Select Page

Privacy Policy

We want our friends to really benefit from upRing’s differentiated value proposition. We have designed from scratch and developed upRing with privacy in mind. We fully endorse Digital Ethics and Data Protection Regulations, and are fully committed to defend your rights regarding personal data protection. We are confident that you will recognize these efforts through the normal functioning of the Application and as you read through this Privacy Policy Statement, which explains the personal data we process, how we process it and for what purposes.

Please read the product-specific details in this privacy statement, which provide additional relevant information regarding:

Your rights;

The use of the Application or the www.upRing.com website before providing any data;

The use of the Application or the www.upRing.com website after providing any data and granting access to your digital information sources; and

Our privacy practices and measure that guarantee the protection and integrity of the data;

so that the consent prior to the submission of data on your part may be duly substantiated.

All this pursuant to General Data Protection Regulation (EU) 2016/679, of the European Parliament and of the Council, of 27 April 2016, with regard to the processing of personal data and on the free movement of such data (the “European Regulation of Data Protection” or RGPD”), beClocked SL informs Users of upRing (hereinafter, the Application), of the processing of personal data, which they voluntarily provided during the process of registration, access and use of the service.

Therefore, any user who wants information, must necessarily mark the option, read and accepted the website’s privacy policy, the legal warning and the cookies policy.

Identification of the data controller

The data controller is the entity responsible for the processing of your data.

BECLOCKED SL, a mercantile company incorporated under the laws of Spain, bearing CIF/NIF no. B-88160361 and address for notification purposes in Madrid, Irún 23, CP 28008 and registered with the Business Registry of Madrid under Volume 38003, Folio 91, Section 8, Sheet M-676659, Entry 1 (hereinafter, the “Data Controller” or “beClocked”), is the entity responsible for processing the data provided by the customers of the Application (hereinafter, the Users). beClocked is the owner and developer of upRing.

Personal data we collect and purpose of data processing

Consistent with the Digital Ethics principle that we endorse, upRing minimizes the amount of Personal Data that it collects. Personal Data (or “Information”) means information that identifies specifically a particular person or User.

To implement these data restrictions, upRing operates under the following technical principles, which affect your privacy, upRing’s functionalities and the personal information we keep for the purpose of guaranteeing the correct functioning of the Application:

 

  • Your contacts only in your device: your contact list only resides inside your device. Not extracting your contact list from your device allows us to provide you with the highest level of privacy and safety, since our servers have no access to such information.
  • Device-to-device communications: data exchanges between users are not stored in our servers, but directly delivered device-to-device whenever the mobile devices involved in a communication are reachable simultaneously.
  • Users keep full control: you keep control at all times of the interactions with your contacts. Only you decide who to contact and when to do it (i.e. upRing does not contact your contacts) and only you decide what information you share, with whom and for how long you share it.
  • Key contact field verification: upRing helps preventing phishing by forcing the verification of exchanged email addresses and mobile numbers. Verified data allows you to receive private in-app communications, directly from your contacts, device-to-device.

We use the data we collect to provide you with rich and interactive experiences. In particular, we use the data to provide our products, which includes updating, protection and troubleshooting, as well as providing technical support. This also includes sharing data, when necessary to provide the service or perform the transactions you request. We also use the data to Improve and develop our products, to customize our products and make recommendations, to announce you updates and offers, and to to operate and improve our business, which includes analyzing our performance, complying with our legal obligations, developing our work capacity and conducting research.

Learn more about what information we collect and why we collect it

Storage of data

The personal data collected through upRing will be be stored in our systems and databases for the duration of your relationship with the Application, and provided that you do not request its deletion. Once the relationship has finished, it will be erased (or blocked only in order to comply with the possible legal obligations, including, the storage of the data for a minimum period of five years in order to allow the possible responsibilities arisen from the processing to be filtered).

We shall inform Users that, as a provider of data storing service and by virtue of the provisions of Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSI), we hold for a maximum term of 12 months the information essential to identify the origin of the data hosted and the moment in which the provision of the service began. The retention of these data shall not affect the secrecy of communications and shall only be used within the framework of a criminal investigation or for safeguarding public safety, being at the disposal of judges and/or courts or the Ministry that so requires. The communication of data to the State Security Forces and Corps shall be carried out by virtue of the provisions of the regulations on personal data protection, ensuring the utmost respect for it.

We, as Data Controller, shall take the required steps to ensure the security, integrity and confidentiality of the data pursuant to the provisions of Regulation (EU) 2016/679 of the European Parliament and the Council, of 27 April 2016, on the protection of individuals with regard to the processing of personal data and their free movement.

Although the Data Controller makes backup copies of the contents hosted on the servers, it shall not be responsible for the loss or accidental deletion of the data by Users. Likewise, the Data Controller shall not guarantee the total replacement of the data deleted by Users since the aforementioned data could have been deleted and/or modified during the period of time since the last backup. As explained before, upRing maximizes your privacy by keeping your contact list and the information it contains only in your device. Note that this implies that we do not have such information and, therefore, we cannot store it nor make backup copies of it.

 

Legitimacy for the treatment of your data

The processing of the Users’ data shall be carried out pursuant to the following legal bases that legitimize it:

  • The request for information and/or the hiring of the services of the Application, whose terms and conditions shall be made available to the Users in any case, beforehand, for express acceptance.
  • The free, specific, informed and unambiguous consent of Users, making available this privacy policy, which must be accepted by means of a statement or a clear affirmative act, such as filling a box provided for that purpose or downloading the app through Apple Store or Google Store. In the event that Users do not provide beClocked with the corresponding data, or do so in a wrong or incomplete manner, it shall not be possible to use the Application.
Disclosure of your personal data to third parties

The data shall not be communicated to any third party not belonging to beClocked, except upon request of the User or the User’s specific consent or by legal obligation. We respect and protect your privacy, but it is possible that we may be required to provide information about you to a court or law enforcement agency. We will only disclose your Information if we are legally required to do so — if we receive a valid subpoena, court order, or search warrant, for example.

On the other hand, we shall be entitled to give access or transfer the personal data provided by you to third-party service providers with which we have formalized data processing agreements, and they shall only access said Information to provide a service in favor and on behalf of the Controller and the Users:

  • We use reputed third parties to assist us in delivering parts of the services to you. This includes, for instance, third-party service providers that facilitate electronic communications ordered by you.
  • We therefore may, and shall be entitled to, share portions of your Information with these third parties to the extent necessary for them to provide these services. These companies are acting on our behalf and are required, by contract with us, to keep this Information confidential and are only authorized to use it for specific purposes, as described in more detail below.
  • By using upRing you expressly consent and grant us permissions to use email addresses and mobile numbers from your digital contact database for the purpose of you ordering electronic communications to your contacts, which may also be Users of the Application. You must be aware that by ordering electronic communications with your contacts through upRing, you accept that your Information may be disclosed to third parties for the purpose of processing these electronic communications, and you consent to subscribe these contacts to our electronic communication services even when they imply third-party service providers.
  • The nature of this user-to-user electronic communications and the associated subscription are your sole responsibility; we shall not be responsible for the subscription and the nature, accuracy or reliability of any Information or advice transmitted by means of the application. We shall be entitled, at any time, to limit or interrupt this use at our sole discretion. To the maximum extent permitted by law, in no case will we be liable for any related damage or breach of Law.

On the other hand, we shall be entitled to give access or transfer the personal data provided by you to third-party service providers with which we have formalized data processing agreements, and they shall only access said Information to provide a service in favor and on behalf of the Controller and the Users:

  • We use reputed third parties to assist us in delivering parts of the services to you. This includes, for instance, third-party service providers that facilitate electronic communications ordered by you.
  • We therefore may, and shall be entitled to, share portions of your Information with these third parties to the extent necessary for them to provide these services. These companies are acting on our behalf and are required, by contract with us, to keep this Information confidential and are only authorized to use it for specific purposes, as described in more detail below.
  • By using upRing you expressly consent and grant us permissions to use email addresses and mobile numbers from your digital contact database for the purpose of you ordering electronic communications to your contacts, which may also be Users of the Application. You must be aware that by ordering electronic communications with your contacts through upRing, you accept that your Information may be disclosed to third parties for the purpose of processing these electronic communications, and you consent to subscribe these contacts to our electronic communication services even when they imply third-party service providers.
  • The nature of this user-to-user electronic communications and the associated subscription are your sole responsibility; we shall not be responsible for the subscription and the nature, accuracy or reliability of any Information or advice transmitted by means of the application. We shall be entitled, at any time, to limit or interrupt this use at our sole discretion. To the maximum extent permitted by law, in no case will we be liable for any related damage or breach of Law.
What are your rights when you provide us with your information

We are happy to inform Users that you are assisted by the rights of information, access, rectification, limitation, deletion, opposition and portability:

  • Right of information: you have the right to be informed clearly before your data is collected about what data is being treated, with what purpose they are treated, where they have obtained the data and if they are going to communicate it or have communicated it to someone.
  • Right of access:  you have the right to know which of your data is being treated, for what purpose, where they have obtained the data and if they are going to communicate it or have communicated it to someone.
  • Right of rectification: you have the right to modify your inaccurate or incomplete data.
  • Right of limitation: you have the right to cancel your inadequate or excessive data.
  • Right of deletion: you have the right to request deletion of your data.
  • Right of opposition: you have the right to prevent your data from being treated or to stop being treated, only in the cases established by law.
  • Right to data portability: you have the right to be able to receive your data provided in a structured electronic format for normal use and in order to be able to transmit them to the person in charge.
  • Right not to be the subject of individualized decisions: you have the right that no decision about you that produces legal effects or affects you is based only on the treatment of your data.

Likewise, Users shall be entitled to revoke the consent initially provided, and to submit claims of rights to the Control Authority.

How can you make use of your rights?

You may exercise your rights by means of a request addressed to the email address: rights@upRing.com, which shall include:

  • Photocopy of the ID Number (passport or other identity document) or electronic signature.
  • Content of the request you make and, if necessary, the documents that prove it.
  • Address (for notification purposes), date and signature.

If you exercise your rights by a voluntarily appointed representative, you must provide the document or electronic instrument that proves the representation.

In the event that the owner of the data is under-age or disabled, the rights will be exercised by their duly accredited legal representative.

Cookies

A cookie is a small file that is stored on a user’s computer. Among other things, cookies enable the Web Services and the Application services to store Preferences Data, as further described in this Privacy Policy. The Web Services and the Applications services may use different types of cookies and always will let you know before use them.

Other relevant privacy information

If you choose to post Information on blogs or forums on the Websites, it will not be private. Once the Information is posted, other users may copy or store it.

This privacy policy only applies to personal data collected through our website or the Application, but this website contains links to other websites. We are not responsible for the privacy practices of these other websites. That is, when you click on one of these links you are leaving our website, so you should read the privacy policies of those other websites that collect personal data.

According to the LSSI (Law on Information Society Services), beClocked shall not send advertising or promotional communications by email or other means of electronic communication equivalent that had not been previously requested or expressly authorized by the recipients thereof. In the case of Users with whom there is a prior contractual, legal or service relationship, the Data Controller shall be authorized to send commercial communications regarding products or services of the Controller similar to those initially contracted with the customer. In the case that Users want to unsubscribe for receiving the aforementioned communications, they must do so by sending the corresponding will by email to the address: rights@upRing.com.

Bitnami