Legal Terms

LEGAL TERMS

Welcome to UPON Group’s website

You are currently in the Legal Terms section of the UPON Group’s site.

By using our website, you agree to the terms and conditions laid out in our legal notice, privacy policy, and cookie policy. These documents outline the rights and responsibilities of both parties concerning the information shared and gathered through our site.

Our legal notice defines the general terms and conditions of our website’s use, including intellectual property rights and liability limitations.

Our privacy policy details how we collect, use, and share your personal information. Protecting your privacy is paramount to us, and we strive to ensure your data is handled securely and responsibly.

Lastly, our cookie policy elaborates on how we employ cookies on our site and how you can manage their use.

It’s crucial that you read and understand these documents before using our website. Should you have any questions or concerns about these terms, please don’t hesitate to get in touch with us.

UPON Group Privacy Policy

1. SCOPE OF THE DOCUMENT:

Through this communication, NORTH POINT, S.L., (hereinafter referred to as NORTH POINT), with its registered office at Enric Borras Street, 15 – 17 BJ PTA. 2 08912 Badalona (Barcelona), and acting as the representative company of UPON Group, informs the users of http://www.upongroup.com (hereinafter referred to as the Website) about its data protection policy. This is so that they can freely and voluntarily decide whether they wish to provide NORTH POINT with the personal data required in subscriptions, registrations, or when filling out online forms or via emails.

This Privacy Policy, together with the one included in the various forms available on the Website at any given time, applies to personal data collected when using the services provided by NORTH POINT through http://www.upongroup.com, as well as data collected via NORTH POINT applications or services that reference this Privacy Policy or contain a link to it, regardless of the device used to access the Website or use the services.

2. CATEGORIES OF PERSONAL DATA:

The personal data that NORTH POINT may collect and process include:

-Contact information that allows us to communicate with you, such as your name, position, title or form of address, age, username, postal address, telephone numbers, email address, or other addresses to which we can send you messages, company information, or registration data provided on the Website.

Concerning the information collected through the Website, we inform you that fields marked with an asterisk on the various data collection forms are mandatory. If you do not provide the requested data in these fields, NORTH POINT may, at its discretion, choose not to process the corresponding inquiry or service requested by the user.

When filling out any form with your personal data, the user guarantees the authenticity, accuracy, and truthfulness of all the information provided, committing to keep the personal data they provide updated so that it reflects their actual situation at all times. The user is solely responsible for any false or inaccurate statements and the damages that such may cause to NORTH POINT.

-Information that allows us to maintain a business relationship with you, such as the types of products and services that might interest you, your contact and language preferences, creditworthiness data, marketing preferences, and demographic data.

-Information about how you interact with us, including purchases, inquiries, customer account data, order and contract data, delivery data, financial and billing data, tax data, transaction history and correspondence, and information about how you use and interact with our website.

-Information related to the installation, configuration, and operation of systems and events for which you request our services, as well as data recorded during such events.

-Information related to the spaces UPON Group occupies on social networks to provide information of interest to its customers and users. Users who follow, visit, or interact with our spaces or page on social networks are giving us their consent to process their personal data within these networks. This data is not incorporated into any personal data file. The processed information is only what the user makes public, and they can configure it at any time in the privacy policies and terms of use for which the respective social network owners are responsible. These rights can be exercised with us at the email address Legal@ineural.es only if we have some control over the personal data you publish on social networks. You can access the privacy policies of social networks at:

https://www.facebook.com/policy.php

https://twitter.com/privacy

https://www.google.es/intl/es/policies/privacy/

https://www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv

3. LEGAL BASES FOR DATA PROCESSING:

-Execution of contracts signed with our clients and suppliers.

-The legitimate interest of NORTH POINT, which arises from the development of its usual business activity.

-Compliance with our legal obligations under applicable legislation.

-Consent, where mandatory and within the limits of applicable law.

-Protection of vital interests of individuals, where mandatory and within the limits of applicable law.

4. PURPOSES OF DATA PROCESSING

The data collected by NORTH POINT are intended for the following purposes:

-To register your data in the requested service, attend to your inquiries, complaints or information requests, and ensure the fulfillment, maintenance, development, control, and improvement of any relationships you might have with NORTH POINT.

-To serve your orders for products or services and associated activities, which might include product or service delivery, customer service, accounting and billing management, technical support and training, product safety and update notifications, technical support related to our products, and other services related to the purchasing process.

-To fulfill our contractual obligations and manage our relationship with you, which includes interacting with you, analyzing and improving the products and services we offer, informing you about our products or services, and about special offers and promotions.

-To ensure the security of our website http://www.upongroup.com, networks, systems, and facilities, and to protect ourselves against fraudulent activities.

-To manage our business operations, including payment processing, accounting, product development, contract management, website administration, order delivery, corporate governance, conducting audits, reporting, and regulatory compliance.

Additionally, upon obtaining your consent, either at the time of data collection or later, NORTH POINT may use the information provided by you for any of the following purposes:

To monitor, evaluate and analyze our market, customers, products, and services (including asking your opinion about our products and services and conducting customer surveys).

For the segmentation of your data and creation of profiles or “profiling” to send you personalized information about NORTH POINT products and services. This process might involve combining the information we collect about you through the Website with data you provide or have provided through other means or lawfully provided to us by third parties.

For the organization and management of prize draws, contests, promotions, or special offers.

In this way, based on the given consent, we can send you this information using any of the following means:

  • Email;
  • Phone;
  • Postal mail;
  • Any other equivalent means we deem appropriate at any given time.

5. RECIPIENTS OF PERSONAL DATA

The recipients of the personal data collected by NORTH POINT can be:

-Third parties: we might resort to other entities to provide services and perform functions on our behalf. In such cases, we might provide them with personal data for the fulfillment of their obligations. Any personal data processing activity will be specified in our instructions and will be in accordance with the purposes for which the data were collected.

-In compliance with the law: due to legal requirements, we might also provide personal data to public or judicial authorities, national or local security forces, and other public institutions, including the institutions and courts of the countries where your information is stored, which might be located outside your country of residence. Where permitted by law, we might disclose such data to third parties (including law firms and legal consultancies) when necessary for the introduction, execution, or defense of legal claims, or to exercise our rights and protect our assets or the rights, property, or security of others, as well as to enable external audits, compliance, and corporate governance functions.

-Mergers and acquisitions: in the event of a sale, merger, liquidation, dissolution, or similar procedure, personal data may be transferred to the party acquiring all or part of NORTH POINT’s assets or securities or its business units.

-Affiliates: we might also transfer the aforementioned information to NORTH POINT’s affiliates or share it with them, in accordance with applicable law.

6. INTERNATIONAL TRANSFERS

North Point disclaims any responsibility arising from the information published on its website, as long as this information has been manipulated or introduced by a third party not related to it (for example, in forums, chats, blogs, comments, etc.). However, in compliance with the provisions of the LSSI-CE, North Point makes itself available to all users, authorities, and security forces to remove or, where appropriate, block any content that might violate national or international laws, third-party rights, or public order and morality, reporting the facts to the competent authorities if necessary.

Should a user believe there is content on the Website that could be classified in this manner, they are kindly requested to notify the Website administrator immediately.

7. DATA RETENTION

We will retain your personal data as long as necessary to fulfill the purpose for which they were collected, typically for the duration of any contractual relationship and any subsequent period required or permitted by applicable law.

8. PROTECTION OF PERSONAL DATA

NORTH POINT commits to maintaining the privacy of its customers and users by using legitimate information processing procedures in accordance with applicable data protection laws.

To protect these personal data, NORTH POINT implements suitable technical, physical, and organizational measures reasonably designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, and any other unlawful form of processing. Access to personal data is restricted to authorized recipients and only to the extent they need to know.

9. LINKS

Our Website may contain links to third-party websites outside of our control. We are not responsible for the security or privacy of any information collected on websites or other services outside of our control. You should exercise caution and review the applicable privacy policies of the third-party websites you use.

10. YOUR RIGHTS

You have the right to request access to your data, as well as rectification or updating of incorrect or outdated personal data by contacting us at Legal@ineural.es. o the extent permitted by applicable law, you can request the deletion of your personal data, limit its processing as far as it concerns you, and object to its processing.

11. CONSENT AND WITHDRAWAL OF CONSENT

By providing us with your personal data, you understand and agree that we can collect, process, transfer to other countries, and use such information as specified in this Privacy Statement. Where required by applicable law, we will seek explicit consent. If you do not agree with the practices described in the Privacy Policy, you should not access the Website or use the Services. At any time, you can oppose the use of your personal data for direct marketing activities or withdraw, at no cost, any previously granted consent for a specific purpose. To do this, you must contact us at Legal@ineural.es attaching a copy of your ID or equivalent official document proving your identity.

12. CHANGES TO OUR PRIVACY STATEMENT

NORTH POINT reserves the right to change, modify, and update this Privacy Statement at any time.

Please consult it periodically to ensure you are aware of the latest version. By accessing the website or using our services after we have made such a modification, you will be accepting the new practice(s) identified in the update.

Effective date of this Privacy Statement: April 5, 2023.

Cookie Policy

COOKIE NOTICE

When you visit our website, we may automatically record certain information using technologies such as cookies, pixel tags, browser analytics tools, log files located on servers, and web beacons. In many cases, the information we collect through cookies and other tools is used in a non-identifiable manner, i.e., without referencing any personal data. Below you will find information about what cookies are, types of existing cookies, which ones are used on this website, and how you can disable cookies in your browser.

WHAT ARE COOKIES?

Cookies are small text files that websites transfer to your computer’s hard drive or other device through the browser when you visit their pages. We may use cookies to enhance navigation and login processes on pages, adapt visitor preferences, and improve the functionality of our websites.

They also serve to monitor performance, gather information about how our websites are used, and carry out relevant analysis. They can also be used to manage website functionality, allowing us to enhance the user’s visit efficiency, for instance, by remembering their language preferences, as well as their password and login details.

WHAT TYPES OF COOKIES ARE THERE?

Based on the entity that manages the domain from which cookies are sent and processes the data obtained, there are two types: first-party cookies (used only by the owner of this website) and third-party cookies (also used by the service provider).

Another classification exists based on how long cookies are stored in the client’s browser. They can be session cookies (deleted from the device when leaving the website) or persistent cookies (remain on the device for a certain time or until manually deleted by the user).

Lastly, there’s another classification with five types of cookies based on the purpose of the data obtained: technical cookies, personalization cookies, analysis cookies, advertising cookies, and behavioral advertising cookies.

Technical Cookies

These allow users to navigate through a website, platform, or application and use its various options or services, such as controlling traffic and data communication, identifying the session, accessing restricted areas, requesting registration or participation in an event, employing security features during browsing, storing content for video or audio dissemination, or sharing content via social media.

Personalization Cookies

These allow users to access services with some general, predefined characteristics based on a series of criteria in the user’s device, such as language, browser type used to access the service, regional settings from where the service is accessed, etc.

Analysis Cookies

These allow the responsible party to monitor and analyze the behavior of users on the websites linked to them. The information gathered using these cookies is used to measure the activity on websites, apps, or platforms, and to create user browsing profiles of these sites, applications, and platforms, with the goal of introducing improvements based on the data analysis of the service usage by the users.

Advertising Cookies

Whether processed by us or third parties, these allow us to manage the available advertising spaces on the website as effectively as possible, tailoring the ad content to the requested service or the use of our website. For this, we can analyze your internet browsing habits and show you advertising related to your browsing profile.

Behavioral Advertising Cookies

These enable the most efficient management of advertising spaces included on the website. These cookies store information about user behavior obtained through continuous observation of their browsing habits, allowing the development of a specific profile to display advertising based on it.

WHAT TYPES OF COOKIES DOES THIS WEBSITE USE?

Our server log files might gather information on how users utilise websites (usage data). This information may encompass the user’s domain name, language, browser type and operating system, the Internet Service Provider, the IP (Internet Protocol) address, the website or link through which the user arrived at our website, as well as the site they visited after leaving ours, and the duration of their stay on our pages. We may monitor and utilise this usage data to measure the website’s performance and activity, to enhance the design and functionality of its pages, or for security purposes.

We might also employ pixel tags and web beacons. These are tiny graphic images placed on the site’s pages or in our electronic mails, which allow us to determine whether the user has carried out a particular action. When one accesses these pages, or opens or clicks an email, these elements indicate that such action has been executed. These tools aid us in measuring the response to our communication activities, and in ameliorating our websites and promotions.

There’s a possibility that we use Flash cookies, also known as LSO (Local Stored Objects), and similar technologies to personalise and enhance your online experience. Adobe Flash Player is an application that facilitates the rapid development of animations, video clips, and other dynamic content. We utilise Flash cookies for security reasons and so that browsers might recall settings and preferences similarly to how they do with browser cookies, though Flash cookies utilise a different interface. To manage Flash cookies, visit Adobe’s website or http://www.adobe.com. We might employ Flash cookies or similar technologies for segmentation processes based on behavioural patterns or to display adverts based on user interests.

Where required by applicable law, the website will ask you to accept specific cookies and similar technologies before we use or install them on your computer or other device. You can adjust your browser settings to block cookies or alert you upon receiving any, delete installed cookies, or browse our website using the browser’s anonymous usage setting.

Each browser operates differently; the ‘Help’ function will guide you on how to do so:

Internet Explorer

Firefox

Chrome

Safari

Furthermore, you can also manage the cookie storage in your browser through tools such as:

Ghostery

Your online choices

Should you disagree with our manner of using cookies or other technologies that store information on your device, you ought to adjust your browser settings accordingly. Please bear in mind that certain elements of our website might not operate correctly if you decline cookies or such technologies.

Shared Data and Request for No Browser Traffic Tracking

Since we do not track (nor do we permit others to) visitors on our website, we do not process browser “do not track” signals. For more information about these signals and the “do not track” feature, please visit All about DNT.

Linked Sites

Our website might contain links to third-party websites (“linked sites”). We do not necessarily review, control, or scrutinise such sites. Each linked site may have its own terms of use and privacy statements, and users should be aware of and adhere to such terms when visiting their pages. We are not responsible for the policies and practices of any linked site, nor for any subsequent links they might contain. Featuring links on our sites does not indicate our endorsement of the linked sites nor of any particular company or service, and we encourage users to peruse the terms of use and statements of linked sites before using them.

Minors

Our websites are not aimed at a young audience and we do not intentionally solicit personal data from minors or market products to them. If we discover that a minor has provided their personal details via our website, we will remove it from our system.

Google Analytics

We might utilise Google Analytics to collect information regarding your activity on our site, such as the pages you visit, links you click, and searches you make. We may use this information to produce reports and enhance our sites. Cookies gather information anonymously, including the number of visitors accessing the website, where those visitors originate from, and the pages they’ve visited. Your browser forwards the information generated by the cookies and your current IP address to Google’s servers situated in the United States and other countries, where it’s stored. Google will use this information on our behalf to evaluate your use of this website as described above.

The IP address logged by Google Analytics won’t be associated with any other data collected by Google. For more insight about the data gathered via Google Analytics, please visit the Protección de datos de GOOGLE ANALYTICS Data Protection website.

You can prevent these cookies from being activated by adjusting your browser settings appropriately. If you do, you might not be able to use all functionalities of our website. You can download the Google Analytics Browser Opt-out Add-on here.

Google Remarketing Technology

Our website might employ Google’s remarketing technology. This technology enables users who have previously utilised our services online and shown interest in them to view targeted advertising on websites within Google’s partner network. It also permits us to direct advertising towards users with interests akin to those of our website visitors. The information generated by the cookie about website usage will be transmitted and stored on Google’s servers in the United States. In cases of IP address transmission, it’ll be truncated to the last three digits.

Using cookies allows for user behaviour analysis on a website, and to present them with recommendations and targeted advertising based on their interests. If you prefer not to receive targeted advertising, you can deactivate the use of cookies for this purpose via Google’s page.

Alternatively, users can employ third-party services to deactivate cookie use. For this, they can visit the Networking Advertising Initiative websites.

Please note that Google has its own data protection policy, independent of ours. We assume no responsibility or liability for their policies and procedures. Before using our websites, kindly read Google’s Privacy Policy.

Facebook Conversion Tracking

Our website might utilise the conversion tracking pixel service provided by Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA (“Facebook”). This tool allows us to monitor the actions of users after they’re redirected to a provider’s website post-clicking on an advertisement on the social network. This way, we can assess the effectiveness of Facebook advertisements for statistical and market research purposes.

The collected data remains anonymous, meaning we cannot access the personal data of any specific user. However, Facebook stores and processes this collected data. Specifically, it may link this data to your Facebook account and use it for its own advertising actions according to the company’s published data usage policy. Facebook conversion tracking also lets the social network and its commercial partners show you advertisements both inside and outside of Facebook.

Furthermore, a cookie will be stored on your computer for this purpose. Only users above the age of 13 can grant permission. If you wish to revoke your permission, please click here.

Conversion Tracking by LinkedIn

Our website may use the conversion tracking service (Insight Tag information label) offered by LinkedIn Corporation, 222 2nd St, San Francisco, CA 94105, United States. The LinkedIn Insight Tag information label creates a unique LinkedIn cookie in the visitor’s browser that allows the collection of data related to our website visits by members, such as the URL, referrer, IP address, browser and device characteristics (user agent), timestamp, and page events (such as page views). Information about post-click conversions and visit ratios to campaigns advertised on LinkedIn allows us to evaluate the impact and performance of our advertising investment.

LinkedIn does not share personal data with the website owner. It only provides reports (in which the user is not identified) about the website audience and ad performance. LinkedIn also offers retargeting of website visitors, allowing the site owner to display customized ads outside of their website using this data, but without identifying the member. In addition, LinkedIn uses non-identifying user data to enhance ad relevance and reach members regardless of which devices they use. LinkedIn members can control the use of their personal data for advertising purposes through their account settings.

Conversion Tracking by Twitter

Our website may use the conversion tracking service (conversion tag) offered by Twitter Inc., 1355 Market St. Ste. 900 San Francisco, CA 94103, United States. This tool allows us to measure the return on investment by tracking user actions after they see our ads on Twitter or interact with them. Twitter’s conversion tracking attributes conversions beyond the last clicked link, including actions driven by all types of ad interactions (such as clicking on links, retweeting, or liking) and impressions. It provides information about device identifiers along with the interests or other characteristics of a device or the person using it to help us decide whether to display an ad on that device or undertake marketing activities, brand analysis, interest-based advertising, or similar.

The information we receive does not include the name, email address, phone number, or Twitter username, but some agreements allow this information to be linked to other personal information if you have previously given us your consent.

The data provided by Twitter is non-personal, such as aggregated information that includes the total number of times people interacted with a Tweet, demographic data, the number of people who clicked on a particular link, or who voted in a Tweet poll (even if only one person did it), topics people are tweeting about in a particular location, or reports for advertisers about how many users saw or clicked on their ads.

You can learn more about this topic in the Twitter Help Center and its Privacy Policy.

You can also control whether Twitter shares your personal data in this way using the “Share your data with Twitter’s business partners” option in your Twitter data and personalization settings. (This setting does not control cases where Twitter shares data with its service providers).