Digital Transformation Providers

Our Policies

Anti-Corruption and Bribery Policy

Introduction & to whom it applies


UpcoMinds does not engage in corruption and bribery and has a zero-tolerance policy for corrupt or illegal practices. These practices are illegal and criminal offenses and may undermine UpcoMinds’ reputation and lead to investigations, fines and/or other penalties for the company and / or individuals

For UpcoMinds, our position is clear: the offer, payment, authorization, solicitation and acceptance of bribes and other improper advantages is unacceptable, and it is not tolerated by UpcoMinds.

UpcoMinds is committed to conducting all aspects of its business in accordance with the highest legal and ethical standards and expects all employees and other persons acting on its behalf to uphold this commitment.

This Anti-Corruption and Bribery Policy applies to all our employees and directors, as well as our subcontractors under our direct supervision, working for UpcoMinds, directly or indirectly, and any affiliates, and / or joint ventures.


Our commitment

We do not tolerate bribery of any kind, whether to a public official or a private individual. We never offer, provide, or authorize bribes of any kind, including facilitation payments, either directly or indirectly, to a public official and / or a private individual. We never request or accept bribes of any kind, either directly or indirectly. A bribe may be monetary or non-monetary, tangible, or intangible. A bribe may indicatively take the form of, or be facilitated through:

We also expect our business partners to share our commitment to ethical and responsible business practices. We never authorize anyone to engage in bribery or corruption on our behalf, as UpcoMinds prohibits all forms of corruption and bribery by all personnel and any third parties engaged to perform activities or provide goods or services on the UpcoMinds’ behalf.

UpcoMinds expects its employees and subcontractors to speak openly and raise concerns about possible breaches of this policy with the Management of the company or via other available reporting channels. At the same time, UpcoMinds has zero tolerance for retaliation against anyone who speaks openly about conduct they believe is unethical, illegal, or not in line with policies, even if the concern isn’t substantiated, as long as they have not knowingly made a false report.

We take breaches of our policies seriously. Depending on the severity of the breach, consequences may range from a warning to termination of employment.


Dealing with Third Parties

The Company can be held liable if an improper payment is made by a third party on UpcoMinds’ behalf. Third parties may include, for example, consultants, joint venture partners, subcontractors, sales representatives, etc. For this reason, it is very important that UpcoMinds is assured that any third parties acting on its behalf have a good reputation and are aware of the Company’s policies regarding prevention of bribes and other improper payments

All agreements with third parties must be in writing and must contain provisions requiring third parties to comply fully with applicable anti-corruption and anti-bribery laws.

Sustainability Policy

UpcoMinds is Committed to



Guiding Principles:


Practical Steps In order to Put These Principles into Practice

Travel and Meetings


Purchase of Equipment and Consumption of Resources


Working Practices and Advice to Clients

Quality Policy


The term Quality in UPCOM means that services in the field of development, customization, installation, technical support of software products fully cover the needs of customers as these have been presented based on agreed specifications as well as the specifications of the company itself.


The Management UNDERTAKES A COMMITMENT when it comes to Quality Policy which is COMMUNICATED to the company's entire human resources. Moreover, the company ensures such commitment by developing a spirit of general and collective effort among all its personnel and by providing the necessary resources so that all personnel may adhere to the Quality Policy and promote all actions that will continuously advance and improve quality. The company's management also commits in terms of adherence to Greek and European legislation.


The Quality Policy, the objective and feasible targets for quality, the performance indexes for quality and overall continuous suitability, sufficiency and effectiveness of the Quality Management System are revised at least once a year.


In the framework of this Quality Policy the Management has set Quality objectives which are described as follows:


For implementing its Quality Policy, the company adheres to the following principles :


We take our visitors privacy seriously

Privacy Policy (Last updated 11/04/2023)


Thank you for accessing our website, created by Upcom (“company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at

When you use our web site and services, you trust us with your personal information. We take your privacy very seriously and in this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of website and our services. This privacy policy applies to all information collected through our website and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the “Sites”).
Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

What information do you collect?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when registering with our site, such as your name and contact details (email). All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected


Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our website. We automatically collect certain information when you visit, use or navigate our website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, or any other related information about how and when you access our website and other technical information. This information is primarily needed to maintain the security and operation of our website, and for our internal analytics and reporting purposes only.

This Privacy Policy applies only to your use of this website. Our website, may contain links to other websites and we have no control over how your data is collected, stored, or used by these sites. It is advisable that that you must check the privacy policies of any such websites before providing any data to them.

How do you use my information

We process your information for purposes based on legitimate business interests, compliance with our legal obligations, and/or your consent. We use personal information collected via our website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into, with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

Will my Information be shared?

We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations. We only share and disclose your information in the following situations:

Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

With your Consent.

We may disclose your personal information for any other purpose with your consent.

How long do you keep my information?

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law. We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time stated above. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

How do you keep my information safe?

We aim to protect your personal information through a system of organizational and technical security measures. We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to our website is at your own risk. You should only access the services within a secure environment.

What are my privacy rights?

In some regions, such as in the European Union (EU) and the European Economic Area (EEA), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your subscription at any time. In EU and EEA you have certain rights under applicable data protection laws (e.g. GDPR). These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal. If you are resident in the EU and/or European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here:

Do you make update to this policy?

Yes, we will update this policy as necessary to stay compliant with relevant laws. We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

How can I contact you about this policy?

If you have questions or comments about our policies, you may email us at

Πολιτική Επιχειρησιακής Συνέχειας


Η Upcom θεωρεί στοιχείο στρατηγικής σημασίας την εξασφάλιση της επιχειρησιακής συνέχειας σε όλες της τις δραστηριότητες και δεσμεύεται για τη συνεχή βελτίωση του συστήματος επιχειρησιακής συνέχειας.


Η συνολική λειτουργία της εταιρείας διέπεται από τις αρχές που αποτυπώνονται στο Σύστημα Διαχείρισης Επιχειρησιακής Συνέχειας, το οποίο είναι βασισμένο στις απαιτήσεις και τις προδιαγραφές που ορίζονται από το διεθνές πρότυπο ISO 22301:2019.


Βασικοί στόχοι του Συστήματος Διαχείρισης Επιχειρησιακής Συνέχειας είναι:


Η εξασφάλιση της διαρκούς αποτελεσματικότητας και καταλληλότητας του Συστήματος Επιχειρησιακής Διαχείρισης επιτυγχάνεται μέσω διαδικασιών και ελέγχων τόσο των λειτουργικών διαδικασιών όσο και των προμηθευτών – συνεργατών, και μέσω των περιοδικών ανασκοπήσεων.


Η παρούσα Πολιτική έχει γνωστοποιηθεί σε όλους τους εργαζόμενους και συνεργάτες και είναι διαθέσιμη στο κοινό. Ανασκοπείται και αναθεωρείται ετησίως κατά την ανασκόπηση από τη Διοίκηση.

Πολιτική Ασφάλειας Πληροφοριών


Η UPCOM, για τις δραστηριότητες, της δεσμεύεται στην ανάπτυξη και εφαρμογή πολιτικών για την προστασία των πληροφοριών που διαχειρίζεται η εταιρεία από όλους τους κινδύνους, εσωτερικούς και εξωτερικούς και προβαίνει στις παρακάτω ενέργειες:



Η UPCOM δεσμεύεται για την Πολιτική Ασφαλείας την οποία και γνωστοποιεί σε όλο το ανθρώπινο δυναμικό της εταιρείας. Εξασφαλίζει δε τη δέσμευση αυτή καλλιεργώντας το πνεύμα της συνολικής και συλλογικής προσπάθειας σε όλο το ανθρώπινο δυναμικό της εταιρείας και διαθέτοντας όλα τα απαραίτητα μέσα, ώστε όλοι να τηρούν την Πολιτική Ασφαλείας και να προωθούν κάθε ενέργεια που διαρκώς προάγει και βελτιώνει την εμπιστευτικότητα, την ακεραιότητα, την αξιοπιστία και τη διαθεσιμότητα των πληροφοριών.

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