well. We will use your data only in order to address your relevant request. In case you want to receive emails with other communications by Upstream in the future, you need to give us your consent by ticking the relevant consent box before submitting your request or you can subscribe by giving us your email address in the resources section. You can revoke your consent any time in the future as per instructions provided in each email communication or by sending “opt-out request from email marketing” to corp.comms@upstreamsystems.com.

If you apply for a job, we will process your data in order to assess your qualifications and make a decision regarding your application. More detailed information on the processing of your personal data for recruitment purposes is provided through the Privacy Notice for Recruitment and at the online submission of the job application to us.

Through the Upstream services:

If you are an end user of our services by accessing or using the services from a Client, please note that the use of the services from a Client is governed by the written terms of service and the written privacy policy posted by the Client on the Client’s site.

2. Use of Cookies

We use cookies in this website. For more information, please see our cookie policy.

3. How we share and how we protect your personal data?

We do not sell or otherwise dispose email addresses, mobile numbers and other personal data collected through the Upstream site or transmitted or collected via our services. We will not share or disclose your personal data to any third party except from our trusted service providers, including IT entities and CRM platform who act on behalf and under the instructions of our firm and are bound to comply with all necessary technical and organizational measures for the protection of your personal data. In case that we transfer your personal data to service providers which are located outside the European Union and the European Economic Area, we will do so in full compliance with the data protection legislation and on the basis of an adequacy decision issued by the European Commission or other sufficient safeguards, including the execution of model clauses with the services providers receiving your personal data.

The security of your personal data is of utmost importance to us. We are committed to maintaining the highest technical and organizational measures to protect the integrity, confidentiality and availability of personal data and to keep them secure against unauthorized access, misuse, disclosure, unlawful destruction or loss.

4. How long we retain your personal data?

We will keep your personal data only for as long as it is necessary for the purposes of the processing mentioned above. As regards your personal information included in your job application, please refer to the Privacy Notice for Recruitment.

5. Your rights

You have the right to request a copy of all personal data we hold for you. You also have the right to have your data erased or rectified and the right to restrict and to object to the processing of your personal data by Upstream. In addition, under certain circumstances, you may ask to receive the personal data that we keep for you in a structured, commonly used and machine-readable format and to have them transmitted to another company suggested by you. The above rights can be exercised by sending an email to the email address provided hereunder.

If you are an end user of a Client using Upstream’s services and you want to edit or delete any information collected about you, you should contact the Client directly.

Finally, if you consider that Upstream violates the applicable data protection laws when processing your personal data, you have the right to lodge a complaint with the Hellenic Data Protection Authority (www.dpa.gr).

6. Our contact details

If you have any questions about this Privacy Policy or if you wish to exercise any of the above rights or raise a concern, you may contact our Data Protection Officer by email at data.protection@upstreamsystems.com.

Last updated: 03.03.2023