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.
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.
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.
Travel and Meetings
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 firstname.lastname@example.org.
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.
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.
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:
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.
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.
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: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
If you have questions or comments about our policies, you may email us at email@example.com