UPGRD Engagement Privacy Policy

Last updated: 15.10.2020

This Privacy Policy is applicable to the personal data processed by Retouch Group Oy (“UPGRD” or “we”) relating to the visitors, users, service providers and/or customers (“User” or “you”) of our browser enabled engagement platform accessible via engagement.upgrd.io and campaign.upgrd.io and/or any related services and/or products ( hereinafter jointly referred to as “Services”). Through our Services, Users may upload their own digital photos in order to create enriched and personalized transformations thereof made via the Services.

The purpose of this Privacy Policy is to provide Users with information about the processing of their personal data in accordance with the information obligations set in Articles 13 and 14 of the General Data Protection Regulation 2016/679 (GDPR). To this extent, we shall describe hereunder the types of personal data we may collect through the Services and how, and for what purposes we may process such personal data. Furthermore, we shall inform you about the rights and choices available to you as regards to our processing of your personal data.

Please note that this Privacy Policy only applies to processing carried out by UPGRD as a data controller. This Privacy Policy does not address, and we are not responsible for, the privacy and data processing practices of any third-party websites’, products and services regardless if they link to our Services. Such third parties may process personal data as data controllers in accordance with their own privacy policies.

This Privacy Policy may be updated if required in order to reflect the changes in data processing practices or otherwise. The current version can be found on our website https://upgrd.io/legal/engagement/privacy-policy.

Controller’s Contact details:

Name: Retouch Group Oy

Company ID: 2499104-8

Mail address: Lokipolku 5, 00980 Helsinki, Finland

E-mail address: info@upgrd.io

Website: www.upgrd.io

We kindly urge Users to use the addresses set out above for all correspondence related to the processing of personal data and the execution of Users’ rights under the applicable data protection legislation.


The personal data collected and processed by us can be divided into three (3) general data categories: (i) User data; ( ii) Transaction data; and (iii) Analytics data.

User data is primarily obtained directly from the User in connection with the use of the Services. This refers to situations where you e.g. choose to upload a digital photo of yourself and/or another person to the Services, fill out an order form through the Services, subscribe to a newsletter and/or provide correspondence to our customer service.

Analytics data may be collected automatically as you use the Services. Although we do not normally use Analytics data to identify individuals, sometimes individuals can be recognized from it, either alone or when combined or linked with User data. In such situations, Analytics data shall also be considered to be personal data under applicable laws and we will treat the combined data as personal data, and process such data in accordance with this Privacy Policy.

UPGRD may process the following categories of personal data:

User data:

  • digital photograph of a User and/or a third person as provided by a User;
  • consents related to digital photographs;
  • e-mail address;
  • delivery address;
  • marketing opt-ins and opt-outs;
  • information provided as part of your correspondence with us;
  • full name;
  • phone number; and
  • other data you voluntarily choose to provide us with.

Analytics data:

  • IP address;
  • browser type and version;
  • language settings;
  • operating system;
  • device and device identification number, device IMEI;
  • time spent on the Services;
  • country and time zone;
  • interaction with the Services;
  • settings and preferences; and
  • internet service provider.


We use various technologies to collect and store Analytics data and other information when Users visit our Service, including cookies.

Cookies are small text files sent and saved on your device that allows us to identify visitors of our Services and facilitate the use of our Services and to create aggregate information of our visitors. This helps us to improve our Services and better serve our Users. The cookies will not harm your device or files. We use cookies to tailor our Services and the information we provide in accordance with the individual interests of our Users.

Whenever you visit or interact with our Services, we automatically collect certain information about your browser and your interaction with our website via cookies, including (a) IP address, (b) browser and device type, (c) operating system, (d) referring web page, (e) the date and time of page visits, and (f) the pages accessed on our websites. We also use cookies and similar technologies to recognize and improve your use of our websites and to retain records associated with each User, and you will not be able to access certain parts of our websites, including those that require a login, unless your device accepts cookies from us.

Users may choose to set their web browser to refuse cookies, or to alert when cookies are being sent. For example, the following links provide information on how to adjust the cookie settings on some popular browsers:


Google Chrome

Internet Explorer

Mozilla Firefox

Please note that some parts of our Services may not function properly if use of cookies is refused.

We also use Google Analytics to compile Analytics data and reports on visitor usage. For an overview of Google Analytics, please visit Google Analytics. It is possible to opt-out of Google Analytics with the following browser add-on tool: Google Analytics opt-out add-on.


Purposes of processing

To provide our Service and carry out our contractual obligations (legal ground: performance of a contract and legitimate interest)

We process personal data to be able to offer the Services to our Users and to run and maintain our business. Personal data may be processed in order to carry out our contractual obligations towards the User. We may use the data for example to offer essential functionalities of the Services and to provide access to the Services as well as to handle your orders. If you contact our customer service, we will use the information provided by you to answer your questions or solve your complaint.

For our legal obligations (legal ground: compliance with a legal obligation)

We process personal data to enable us to administer and fulfil our obligations under law. This includes data processed for complying with our bookkeeping obligations and providing information to relevant authorities, such as tax authorities.

For claims handling and legal processes (legal ground: legitimate interest)

We may process personal data in relation to claims handling, debt collection and legal processes. We may also process data for the prevention of fraud, misuse of our Services and for data, system and network security.

For communication and marketing (legal ground: legitimate interest)

We may process personal data for the purpose of contacting our Users regarding our Services and for informing Users of any changes to our Services. We may also process personal data to market our Services, for example in the form of sending newsletters.

For quality improvement and trend analysis (legal ground: legitimate interest)

We may process information regarding the use of the Services to improve the quality of our Services, for example by analyzing any trends in the use of our Services. Where possible, we will do this using only aggregated, non-personally identifiable data.

Legal grounds for processing

We primarily process personal data of Users on a contractual basis and to comply with legal obligations. Furthermore, we may process personal data to pursue our legitimate interest to run, maintain and develop our business or to engage in analytics and marketing activities. When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy and e.g. provide you with easy to use opt-out from our marketing communications and use pseudonymized or non-personally identifiable data when possible.

In certain cases, Users may be requested to grant their consent for the processing of personal data. In this event, the legal ground for such processing is your consent. You may withdraw your consent at any time.


App Users’ personal data primarily within the European Economic Area. However, we have service providers in several geographical locations. As such, we, our service providers may transfer personal data to, or access it in, jurisdictions outside the European Economic Area or outside of the User’s domicile.

We will take steps to ensure that the Users’ personal data receives an adequate level of protection in the jurisdictions in which it is processed. We provide adequate protection for the transfers of personal data to countries outside of the European Economic Area through a series of agreements with our service providers based on the Standard Contractual Clauses or other similar arrangements providing appropriate safeguards under applicable data protection legislation.


We do not share personal data with third parties outside of UPGRD’s organization unless one of the following circumstances applies:

For the purposes set out in this Privacy Policy and to authorized service providers

To the extent that third parties (such as our print service partners) need access to personal data to perform the Services, UPGRD has taken appropriate contractual and organizational measures to ensure that personal data are processed exclusively for the purposes specified in this Privacy Policy and in accordance with all applicable laws and regulations and subject to our instructions and appropriate obligations of confidentiality and security measures.

Furthermore, we may provide your personal data to our affiliates or to other authorized service providers who perform services for us (including data storage, printing, accounting or advertising) to process it for us and to payment service provider to process your payments to us.

Please bear in mind that should you provide personal data directly to a third party, such as through a link in the Services, the processing is typically based on their policies and standards.

For legal reasons

We may share personal data with third parties outside UPGRD if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, properties or safety of UPGRD, our Users or the public in accordance with the law. When possible, we will inform Users about such transfer and processing.

For other legitimate reasons

If UPGRD is involved in a merger, acquisition or asset sale, we may transfer personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all Users concerned when the personal data are transferred or become subject to a different privacy policy as soon as reasonably possible.

With your explicit consent

We may share personal data with third parties outside UPGRD for other reasons than the ones mentioned before, when we have the User’s explicit consent to do so. You have the right to withdraw this consent at all times.


UPGRD does not store personal data longer than is legally permitted and necessary for the purposes of providing the Services or the relevant parts thereof. The storage period depends on the nature of the information and the purposes of processing. The maximum period may therefore vary per use.

User data and Transaction data shall be deleted after a reasonable period has lapsed following User’s inactivity with the Services, Thereafter, User data and/or Transaction data may be stored only as long as such processing is required by law or is reasonably necessary for our legal obligations or legitimate interests such as claims handling, legal proceedings, bookkeeping and marketing.

We will store Analytics data relating to the Services approximately thirty (30) days.


Right to access

You have the right to access your personal data processed by us and to request a copy of your personal data. You may contact UPGRD and we will inform what personal data we have collected and what personal data we process regarding you.

Right to withdraw consent

In case the processing of personal data is based on a consent you have granted to us, you may withdraw the consent at any time. Withdrawing a consent may lead to fewer possibilities to use our Services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Right to rectify

You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us.

Right to erasure

You may also ask us to erase your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data.

Right to object

You may object the processing of personal data on grounds relating to your particular situation if such data is processed for other purposes than purposes necessary for the performance of a contract or for compliance with a legal obligation. In case we do not have legitimate grounds to continue processing such personal data, we shall no longer process the personal data.

Right to restriction of processing

You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use our Services.

Right to data portability

You have the right to receive your personal data from us in a structured and commonly used format and to independently transmit those data to a third party.

How to use the rights

The above mentioned rights may be used by sending a letter or an e-mail to us on the address set out above. We may request the provision of additional information necessary to confirm your identity.

We reserve the right to reject requests that are unreasonably repetitive, excessive or manifestly unfounded.


Notwithstanding any consent granted beforehand for the purposes of direct marketing, you have the right to object to and prohibit us from using your personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or by using the unsubscribe possibility offered in connection with any direct marketing messages. Where you object to processing of your personal data for direct marketing purposes, the personal data will no longer be processed for such purposes.


In case you consider our processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection.

In Finland, the local supervisory authority is the Data Protection Ombudsman (www.tietosuoja.fi).


We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability restore the data. We regularly test our systems, and other assets for security vulnerabilities.

Should despite of the security measures, a security breach occur that is likely to have negative effects on your privacy, we will inform you and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.