At Up2U, we take privacy and the protection of personal data seriously. This Privacy Policy explains how SMS2U SL, trading as Up2U ("Up2U", "we", "us" or "our"), collects, uses, shares and protects personal data when you visit our websites, contact us, become a customer or partner, or use our services. It also explains the rights available to you under applicable data protection legislation, including the EU General Data Protection Regulation ("GDPR") and applicable Spanish data protection law.
1. Who We Are
Up2U is the trading brand of:
SMS2U SL
Avenida Virgen Del Rocio S/n CCIAL LA C. 29670, Marbella (Malaga). España
Privacy enquiries: [email protected]
For the purposes of applicable data protection law, SMS2U SL will generally act as the data controller where we determine how and why your personal data is processed.
In some circumstances, particularly where we provide platform or connectivity services on behalf of a business customer or partner, we may process personal data as a data processor acting on that organisation's instructions.
2. Personal Data We May Collect
The information we process depends on how you interact with Up2U and which services you use. It may include:
Identity and Contact Information
- Name
- Business name
- Job title
- Email address
- Telephone number
- Country
- Billing or business address
Account and Partner Information
Where you create an account, become a customer or participate in the Up2U Partner Programme, we may process information associated with your account, organisation, commercial relationship and use of our platform.
Transaction and Billing Information
Where applicable, we may process information relating to purchases, subscriptions, invoices, payments and transaction history. Payment card information may be processed directly by authorised payment service providers rather than stored by Up2U.
Telecommunications and Service Information
When connectivity services are provided, technical information may be processed where necessary to provision, operate, secure, support and manage those services. Depending on the service, this may include:
- SIM or eSIM identifiers
- Mobile number information
- Network information
- Connectivity and service usage information
- Activation and provisioning information
- Device or technical information
- Service status and diagnostic information
- Country or network from which a service connects
The exact information processed will depend upon the connectivity service being provided.
Website and Technical Information
When you visit an Up2U website or use our digital services, we may receive technical information such as:
- IP address
- Browser type
- Device type
- Operating system
- Pages visited
- Referral source
- Date and time of access
- Website interaction information
- Cookie and similar technology information
Further information is provided in our Cookie Policy.
Communications
If you contact us, we may retain correspondence and information contained within enquiries, support requests, emails, forms or other communications.
3. How We Use Personal Data
We may process personal data for purposes including:
Providing Our Services
- Create and manage accounts
- Provision connectivity services
- Activate and manage SIMs and eSIMs
- Provide mobile numbers and related services where applicable
- Manage connectivity and network access
- Process orders and subscriptions
- Provide customer and technical support
- Maintain and improve service reliability
Managing Partners and Business Customers
- Operate the Up2U Partner Programme
- Manage commercial relationships
- Support Referral, Retail, Platform and Operator Partners
- Provide access to partner tools and platforms
- Manage commissions, billing and commercial arrangements
- Respond to partnership enquiries
Communications
- Respond to enquiries
- Provide service notifications
- Communicate important account or platform information
- Provide customer and partner support
Security and Fraud Prevention
- Protect our systems and services
- Detect and prevent fraud, abuse or unauthorised access
- Investigate security incidents
- Protect customers, partners and telecommunications infrastructure
Legal and Regulatory Compliance
To meet obligations arising under applicable laws, regulations, court orders and regulatory requirements.
Improving Up2U
We may analyse service and website usage to understand how our products are being used and to improve our platform, services and customer experience.
Marketing
Where permitted by law, we may use contact information to communicate relevant information about Up2U products, services and opportunities. You can opt out of direct marketing communications at any time.
4. Legal Bases for Processing
Depending on the circumstances, Up2U may process personal data on one or more of the following legal bases:
Contract
Processing may be necessary to enter into or perform a contract with you, including providing services you have requested.
Legitimate Interests
We may process information where necessary for legitimate business interests, provided those interests are not overridden by your fundamental rights and freedoms. These interests may include:
- Operating and improving our business
- Providing customer and partner support
- Protecting our systems
- Preventing fraud
- Maintaining service security
- Managing business relationships
Legal Obligation
Certain information may be processed where necessary to comply with legal or regulatory obligations.
Consent
Where required, we may ask for your consent before processing information for a particular purpose. Where processing relies upon consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
5. Who We Share Personal Data With
Up2U does not sell personal data. We may share information where necessary with organisations involved in delivering or supporting our services, including:
- Mobile network operators
- Telecommunications carriers
- Connectivity providers
- Roaming and network partners
- Technology and infrastructure providers
- Cloud and hosting providers
- Payment service providers
- Professional advisers
- Customer-support providers
- Analytics and website service providers
- Business partners where required to deliver a service
- Government, regulatory or law-enforcement authorities where legally required
We seek to ensure that organisations processing personal data on our behalf are subject to appropriate contractual and data-protection obligations.
6. International Data Transfers
Up2U operates in an inherently international telecommunications environment. Providing global connectivity may require personal data to be processed by telecommunications networks, technology providers and other service providers located in countries outside Spain or the European Economic Area ("EEA").
Where personal data is transferred outside the EEA and applicable data protection legislation requires safeguards, we use appropriate mechanisms intended to protect that information in accordance with applicable law. These may include adequacy decisions adopted by the European Commission, approved contractual safeguards or other lawful transfer mechanisms.
7. How Long We Keep Personal Data
We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including providing services and meeting legal, accounting, regulatory, security and contractual requirements. Retention periods vary according to:
- The nature of the information
- The service being provided
- The duration of our relationship with you
- Applicable legal and regulatory obligations
- The need to establish, exercise or defend legal claims
When information is no longer required, we take appropriate steps to delete or anonymise it.
8. How We Protect Personal Data
We use appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.
These measures are reviewed according to the nature of the information being processed and the risks associated with that processing.
No internet, telecommunications or information-storage system can be guaranteed to be completely secure, and we therefore cannot guarantee absolute security.
9. Your Data Protection Rights
Depending on applicable law and the circumstances of the processing, you may have the right to:
- Access personal data we hold about you
- Rectify inaccurate or incomplete information
- Erase personal data in certain circumstances
- Restrict processing in certain circumstances
- Object to certain processing
- Receive or transfer certain personal data in a portable format
- Withdraw consent where processing is based on consent
- Object to certain automated decision-making, where applicable
Some rights are subject to legal conditions and exceptions and therefore may not apply in every circumstance.
To exercise a data protection right, contact: [email protected]
We may need to verify your identity before fulfilling a request.
10. Complaints
If you have concerns about how Up2U processes your personal data, we encourage you to contact us first so that we can investigate the matter.
You also have the right to lodge a complaint with the competent data protection supervisory authority. As SMS2U SL is established in Spain, the Spanish supervisory authority is the Agencia Española de Protección de Datos (AEPD).
11. Cookies
Our website may use cookies and similar technologies to operate the website, remember preferences, understand website usage and, where applicable and permitted, support analytics or marketing activities.
Where legally required, non-essential cookies will only be used after obtaining the appropriate consent.
Further information about the cookies used on our website is available in our Cookie Policy.
12. Third-Party Websites
Our websites may contain links to websites, applications or services operated by third parties.
Up2U is not responsible for the privacy practices of third-party services. We recommend reviewing the privacy information provided by those organisations before providing personal information to them.
13. Children
Up2U's business and partner services are not intended to be contracted directly by children.
We do not knowingly use our website to solicit personal data directly from children for marketing or commercial partnership purposes.
Where connectivity services are provided to or used by minors through a customer, partner or organisation, additional requirements may apply depending upon the service and circumstances.
14. Automated Decision-Making
If Up2U introduces processing involving solely automated decisions that produce legal effects or similarly significant effects for individuals, we will provide the information and safeguards required by applicable data protection legislation.
15. Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes to our services, technology, business practices or legal requirements.
The latest version will be published on this page and identified by the "Last updated" date shown above.
Material changes may also be communicated through other appropriate channels where required.
16. Contact Us
Questions about this Privacy Policy or how Up2U processes personal data can be directed to:
SMS2U SL trading as Up2U
Avenida Virgen Del Rocio S/n CCIAL LA C. 29670, Marbella (Malaga). España
Privacy enquiries: [email protected]
General enquiries: [email protected]
Website: up2u.red
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