Who we are
This privacy policy is issued by UP Training & Development Limited (“we”, “us”, or “our”), a company registered in England and Wales with company number 05286481. We are a controller of your personal data and are responsible for ensuring that it is properly protected. We are registered with the Information Commissioner’s Office (ICO) in the UK with reference ZA805259.

Please see the “How to contact us” section at the end of this privacy policy if you have any questions about this privacy policy or the data we hold about you.

This privacy policy
UP Training & Development Limited is committed to protecting and respecting your privacy. Please read this privacy policy carefully as it contains important information about who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint. We collect, use and are responsible for certain personal data about you. When we do so, we are subject to UK data protection laws.

If you are located in the European Economic Area (EEA), we are also subject to the EU General Data Protection Regulation (EU GDPR) and other local laws in relation services we offer to individuals in the EEA.

The independent authority that upholds information rights in the public interest in the United Kingdom is the ICO. Further information can be found at https://ico.org.uk

Information we may collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect personal information from you because we have a legal reason (allowed by law or under contract) to collect the information, or because you have consented for us to do so for a specific purpose.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, title, date of birth and gender.
  • Contact Data includes email address, billing address, delivery address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Service Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How we collect your personal information
We use different methods to collect information from and about you

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in a form or corresponding with us by post, phone, sending us an e-mail or otherwise. This includes personal information you provide when you:
  • apply for our services;
  • enter a competition, promotion or survey;
  • request marketing to be sent to you; or
  • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties. We may receive information about you if you use any of the other websites we operate, any other services we provide, or from our business partners instructed to collect information on our behalf.

    We also work with third parties (including, for example, business partners, sub-contractors in technical, payment, mailing and delivery services, analytics providers, credit reference agencies) and may receive information about you from them as part of the service we provide you, or for legal reasons.

How and why we use your personal information
Under data protection law, we can only use your personal data if we have a lawful basis for doing so, which includes:

  • Consent: where you have given us clear consent for us to process your personal data for a specific purpose. 
  • Contract: where our use of your personal data is necessary to fulfil a contract we have with you, or because you have asked us to take specific steps before entering into a contract. 
  • Legal obligation: where our use of your personal data is necessary for us to comply with the law (not including contractual obligations).
  • Legitimate interests: where our use of your personal data is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal data which overrides our legitimate interests).

The table below explains what we use your personal data for and why, as well as what our legitimate interests are where we are relying on our legitimate interests as the lawful basis to process your personal data:

Purpose/Activity

Type of data

Lawful basis for processing, including basis of legitimate interest and any additional processing conditions

To register you as a new customer.

(a) Identity
(b) Contact

(a) Performance of a contract with you

To process and deliver your order of services, including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and communications

(a) Performance of a contract with you


(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey

(a) Identity
(b) Contact
(c) Profile
(d) Marketing and communications

(a) Performance of a contract with you


(b) Necessary to comply with a legal obligation


(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity
(b) Contact
(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and communications
(f) Technical

Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and inform our marketing strategy

To use data analytics to improve our website, services, marketing, customer relationships and experiences

(a)Technical
(b)Usage

(a) Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and inform our marketing strategy

To make suggestions and recommendations to you about services that may be of interest to you

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and communications 

(a) Necessary for our legitimate interests (to develop our services and grow our business)

To employ you or consider you for employment

(a) Identity
(b) Contact

(a) Performance of a contract with you

(b) Consent

Who we share your personal data with
We may share your personal information with the third parties set out below for the purposes listed in the above ‘how and why we use your personal information’ section.  

For example, we may share your personal information with:

  • Subcontractors and third parties for the purpose of the performance of a contract that we hold with them or that we hold with you;
  • With third parties because you have given consent;
  • With third party service providers we use to help run our business such as cloud storage providers, Google Analytics and email marketing tools and services.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Other reasons we may share your personal information with a third party
If UP Training & Development Limited or substantially all of its assets are acquired by a third party, personal data held by UP Training & Development Limited about its customers will be one of the transferred assets of the company.

In addition, UP Training & Development Limited will share your personal data with third parties for the following reasons:

  • If UP Training & Development Limited must comply with a legal obligation;
  • To enforce or apply our Website Terms of Use or other agreements;
  • To protect the rights, property, or safety of UP Training & Development Limited, our customers or others;
  • We will exchange information with other companies or organisations to prevent fraud or to reduce our credit risks.

Transferring your personal data out of the UK and EEA
We primarily store and process your personal data in the UK and European Economic Area (“EEA”). However, to provide services to you, it is sometimes necessary for us to share your personal data outside the UK and EEA, for example, with our service providers that are either located outside the UK or EEA, or that transfer personal data outside of the UK and EEA.

Transfers of personal data outside of the UK are subject to special rules under UK data protection law. This is because non-UK countries do not have the same data protection laws as the UK.

Transfers of personal data outside of the EEA are subject to special rules under EU data protection law. This is because non-EEA countries do not have the same data protection laws as the EEA.

We will ensure that any transfer of personal data outside of the UK or EEA as applicable, complies with data protection laws and that all personal data will be secure.

As a result, when we transfer personal data outside of the UK and EEA we will ensure that the transfer complies with data protection laws by following one of the below steps:

  • Confirming that the recipient is located in a country which has been recognised as having an adequate level of protection for personal data.
  • Putting in place safeguards (such as approved standard contractual clauses) so that you have enforceable rights and effective legal remedies.
  • Confirming that a specific exception applies under data protection law.

For more information about our international transfers, please contact us using the information below.

Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your data will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How long will you keep my personal information?
We will not retain your personal information for longer than required for the purposes set out in this privacy policy. Different retention periods apply for different types of personal data.

When it is no longer necessary to retain your personal data, we will delete or anonymise it.

We will keep your personal information:

  • To respond to any questions, complaints or claims made by you or on your behalf;
  • For as long as required by law;
  • Until we no longer have a valid reason for keeping it; or
  • Until you request us to stop using it.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

You can request further details of retention periods for different categories of your personal data by contacting us.

What if I choose not to give you my personal information?
Where we need to collect personal information by law or under the terms of a contract we have with you, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

Your legal rights
 Under certain circumstances, you have rights under data protection laws in relation to your personal data. UP Training & Development Limited will respect your legal rights to your data. You have the following rights, which you can exercise free of charge:

The right to be informed

We are publishing this Privacy Policy to keep you informed as to what we do with your personal information. We strive to be transparent about how we use your data.

The right to access

You have the right to be provided with a copy of the personal information that we hold about you.

The right to rectification

If the information we hold about you is inaccurate or not complete, you have the right to ask us to rectify it. If that data has been passed to a third party with your consent or for legal reasons, then we must also ask them to rectify the data.

The right to erasure

You have the right to require us to delete your personal data – in certain situations. This is sometimes called ‘the right to be forgotten’.

The right to restrict processing

You have the right to require us to restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data.

The right to data portability

You have the right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.

The right to object

You have the right to object:

  • at any time to your personal data being processed for direct marketing (including profiling);
  • in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.

The right to withdraw consent

If you have given us your consent to process your data but change your mind later, you have the right to withdraw your consent at any time, and UP Training & Development Limited must stop processing your data.

The right to complain to a Supervisory Authority

You have the right to make a complaint at any time to the ICO, the UK regulator for data protection issues, or any relevant European data protection supervisory authority. The ICO may be contacted at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113

For further information about your rights please contact us at contact@uperformance.co.uk or see the guidance provided by the UK ICO on individuals’ rights or if you are located in the EEA, the guidance provided by your local supervisory authority.

If you wish to exercise any of the rights set out above, please:

  • Email, call or write to us — see the “How to contact us” section at the end of this policy;
  • Let us have enough information to identify you e.g. your full name and address and details of the nature of your relationship with us;
  • Let us have proof of your identity if requested; and
  • Let us know which right you want to exercise and the data to which your request relates.

Links to other websites
From time to time, our website may contain links to and from other websites. If you follow a link to any of these websites, please note that these websites may have their own privacy notices and that we do not accept any responsibility or liability for any such notices. Please check these notices, where available, before you submit any personal data to these websites.

Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

How to contact us
You can contact us using the contact details below if you have any questions about this privacy policy or the data we hold about you, to exercise a right under data protection law or to make a complaint.

Contact email address: contact@uperformance.co.uk

Postal address: UP Training & Development Limited, 30 Upper High Street, Thame, Oxfordshire, OX9 3EZ.

Phone: +44 07712 527154

Changes to our privacy policy
This privacy policy was last updated in March 2024. We keep our privacy policy under regular review to make sure that it is up to date and accurate. If we change our privacy policy from time to time, we will post the details of any changes on our website. We may also take reasonable steps to notify you if such changes affect you.

>