Privacy notice and Cookie Policy on UPPFIRST

The UPPFIRTS platform uppfirst.com is owned and operated by Uppfirst SG PTE LTD, 6001 Beach Road #22-01Golden Mile Tower Singapore (199589), registration number: 202224695N (we or us).

  1. What is the purpose of this document?

    1.1 We are committed to protecting and respecting your privacy. This privacy notice sets out the basis on which any personal data we collect about you, including through our website https://uppfirst.com (our site), will be processed by us.

    1.2 We are a controller. This means that we are responsible for deciding how and why we hold and use personal data about you, and for explaining this clearly to you.

    1.3 Please read this privacy notice carefully to understand what we do with your personal data and what rights you have in relation to our activities.

    1.4 This privacy notice applies to anyone we interact with, including sellers and buyers of products and UPPNFTs and to visitors of our site.


  2. What is personal data and our lawful basis for processing?

    2.1 Personal data means any information relating to an individual from which that person can be identified (directly or indirectly). It does not include data where the identity has been removed (anonymised).

    2.2 We will only use your personal data when the law allows us to. Our lawful bases for processing is set out in the table below. However, some of our grounds for processing will overlap and there may be several grounds which justify our use of your personal data.

    2.3 If we rely on consent as a legal basis for processing your personal data then you have the right to withdraw any consent you give. You can do this at any time by contacting us.

    2.4 Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.


  3. How we collect and use your personal data and how our use complies with the law

    3.1 We have set out below the main ways we plan to use your personal data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.


    Personal data about sellers
    Type of personal data and sourceHow we use your personal dataOur lawful bases for using your personal data
    We collect your business name, representative’s full name, website, business email address, business phone number and business address.To enable you to use our platform and create your profileNecessary for the performance of the contract we have with you. Necessary for our legitimate interest in providing a platform that allows sellers to create content for the sale of the rights to products and services and to enable the sellers to engage with buyers and potential buyers.
    We also collect your social media handle from Instagram, Tik Tok, Twitter and Snapchat if you choose to share those. This information is visible to other users as part of your profile on our platform.To complete a profile on our platform and to share your profiles with, and interact with, other users.Optional for the performance of the contract we have with you. Optional for our legitimate interest in providing a platform that allows sellers to create content for the sale of the rights to products and services and to engage with buyers and potential buyers.
    Personal data about buyers
    We collect your email address when you contact us by filling in a form or register for an account.To enable you to use our platform or to respond to your query.Necessary for the performance of the contract we have with you.
    We collect your billing and shipping address.To enable you to purchase and request delivery from sellers on the UPPFIRST platform.Necessary for the performance of the contract we have with you.

    We will sometimes use and share your personal data in other ways. Here are some examples:

    • To respond appropriately if someone gives us feedback or raises a complaint or concern about us or our platform. This is for our legitimate interest in protecting our reputation and business and for our legitimate interest in improving and developing our products and services.
    • We may contact users to request feedback on those users' experiences with us or other users. Users may also proactively provide feedback, for example, by posting a review about you or your products. This information may be shared on the platform and with you, other users or other third parties for the purpose of improving the platform and improving future users' experiences. The information may also be used for the purposes of addressing any complaints. This is for our legitimate interests in improving the platform and user experience.
    • To investigate any breach of our terms of use, if someone made a complaint about a user or if there was another concern that we needed to look into. We have the right to disclose your identity to any third party who is claiming that any content posted or uploaded by you to our platform constitutes a violation of their intellectual property rights, or of their right to privacy. This is for our legitimate interest in ensuring that our platform is used appropriately and in accordance with our terms of use and in some cases may also be necessary for us to enforce our rights under our contract with you.
    • To send you our newsletters. We will do this with your consent (where applicable) otherwise for the legitimate interest of promoting our business. You can ask us to stop sending you newsletters or other marketing messages at any time by following the opt-out links on any marketing message sent to you.

  4. Sharing your information

    4.1 We may share your information with third parties as follows:

    • 4.1.1 if we sell any business or assets, in which case we may disclose your personal data to the prospective buyer (and their advisors) of such business or assets;


      4.1.2 with our insurers or professional advisors;


      4.1.3 if we have a legal obligation to do so; or


      4.1.4 in exceptional circumstances, we may need to share personal data with law enforcement, for example, where we consider that doing so is necessary for our legitimate interests in ensuring that our platform is used appropriately.

    4.2 We share your personal data with third-party service providers, such as our platform provider, our site host, IT support and maintenance service, cloud storage providers and email exchange servers.


  5. If you fail to provide personal data

    5.1 You are required to provide the personal data set out in the table. If you fail to provide certain information when requested, we will not be able to provide our services to you.


  6. How long we keep your personal data for

    6.1 We will only keep your personal data for as long as necessary to fulfil the purposes we use it for, including for the purposes of satisfying any legal, accounting or reporting requirements. Usually, when a seller or a buyer deletes their account then their personal data held in relation to that account will be deleted at the time or shortly after. However, we may retain your personal data for a longer period in the event of a complaint or concern or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

    6.2 We may keep personal data for up to 12 months longer than any stated retention period to allow time for us to anonymise or delete information in accordance with our internal data management processes.

    6.3 Emails are kept for up to 2 years on our back-up email exchange server.


  7. Your legal rights

    7.1 You have the following rights:

    • 7.1.1 to correct or update the personal data we hold about you. As a buyer or seller, you can do this through your account settings or by emailing us at [email protected];

      7.1.2 to object to the processing of your personal data where we are processing your data for direct marketing purposes or where we are relying on legitimate interests as our lawful basis;

      7.1.3 to request a copy of the personal data we hold about you;

      7.1.4 to ask us to delete the personal data that we hold about you;

      7.1.5 to ask us to restrict how we use your personal data;

      7.1.6 to ask us to send your personal data to another organisation in a computer-readable format;

      7.1.7 to complain to the UK data protection regulator, the Information Commissioner's Office (ICO). If you do have any concerns about how we have handled your personal data we would kindly ask that you contact us in the first instance before you speak to the ICO so that we have an opportunity to put things right.

    7.2 If you want to exercise any of your rights, please contact [email protected]. Please note that some of these rights are subject to a number of exceptions and exemptions, which means that we will not always have to comply with your request.


  8. Further information

    8.1 If you have any questions about this notice, please contact us at [email protected].



    Addendum: Additional Information for users in Singapore

    To the extent that Singapore Data Protection Laws (as defined below) apply to the processing of your personal data, this Addendum (“Additional Information for users in Singapore”) shall apply.

    Singapore Data Protection Laws shall mean any applicable data protection and privacy laws relating to the processing of personal data and privacy including the Personal Data Protection Act 2012 (“PDPA”) and the Personal Data Protection Regulations 2021. Further, “personal data” shall have the meaning ascribed to it in the PDPA.

    In the event of any conflict or inconsistency with the main body of this Privacy Notice and this Addendum, this Addendum shall prevail to the extent that the Singapore Protection Laws apply to our use of your personal data.

    Legal Basis for Processing your Personal Data

    We foresee collecting and using your personal data in the ways set out in Section 3.1 above and disclosing your personal data in the ways set out in Section 4.1 above. We will collect, use and disclose your personal data in accordance with the Singapore Data Protection Laws. In general, before we collect any personal data from you, we will notify you of the purposes for which your personal data may be collected, used or disclosed, and we will obtain your express or deemed consent for the collection, use or disclosure of your personal data for such purposes, unless we are able to rely on any exceptions to consent under the PDPA.

    How Do I Access My Personal Data?

    You may contact us if you wish to find out about the personal data we hold about you or how we used or disclosed that personal data in the past 12 months prior to your request. We may need to verify your identity before giving you access and, depending on the complexity of your request, we may charge a reasonable fee for processing the request. If we are unable to respond to your requests within thirty (30) days after receipt of your request, we will inform you within that time in writing the time by which we will be able to respond to the request.

    How Do I Correct my personal data?

    In order to ensure that the personal data that we maintain is accurate, you may, at any time, send our Data Protection Officer requests to update your information or requests for correction of errors or omissions in personal data which we hold about you. If we are unable to respond to your requests within thirty (30) days after receipt of your request, we will inform you within that time in writing the time by which we will be able to respond to the request.

    How Do I Withdraw my Consent?

    You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed herein by submitting your request via email to our Data Protection Officer. We will inform you of the likely consequences of withdrawing consent and will endeavour to process your request within ten (10) business days from the day of receipt of your request.

    Security

    We will use technical and organisational measures to safeguard your personal data. For example: (a) all personal data you provide to us is stored on our secure servers; (b) we restrict access to personal data to our employees, service providers and contractors on a strictly need-to-know basis and ensure that those persons are subject to contractual confidentiality obligations; and (c) we review our personal data collection, storage and processing practices from time to time to guard against unauthorised access, processing or use.

    Retention of personal data

    We will only retain and use your personal data for as long as the purpose for which that personal data was collected for is being served by retention of the personal data, or the retention is necessary for legal or business purposes, including complying with our legal obligations, resolving disputes and enforcing our agreements.

    International transfers

    We will only transfer personal data to a country or territory outside Singapore if we ensure that the overseas receiving party is bound by legally enforceable obligations to afford the transferred data a standard of protection that is comparable to that under Singapore law. We will also ensure that any overseas recipient is able to provide appropriate technical and organisational measures to protect your personal data and its confidentiality.

    Data Protection Officer

    Our Data Protection Officer can be contacted using the business contact information provided at Section 8.1 of the main body of this Privacy Notice.





  9. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website.
  10. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
  11. We use the following cookies:

    11.1 Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.


    11.2 Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.


    11.3 Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).


    11.4 Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.


    11.5 You can find more information about the individual cookies we use and the purposes for which we use them in the table below:


    Cookie NamePurpose
    uppfirst_authThis cookie is essential for our site to enables us to:

    a) Recognise you when you return to our site.
    b) Store information about your preferences.
    c) Speed up your searches.
    d) Allow you to use our site in a way that makes your browsing experience more convenient, for example, by allowing you to store items in an electronic shopping basket between visits. If you register with us or complete our online forms, we will use cookies to remember your details during your current visit, and any future visits provided the cookie was not deleted in the interim.

  12. Please note that the third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies;

    12.1 Third parties may include purchasing providers, data analytics providers or vendors, companies providing communication or identity verification to us which you choose to use, third-party providers which you choose to use or other vendors which provide us with information necessary to run the platform.


    12.1.1 Google Analytics, needed to collect analytics regarding website audience.

    12.1.2 Stripe, needed for fraud prevention.


    12.2 Third parties may also include agents and or affiliates, subsidiaries, or joint ventures under our control in which they are required to honour this Privacy notice.


  13. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.

    However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.