Personal data processing notice
USN Ltd. respects your privacy and processes personal data in accordance with Regulation (EU) 2016/679 (the "GDPR") and applicable data protection law. This notice explains what data we collect, for what purposes, on what legal bases, who we share it with and what rights you can exercise.
1Data controller
USN Ltd. (also referred to as "Upperlead" or the "Controller")
31, Pjazza l-Eroj, Swatar, Birkirkara BKR 4251, Malta
VAT number: MT30438704
Email for privacy requests: privacy@upperlead.eu
2Personal data we collect
2.1 Data you give us
When you fill in one of our contact forms or an advertising form hosted on third party platforms (for example Meta, Facebook and Instagram, Google, TikTok), we collect the data you enter, including: first name, last name, email address, telephone number e le answers you give to the questions in the form or qualification questionnaire (for example the type of product or service you are interested in, your budget range, your timing and similar information relevant to your request).
2.2 Browsing data
The IT systems and software procedures that operate this site acquire, in the course of normal operation, certain data whose transmission is inherent in the use of internet communication protocols, such as IP addresses, domain names, URIs of requested resources, the time of the request and parameters relating to the operating system and computing environment.
3Purposes of processing and legal bases
| Purpose | Legal basis |
|---|---|
| Delivering the lead generation service: collecting and qualifying your request and passing it to the client or advertiser whose product or service you asked to be contacted about. | Consent and/or performance of pre contractual measures requested by the data subject (art. 6.1(a) and (b) GDPR). |
| Contact and qualification: contacting you by telephone, SMS, WhatsApp and email, including through our own operators, in order to verify and follow up on your request. | Consent (art. 6.1(a) GDPR). |
| Commercial and marketing communications about our services or the products and services of our clients. | Consent (art. 6.1(a) GDPR), withdrawable at any time. |
| Reactivating contacts already acquired: contacting people already held in our databases in order to offer relevant products. | Consent originally collected or legitimate interest (art. 6.1(a) or (f) GDPR). |
| Operation and security of the site and statistics in aggregated form. | Legitimate interest (art. 6.1(f) GDPR). |
| Compliance with legal obligations and defence of rights in legal proceedings. | Legal obligation and legitimate interest (art. 6.1(c) and (f) GDPR). |
4How we collect data and the role of the platforms
Collection forms may be hosted directly on our site or on third party advertising platforms (for example the lead generation forms of Meta, Facebook and Instagram, or similar tools from Google and TikTok). When you fill in a form on such platforms, the data is collected through the tools made available by the platform and transmitted to the Controller. Processing of the data by those platforms for their own purposes is governed by their respective privacy notices, which we invite you to consult.
5Who we share your data with
Your data may be shared with:
- End clients and advertisers: if you request information, a quote or a call back about a product or service of one of our clients, we pass your data to that party so they can follow up on your request. The client processes your data as an independent controller, under its own privacy notice.
- Processors acting on our behalf: IT, hosting and cloud service providers, email and SMS platforms, CRM systems, call centers and contact and qualification services, consultants and professional advisers.
- Advertising platforms (Meta, Google, TikTok and similar), within the limits described in section 4.
- Public and judicial authorities, where required by law.
Your data is not disseminated, meaning it is not made available to an indeterminate audience.
6Data transfers outside the European Union
Some of the providers and platforms listed above may process data outside the European Economic Area. In such cases the transfer takes place under an adequacy decision of the European Commission (art. 45 GDPR) or on the basis of appropriate safeguards such as Standard Contractual Clauses (art. 46 GDPR), having verified that appropriate security measures are in place.
7How long we keep data
As a general rule we keep data for as long as necessary for the purposes for which it was collected:
| Purpose | Retention |
|---|---|
| Handling and qualification of the request (lead) | 24 months or until consent is withdrawn |
| Marketing and commercial communications | Until consent is withdrawn or an objection is raised |
| Browsing data | 13 months |
| Legal compliance and defence of rights | Up to 10 years |
8Your rights
As a data subject you may exercise, within the limits set out in the GDPR, the rights of: access to your data, rectification, completion, erasure, restriction of processing, portability, objection to processing for direct marketing purposes and, where processing is based on consent, withdrawal of consent at any time without affecting the lawfulness of processing carried out before withdrawal.
You can object to commercial communications at any time, for example by clicking the unsubscribe link at the bottom of our emails or by replying to an SMS with the opt out keyword. To exercise your rights, write to privacy@upperlead.eu.
9Complaint to the supervisory authority
If you believe that the processing of your data infringes the GDPR, you have the right to lodge a complaint with a supervisory authority. For the Controller, established in Malta, the competent authority is the Information and Data Protection Commissioner (IDPC), Level 2, Airways House, High Street, Sliema SLM 1549, Malta, idpc.org.mt. Alternatively you may contact the supervisory authority of the country where you reside. For Italy: Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Roma, garanteprivacy.it.
10Cookies
The site uses technical cookies, necessary for browsing, and may use measurement and marketing cookies subject to your consent. Details of the cookie categories, their purposes and how to manage your preferences are available through the site cookie banner.
11Changes to this notice
The Controller may update this notice to reflect new legislation, guidance from the authorities or changes to its services. The purposes of processing will not be changed without informing you first. The version published on this page, with its update date, is the one that applies.
Language
This is a courtesy translation. In the event of any discrepancy, the Italian version of this notice prevails.