This privacy notice tells you what to expect us to do with your personal information.

What this notice covers:

• Contact details

• What information we collect, use, and why

• Lawful bases and data protection rights

• Where we get personal information from

• How long we keep information

• How to complain

Contact Details

Telephone: +44 7350 293596
Email: contact@uptrail.co.uk

What Information We Collect, Use, and Why

We collect or use the following information for student education and welfare:

• Names and contact details for students/children

• Gender

• Date of birth

• Right to work information

We collect or use the following personal information for dealing with queries, complaints or claims:

• Names and contact details

• Purchase or service history

• Financial transaction information

We collect or use the following information for information updates or marketing purposes:

• Names and contact details

• Marketing preferences

• Website and app user journey information

We collect or use the following information for recruitment purposes:

• Contact details (e.g. name, address, telephone number or personal email address)

• Date of birth

• National Insurance number

• Copies of passports or other photo ID

• Employment history (e.g. job application, employment references or secondary employment)

• Education history (e.g. qualifications)

• Right to work information

• Details of any criminal convictions (e.g. DBS, Access NI or Disclosure Scotland checks)

• Security clearance details (e.g. basic checks and higher security clearance)

We collect or use the following information to comply with legal requirements:

• Identification documents

Lawful Bases and Data Protection Rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights, which are set out in brief below. You can find out more about your rights and the exemptions which may apply on the ICO’s website:

• Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share it with. There are some exemptions which mean you may not receive all the information you ask for. Read more about the right of access.

• Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.

• Your right to erasure – You have the right to ask us to delete your personal information. Read more about the right to erasure.

• Your right to restriction of processing – You have the right to ask us to limit how we use your personal information. Read more about the right to restriction of processing.

• Your right to object to processing – You have the right to object to the processing of your personal data. Read more about the right to object to processing.

• Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.

• Your right to withdraw consent – When we use consent as our lawful basis, you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our Lawful Bases for the Collection and Use of Your Data

For student education and welfare:

• Consent – We have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. You have the right to withdraw your consent at any time.

For dealing with queries, complaints or claims:

• Consent – We have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. You have the right to withdraw your consent at any time.

For information updates or marketing purposes:

• Consent – We have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. You have the right to withdraw your consent at any time.

For recruitment purposes:

• Consent – We have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. You have the right to withdraw your consent at any time.

To comply with legal requirements:

• Consent – We have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. You have the right to withdraw your consent at any time.

Where We Get Personal Information From

• Directly from you

• Publicly available sources

How Long We Keep Information

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, including to meet legal, regulatory, or contractual obligations. The specific retention periods are as follows:

• Candidate and Student Data (e.g. CVs, application details): Retained for up to 1 year after the last meaningful interaction, unless a longer period is required by law or explicitly agreed.

• Client Data (e.g. contracts, business communications): Retained for up to 2 years after the end of the business relationship to comply with legal and accounting requirements.

• Complaint or Claim Information: Retained for up to 2 years from the resolution of the issue.

• Marketing Preferences and Contact Information: Retained until the individual withdraws consent or unsubscribes. After this, only minimal data is kept to comply with opt-out requests.

After the applicable retention period, personal information is securely deleted or anonymised. For more information on how long we store your personal information or the criteria we use to determine this, please contact us using the details provided above.

How to Complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) if you are unhappy with how we have handled your data. More information is available on the ICO’s website.

Last Update: 29-06-2025