Privacy Policy

IN BRIEF: We use only the data needed to respond to you, provide our services, keep the website secure, and improve your experience. We do not sell your personal data. You can ask what data we hold about you or request to exercise your rights by contacting dpo@upsociative.com.

This Privacy Policy (the “Policy”) sets forth the terms under which UpSociative processes and protects personal data, including the categories of data processed, the purposes and lawful bases of processing, the recipients to whom data may be disclosed, and the manner in which data subjects may exercise their rights.
This Policy applies to personal data processed in connection with the UpSociative website, contact forms, business communications and the provision of services. It must be read together with any specific privacy notice issued in respect of a particular processing activity; where applicable, such specific notice must supplement this Policy.

1. Identity of the Data Controller
The controller responsible for the processing of personal data is UPSOCIATIVE CONSULTORES LIMITADA (“UpSociative”), with registered address at Dr. Manuel Barros Borgoño 236, Providencia, Santiago Metropolitan Region, Chile.

Privacy contact: dpo@upsociative.com
Website: upsociative.com
The company’s legal name is UPSOCIATIVE CONSULTORES LIMITADA.

2. Categories of Personal Data Processed
UpSociative may process personal data voluntarily provided by the data subject, together with certain information generated through use of the website. Depending on the nature of the interaction, such data may include:

Identification and contact data: name, telephone number, email address, company, or job title.
Your communications: inquiries, messages, information from a diagnostic meeting, and files you choose to share.
Business and service information: interests, preferences, quotations, requests, and information needed to manage our business or contractual relationship.
Technical and browsing data: IP address, device type, operating system, browser, pages visited, date and time of access, and information collected through cookies or similar technologies.
We do not request sensitive data through our website. Please do not include sensitive information, such as health or biometric data, beliefs, or sexual orientation, in free-text form fields. If we exceptionally need to process this type of information, UpSociative must provide specific notice and apply the appropriate legal basis and safeguards.

3. Sources of Personal Data
Personal data may be obtained from the following sources:

Directly from you, when you complete a form, contact us, attend a meeting, or engage our services.
Automatically, when you visit the website and consent to cookies or technologies that are not strictly necessary.
From legitimate sources, such as a company or person who provides us with your data to arrange a meeting or service, always as permitted by applicable law.

4. Purposes of Processing
Personal data must be processed solely for specified, explicit and legitimate purposes, including:

To respond to inquiries, arrange meetings, and prepare assessments or proposals.
To manage our business relationship and provide privacy and data protection consulting services.
To send operational communications relating to a request or service.
To send news, invitations, or information about events when we have your consent or another valid legal basis. The data subject may unsubscribe at any time.
To maintain the security, availability, and proper operation of the website.
To measure website use and improve its content and user experience, where applicable and in accordance with your cookie preferences.
To comply with legal obligations, respond to requests from competent authorities, and establish, exercise, or defend legal claims.

5. Lawful Bases for Processing
Subject to the purpose of the processing and the requirements of applicable law, UpSociative will rely on one or more of the following lawful bases:

Your consent, for example, when you accept non-essential cookies or authorize marketing communications.
Taking steps at your request before entering into a contract and performing a contract.
Compliance with legal obligations.
Our legitimate interests, where permitted, for example, to protect the website, prevent misuse, and improve our services, after considering your rights and interests.
Where processing is based on consent, the data subject may withdraw that consent at any time. Such withdrawal will not affect the lawfulness of processing undertaken prior to its withdrawal.

6. Cookies and Similar Technologies
A cookie is a small data file stored on a user’s device for the purpose of retaining information concerning a website visit. Where appropriate, UpSociative may also use comparable technologies, including tags and pixels.
Our website may use the following categories:

Strictly necessary cookies: enable essential functions such as security and navigation. They cannot be disabled through our preference manager.
Performance cookies: allow us to count visits and traffic sources so that we can measure and improve the performance of our website.
Functionality cookies: remember choices to provide a more personalized experience.
Advertising cookies: may be placed through our website by advertising partners. They are used to build a profile of your interests and show you relevant advertisements on other websites based on the identification of your browser and internet device. If you do not allow these
cookies, you will receive less advertising tailored to your interests.
Social media cookies: may be set by social media services integrated into the website to enable users to share content with their contacts. If such cookies are not permitted, the relevant sharing tools may be unavailable.
Cookies that are not strictly necessary will be activated only after the user’s prior consent has been
obtained, where required by applicable law. Consent may be granted, refused or withdrawn, and preferences may be amended at any time through the “Cookie Preferences” mechanism available on the website.

7. Retention of Personal Data
Personal data must be retained only for the period reasonably necessary to fulfill the purposes for which it was collected. Thereafter, it may be blocked or otherwise placed under restricted access for the duration of any applicable statutory limitation period in order to address potential legal liabilities.
Upon expiry of such period, the data must be securely erased or irreversibly anonymized.
Specific retention periods may vary depending on the type of relationship, the nature of the data, and applicable legal obligations. Where processing is based on your consent, UpSociative must also take its withdrawal into account unless another legal reason requires us to retain the information.

8. Disclosure and Recipients of Personal Data
UpSociative does not sell personal data. Personal data may be disclosed only where necessary and lawful, including to:

Service providers that support our operations, for example, website hosting, email, customer relationship management, analytics, security, or support, and that process data under our instructions and confidentiality and security obligations.
Professional advisers where necessary and subject to duties of confidentiality.
Authorities, courts, or other third parties where required by law, in response to a valid request, or where necessary to establish, exercise, or defend legal claims.
Where a third party independently determines the purposes and means of processing, it will act as an independent controller and must provide you with information about its own processing activities.

9. International Transfers of Personal Data
Some technology providers may process or store data outside Chile. Before making an international transfer, we assess the applicable rules and adopt the measures or safeguards required to protect the information, such as contractual clauses, confidentiality commitments, security controls, or other legally recognized mechanisms.
The data subject may request general information about the categories of recipients and applicable safeguards by contacting dpo@upsociative.com.

10. Security of Personal Data
UpSociative implements appropriate administrative, technical and organizational measures proportionate to the risks associated with the processing, with a view to protecting personal data against unauthorized or unlawful access, loss, alteration, disclosure or destruction. Such measures are subject to periodic review and improvement.
No information system can be guaranteed to be entirely secure. Where a personal data security incident is identified, UpSociative must respond in accordance with its internal procedures and any notification or remediation obligations imposed by applicable law.

11. Rights of Data Subjects
Subject to applicable law, data subjects may exercise the rights available in respect of their personal data, including the following:

Access: find out whether we process your data and obtain information about it or a copy.
Rectification: correct inaccurate, outdated, or incomplete data.
Erasure or deletion: ask us to delete your data where applicable.
Objection: ask us to stop processing your data in the circumstances provided by law.
Restriction: request the temporary suspension of processing where applicable.
Data portability: receive certain data in a structured, commonly used format or request its transmission, where applicable.

12. Procedure for Exercising Data Subject Rights
Send your request to dpo@upsociative.com and include:
1. Your name and a means of contacting you.
2. The right you wish to exercise and a clear description of your request.
3. The information needed to identify the data concerned.
For the purpose of protecting personal data, UpSociative may require reasonable evidence to verify the applicant’s identity or authority to act on behalf of another person. UpSociative must respond within the period and in the manner prescribed by applicable law. Where a request cannot be granted in whole or in part, UpSociative must state the applicable grounds, unless otherwise provided by law.

13. Personal Data Relating to Minors
This website and our services are intended for professionals and organizations. We do not seek to collect personal data from children or young people through the website. If you believe that a minor has provided us with information without the required authorization, please contact us so that we can review it and take appropriate action.

14. Users Located Outside Chile
UpSociative is established in Chile. If you access the website from another country, foreign law may apply depending on factors such as our activities, that law’s territorial scope, and the nature of the processing. Accessing the website from a particular country does not, by itself, necessarily make that country’s law applicable.
Where applicable law confers additional rights, the data subject may request their exercise by contacting dpo@upsociative.com. UpSociative must assess each request in accordance with the relevant legal framework.

15. Applicable Chilean Data Protection Framework
As of the date of this version, processing in Chile is governed by Law No. 19,628 on the protection of private life and other applicable rules. Law No. 21,719, published on December 13, 2024, introduces comprehensive reform and enters into force on December 1, 2026. UpSociative has prepared this Policy with that regulatory transition in mind, without prejudice to any further adjustments required once the new framework becomes fully enforceable.

16. Amendments to this Policy
UpSociative may update this Policy when our practices, services, technologies, or applicable rules change. UpSociative must publish the current version and state the date of the latest update. If a change is material, UpSociative must endeavor to provide prominent notice or obtain fresh consent where appropriate.

17. Contact Information
If you have questions about this Policy or how we process your data, please contact us:

UpSociative.
Address: Dr. Manuel Barros Borgoño 236, Providencia, Región Metropolitana, Chile.
Privacy: dpo@upsociative.com.

Privacy Policy

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