UPG GDPR Privacy Policy

Picture Playground Print Ltd trading as “UPG Print Group” (UPG Print Group are referredtogether as UPG), recognise the importance of maintaining the confidentiality, integrityand security of your personal data (“Personal Data”), and hereby inform you that anypersonal data which you provide to UPG through our Website, as well as any personal data which you may provide through its subsidiaries and/or affiliates (collectively the “Picture Playground Group Ltd”), will be processed in compliance with current Europeanprivacy laws (Regulation (EU) 2016/679 – “GPDR”) and with any specific local regulationsapplicable from time to time for the processing of data outside the European Union,together with the principles and general rules of conduct contained in the Code ofEthics adopted by UPG Print Group Ltd.4

1. Type and source of DataBrowsing-data
During their normal operation, the computer systems and software procedures used to operate our website and internal quotation systems collect certain personal data (log files). The transmission of such data is inherent to the use of internet communication protocols. This information is not collected in order to be associated to specific data subjects. However, due to its nature, this information can allow users to be identified by means of their processing and integration with data held by third parties. Such information includes the IP addresses or domain names of the computers you use to visit our website, URIs (Uniform Resource Identifiers) of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the numerical status code of the server reply (successful, error, etc.) and other parameters concerning the user’s operating system and computer environment. This data is used with the sole purpose of obtaining anonymous statistical information on the use of our Website and to guarantee its correct operation.

Our website uses cookies to ensure its efficient functioning and to improve our services. Cookies are small text files that are sent to your computer (usually to your browser) by the websites you visit. Cookies are stored in your computer to be recognised by those websites on your subsequent visits. For more information on cookies, on the types of cookies used on our Website, on how to disable them and on how you can revoke your consent, see our cookie policy.

Personal Data voluntarily provided by the data subject
UPG Print Group collects and processes the personal data that you directly and voluntarily provide through our website when you place online orders and/or register to our website and/or subscribe to our newsletter and/or contact our customer service. UPG Print Group also collects and processes the personal data that you may provide by filling in our customer card at our store. This data includes, for example, your first and last name, postal and e-mail address, phone number and date of birth. Furthermore, when you voluntarily send an e-mail through our website and/or to the addresses indicated in our website, we collect your e-mail address so that we can reply to any request, as well as any additional personal data contained in your message.

2. Purpose of processing, your personal data may be based on the necessity for the provision of the services for the following purposes:
To respond to all your requests and to manage your relationship with UPG Print Group;To fulfill your online purchase orders and perform all management activities connected with it (including administrative management of the contract, delivery of goods, payment processing, management of any claims and litigation, and fraud prevention), and to comply with any applicable legal or regulatory obligations.Furthermore, subject to your prior consent, your personal data may be included in the Picture Playground Print Ltd, customer data base, managed by the holding company Picture Playground Ltd, and processed together with the details of your purchases for the following purposes:Profiling: to perform individual or group studies, surveys, statistical and/or market researches on your preferences with regards to our products, so that we can offer you a personalised service and promote cultural and recreational activities that may interest you;Marketing: to contact you and/or send you (by post, telephone, e-mail and any other form of electronic communication) information and promotions including commercial information, newsletters, advertising material, catalogues and invitations to events related to the UPG Print Group Group’s products and services.

3. Processing Methods
Your personal data will be processed by suitable electronic or automated means and computerised tools, or manually and on hard copy, exclusively for the purposes for which they have been collected and guaranteeing the security and confidentiality of any processed information. Your personal data will be processed only by UPG Print Groups internal staff duly authorised to do so under their respective job duties. Your personal data may also be processed by third parties to the extent necessary and/or instrumental for the above purposes. These third parties will act on behalf of UPG Print Group as data processors (e.g. service providers, carriers, IT technicians or any other suppliers appointed by UPG Print Group to carry out and/or manage any promotional campaigns for UPG Print Group’s products and services, etc.).

4. Nature of the provision of personal data
The provision of your personal data is optional. However, if you wish to make a purchase order for products offered on our website, and/or receive information on UPG Print Group’s products and services, and/or contact our customer service and/or use any other services offered by the UPG Print Group, you need to fill in all mandatory fields of the relevant forms.The processing of your personal data for the purposes indicated at letters (c) and (d) of paragraph 2 above is subject to your prior express consent. If you withhold your consent, we may not be able to offer you a personalised service and inform you of any initiatives that may interest you and/or send you any other commercial information on products, initiatives and events of the UPG Print Group.You may withdraw your consent to the processing of your Personal Data by us at any time, by writing to UPG Print Group, Kings Lodge, London Rd, West Kingsdown TN15 6AR (United Kingdom), by sending an e-mail at sales@upgprintgroup.com or by using the “unsubscribe” link included in all of our commercial electronic communications, and/or by using any other appropriate procedures which may be made available to you.

5. Transfer and disclosure of data of data
Whenever necessary and/or instrumental to the above purposes, your personal data may be processed on behalf of UPG Print Group by other entities acting as data processor, including:Picture Playground Ltd companies and franchisees that operate Picture Playground Ltd stores; companies, consultants and firms providing advisory and/or consulting activities or performing related services that are instrumental to data processing on behalf of UPG Print Group.Your personal data will not be used for third-party advertising purposes or for the promotion of products, services, or initiatives by entities other than the UPG Print Group, nor shall they be disclosed to unknown persons under any circumstances.

6. Retention period
Your personal data will be processed and stored for as long as required for the purposes for which they were collected, and in accordance with the storage periods provided for by the applicable laws, or until you revoke your consent to the processing, if applicable. After such period, your Personal Data will be automatically and permanently erased or made anonymous.

7. Data controllers
For the purpose of managing and executing your online purchase orders referred to at letter (b), of the paragraph 2 above the Data Controller is UPG Print Group Ltd. Please contact the Data Controller by writing to UPG Print Group Ltd, Kings Lodge, London Rd, West Kingsdown TN15 6AR (United Kingdom), or sending an e-mail to sales@upgprintgroup.com

8. Rights of the data subject
Please note that you may exercise the rights under Articles 15 to 21 GDPR, and specifically the right to request information
as to whether your personal data is being processed and as to the characteristics of the processing, the right to rectification and erasure of your personal data, the right to object to the processing and/or the right to have those personal data transmitted to another controller. You also have the right to withdraw your consent at any time. The withdrawal of your consent will not affect the lawfulness of processing based on your consent before its withdrawal.

9. Contacts
If you have any request on your personal data or on how you might exercise your rights, you may contact the data controller or the DPO free of charge. UPG Print Group reserves the right to amend this Privacy Policy at any time. The Privacy Policy currently in force is the one published on our Website.