1. Introduction

This Privacy Policy explains how Upper Room (“we,” “us,” or “our”) collects, uses, discloses, and protects personal data when you visit and interact with this website (“Website”).

We are committed to protecting your privacy and processing your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the UK GDPR, and applicable privacy laws.

By using this Website, you acknowledge that your personal data may be processed as described in this Privacy Policy.

2. Data Controller

The data controller responsible for the processing of personal data on this Website is:

Upper Room
Email: hello@upperroommarketing.com

If you have any questions regarding this Privacy Policy or how your personal data is processed, you may contact us at the email above.

3. What Personal Data We Collect

We may collect and process the following categories of personal data:

a) Information you voluntarily provide

When you submit a contact form, inquiry, book a call, or otherwise communicate with us, we may collect:

• Full name
• Email address
• Phone number (if provided)
• Company name (if provided)
• Message content
• Any other information you voluntarily submit

b) Technical and usage data

When you access the Website, we may automatically collect:

• IP address
• Browser type and version
• Device type
• Operating system
• Referring URL
• Pages visited
• Date and time of access
• General geographic location (country / region)

c) Cookies and similar technologies

We may use cookies and similar technologies to ensure Website functionality, improve performance, and (subject to your consent) analyze Website traffic.

See Section 8 (“Cookies”) for more details.

4. Purposes of Processing and Legal Basis

We process personal data for the following purposes and under the following legal bases:

PurposePersonal DataLegal BasisResponding to inquiries submitted via formsName, email, phone, messageArt. 6(1)(b) GDPRCommunicating with usersContact details, message contentArt. 6(1)(b) GDPROperating and securing the WebsiteIP address, technical dataArt. 6(1)(f) GDPRPreventing abuse, spam, fraud, and security incidentsIP, technical identifiersArt. 6(1)(f) GDPRAnalytics and performance measurement (if enabled)Usage data, cookie identifiersArt. 6(1)(a) GDPRCompliance with legal obligationsAny relevant dataArt. 6(1)(c) GDPR

Where we rely on consent, you may withdraw your consent at any time.

5. How We Use Your Data

We use your personal data to:

• respond to your inquiries and requests;
• communicate with you regarding services or collaboration;
• provide and improve Website functionality;
• ensure Website security and prevent abuse;
• monitor Website performance and usage (where consent is provided);
• comply with legal and regulatory obligations.

We do not sell your personal data.

6. Sharing of Personal Data

We may share your personal data with trusted third-party service providers (“processors”) who help us operate the Website and provide our services.

These may include:

• Webflow (hosting / CMS / infrastructure)
• Google Analytics (analytics, only if enabled and only after consent)
• Email providers (for communication and form delivery)
• CRM tools (if connected)
• Automation tools such as Zapier / Make (if connected)
• Spam / security filtering tools

All third-party processors are required to process data in accordance with applicable data protection laws and appropriate contractual safeguards, including Data Processing Agreements where required under Article 28 GDPR.

7. International Data Transfers

Some of our service providers may process personal data outside the European Economic Area (EEA), including in the United States.

Where such transfers occur, we ensure appropriate safeguards are in place, such as:

• European Commission Standard Contractual Clauses (SCCs);
• adequacy decisions;
• other legally recognized safeguards.

8. Cookies

This Website may use cookies and similar technologies.

a) Strictly necessary cookies

These cookies are required for the Website to function properly and do not require consent.

b) Analytics cookies

Analytics cookies help us understand how visitors use the Website and improve performance.

These cookies are only used after you provide explicit consent through the cookie banner.

c) Managing cookies

You may accept, reject, or manage your cookie preferences through the cookie banner shown on your first visit.

You may also adjust browser settings to block or delete cookies.

9. Data Retention

We retain personal data only for as long as necessary for the purposes described in this Privacy Policy, including:

• Contact form submissions: up to 12 months after last communication
• Business correspondence: up to 3 years where relevant
• Technical logs: typically up to 90 days
• Analytics data: according to analytics provider retention settings and consent preferences

We may retain data longer where required by law or for the establishment, exercise, or defense of legal claims.

10. Your Rights Under GDPR

Under GDPR, you have the right to:

• request access to your personal data;
• request correction of inaccurate or incomplete data;
• request deletion of your personal data;
• request restriction of processing;
• object to processing based on legitimate interests;
• withdraw consent at any time;
• request data portability;
• lodge a complaint with a supervisory authority.

To exercise your rights, contact us at: hello@upperroommarketing.com

We will respond in accordance with applicable legal deadlines.

11. Data Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, disclosure, alteration, or destruction.

However, no method of transmission over the Internet is completely secure, and we cannot guarantee absolute security.

12. Third-Party Links

This Website may contain links to third-party websites.

We are not responsible for the privacy practices or content of third-party websites. We encourage you to review their privacy policies separately.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect legal, technical, or operational changes.

Any updates will be posted on this page with a revised “Last updated” date.

14. Contact

If you have any questions about this Privacy Policy or the processing of your personal data, please contact:

Upper Room
Email: hello@upperroommarketing.com