Privacy Policy

Last update: May 7, 2021
Published: April 29, 2021

1. Intro

Welcome to Upfeed!

Our Privacy Policy describes the definition of Personal Information, how it is collected, stored, used, disclosed, and shared when You use Our Website and Our Services.

By using the Website, You give consent to Us for collecting, storing, using, and disclosing Your information, including Personal Information as described in this Privacy Policy. If You do not agree to all provisions of this Privacy Policy, You may not access the Website.

The Privacy Policy will be permanently accessible on the Website and periodically renewed. By providing any of the information about Yourself, as well as accessing and using the Website, You acknowledge and agree that You have read, fully accept, and abide by this Privacy Policy. If You don't agree to the terms of this Privacy Policy and/or the Terms and Conditions, please don’t use the Website.

In case You have any questions relating to the terms contained in this Privacy Policy, please contact Us via email: [email protected]

Your question will be responded to during 30 (thirty) days, but We try to respond as soon as it is practically possible.

2. Definitions

For this Privacy Policy, the following terms have the meanings as mentioned below:

“Company” – refers to LTD UPSYSTEM (Tax number: 43848197), legal address: 02090, Kyiv city, Almatynska street, building 2/1, represented by CEO HADAY ANDRIY OLEHOVYCH, acting based on Statute / PPE HADAY ANDRIY OLEHOVYCH, date and number of the record in the Unified State Register of Legal Entities and Individual Entrepreneurs: 2009040000000000867 dd.11.05.2020  (hereinafter – “Company”, “We”, “Our” or “Us”).

“Website” — means all content and links of the page that provides Services to Users and provides information regarding the Services (also referred to as “Upfeed”).

“Account” — means an account required to access and/or use certain areas and features of Our Website.

“Automatically-collected information” – information collected automatically through the Website (or Third-party services employed in this Website) -referred to as “Usage Data”.

“Cookies” — means small text files that a Website stores on Your computer or mobile device when You visit the Website.

“Content” — the information, Company provides via Website, including bids with offers, the search for which is configured by providing Services by the Company.

“Services” provision of services by the Company to improve and customize the search for job offers and vacancies using special filters.

“Data Controller”, “Owner” company which determines the purposes and means of the Processing of Personal Data (referred to as “Controller”). Contact email: [email protected]

“Data Processor” means a natural person or legal entity which processes Personal Data on behalf of the Controller, specified in this Privacy Policy (referred to as “Processor”).

“European Union”, “EU” — unless otherwise specified, all references made within this document to the European Union include all current member states of the European Union and the European Economic Area.

“Personal Data”, “Personal Information” — any information that directly, indirectly, or in connection with other information allows an identification or identifiability of a natural person. For example, a name, an email, a password, etc. (also referred to as “Data”).

“User” — the individual using the application that has passed the registration and who, unless otherwise specified, coincides with the Data Subject (also referred to as “You”, “Your”).

“Third-Party” a legal person, public authority, agency, or body - other than the Data Subject, Controller, Processor - and persons who, under the direct authority of the Controller or Processor, are authorized to process Personal Data and/or Usage Data.

“Processing” – any operation or set of operations that is performed on Personal Data or sets of Personal Data.

“Cross Border Data Transfer (CBDT)” – Transfer of Personal Data by Controllers, established in the European Union (EU) to recipients, established outside the territory of the EU/EEA who act either as Controllers or as Processors.

3. Data we collect

We collect information directly from Users when they register online, as well as through browsing of Our Website. We collect Personal Data only when You register an Account through Upfeed and with Your consent, the rest of the Data that We collect is the Usage Data.

We also collect information from the User’s Google personal account, but only if the User registered on the Website via the mentioned Service and only to the extent allowed by Google. We kindly recommend You to read the Privacy Policy of Google at before registration.

3.1. Personal Data You Provide to Us

Personal Data is collected when You sign up in the Upfeed and create the Account. You can also provide Us with Personal Data via chats and support services at Your discretion.

We may collect Personal Information about You, such as:

  • Your first name and last name;
  • Email address;
  • Password;
  • Information contained in Your Google profile if You signed via Google (such as profile name, photos, place of the living, workplace, list of friends, etc.);

All Personal Data requested by the Upfeed is mandatory, and failure to provide it may make it impossible for the Company to provide the Services.

3.2. Automatically-collected Information

Apart from Personal Data, We collect particular information about You automatically, in an aggregated way. We collect Usage Data directly from Users when they browse Our Website. Usage Data helps Us to customize the Website and improve the Services performance.

We collect Usage Data when Users access or use Our Website:

  • computer's Internet Protocol address (e.g., IP address);
  • browser type;
  • browser version;
  • type of device You are using;
  • the pages of Our Service that You visit;
  • the time and date of Your visit;
  • the time spent on those pages;
  • unique device identifiers;
  • other diagnostic data.

3.3. Cookies

The Website can create objects and store them on the User's device. We use Cookies to collect certain Usage Data, such as visited pages and Services used within the Our Website to customize and enhance User experience. We generally collect 1 type of Cookies:

a. Session Cookies: We use Session Cookies to operate Our Service.

The Session Cookies store information that the User has inputted and tracks the movements of the User within the Website. The storage period of Data obtained through Session Cookies — 1 (one) calendar year.

The Website uses Cookies and other tracking technologies for the following purposes:

  • obtaining standard web analytics information;
  • retrieve Data collected using HTML cookies, Flash cookies, web beacons, and similar technologies;
  • obtaining demographic information and other details to help Us customize the Website to suit Your preferences.

We may provide this information to partners who assist Us in restoring, managing, or maintaining Our Platform (Third Parties).

You can delete all Cookies that are already on Your device by clearing the browsing history of Your browser. You can set Your browser to prevent any Cookies from being placed on Your device, but You may then have to manually adjust some preferences every time You visit the Website.

If You have been living in the EU or You are an EU citizen, the provisions of the European Commission’s General Data Protection Regulation should apply to You.Where You have provided consent to the use of Cookies on the basis of a notice displayed on Our Websites, the legality of this Data Processing is governed by Art. 6 (1) (a) European Commission’s General Data Protection Regulation.

5. Terms of data storage

We will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain your Data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.

Personal Data shall be processed and stored for as long as required by the purpose it has been collected for.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this Data is used to strengthen the security or to improve the functionality of our Service, or We are legally obliged to retain this Data for longer time periods.

Usage Data shall be processed and stored for as long as required by the purpose they have been collected for, but not more than 3 years from the date of collection, unless otherwise derived from the purpose of Data Processing.

Prolonging of retaining of Personal Data

The Controller may be allowed to retain Personal Data for a longer period whenever the User has given consent to such Processing, as long as such consent is not withdrawn. Furthermore, the Сontroller may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

6. How we process your data

6.1. How We Process and Where We Store

The Usage and Personal Data are processed at the Owner's operating offices and in any other places where the Third Parties involved in the Processing are located.

Sometimes Data transfers may involve transferring the User's Data to another country. To find out more about the place of Processing of such transferred Data, Users can check section 6.2. “Cross-border Data Transfer”.

As a rule, We use MongoDB provided by MongoDB, Inc. in order to store the Personal Data. MongoDB provides its services in compliance with General Data Protection Regulation. You can find MongoDB’s Privacy Policy at  But We can change the provider of database services at any time without additional notification of Users.

Automatically-collected data is collected and stored by Third-party servers, namely Google.

Google Analytics (Google LLC). Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of the Website, to prepare reports on its activities, and to share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network (Usage Data Processors). You can find the Privacy Policy of Google at Google Analytics may also place Cookies on Your device.

Google Ads (AdWords) remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page:

6.2. Cross-border Data Transfer

A Cross-Border Data Transfer may take place if the transfer is necessary for the conclusion or performance of a contract between the Controller and a Third-party, where it is in the interests of the Data Subject.

Personal Data may be transferred to:

a. a third country only if a set of conditions are fulfilled;
b. countries whose legal regime is deemed by the European Commission to provide for an “adequate level of Personal Data protection”.

Depending on the User's location, Data interpretation may involve transferring the User's Personal Data to a country other than their own.

While most provisions of this Privacy Policy concern all Users, some provisions expressly apply only if the Processing of Personal Data is subject to broader protection standards.

Such broader protection standards apply when the Processing:

a. Is performed by an Owner within the EU;
b. Concerns the Personal Data of Users who are in the EU and is related to the offering of paid or unpaid goods or services, to such Users;
c. Concerns the Personal Data of Users who are in the EU and allows the Owner to monitor such Users’ behavior taking place in the EU;
d. Concerns the Personal Data of Users who are in the US. You can find California Consumer Privacy Act (CCPA) at

You may access the European Commission’s General Data Protection Regulation at

EEA residents are subject to EEA Data protection legislation that apply to those Users.

All other worldwide Users (third countries) are subject to its domestic Data protection legislation.

6.3. Disclosure of Personal Data

Any information that We collect or that You provide to Us may be shared and processed by any entity of the Company. We do not sell Your Personal Data or transfer it with any other commercial purpose to third parties. But if necessary, We may share Personal Information with the following categories of Third Parties:

a. Our professional advisers and providers of hosting.
b. Government and/or regulatory authorities.
c. Third Parties, which are the Processors.

In addition, We may disclose Personal Data to other third parties under the following circumstances:

a. Legally required. If We are required to do so by law (e.g., to law enforcement bodies, courts, or others, e.g.).
b. Protect Our rights.
c. We may also share, aggregate, or de-identified information with Third Parties for research, marketing, analytics, and other purposes, provided such information does not identify a particular individual.

6.4. Payment system

We never monitor or store any User’s full credit or debit card details within Our Services. We use the FONDY platform as a payment system. FONDY uses a number of Payment Card Industry (“PCI”), compliant providers, to process the credit. We kindly recommend You to read the Privacy Policy and Terms and Conditions of FONDY at before registration there.

6.5. Links to other Websites

Our Service may contain links to other sites that are not operated by Us. If You click a Third-party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any Third-party Websites or services.

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

7. User's rights

a. The Right to Access to Your Personal Data

You have the right to obtain from the Company confirmation as to whether or not Your Personal Data is being processed, and where that is the case, access to Your Personal Data.

b. The right to withdraw consent

You also have the right to withdraw Your consent atany time where We relied on Your consent to Processing Your Data.

c. The Right to Be Forgotten

You can withdraw Your consent if You believe Your fundamental rights to Data Privacy and protection outweigh Our legitimate interest in continuing the Processing, We may retain an anonymous history of User actions (excluding Personal Data). Within 30 (thirty) days of Your request for deletion of information, the Company deletes all information it possesses about You. If You have any questions, please contact Us at [email protected]

d. The Right to Change Your Personal Data

You can ask Us to correct a mistake in Your Data or to erase Your Personal Data from Our Website if it is no longer necessary for the purpose for which it was submitted.

e. Right to Request Data, We Have about You

We can provide You with the information We maintain about You. Your question will be responded to during 30 (thirty) days, but We try to respond as soon as it is practically possible.

f. Right to Lodge a Complaint

The Personal Data may be used for legal purposes by the Controller in court or the stages leading to possible legal action arising from improper use of this Website. The User declares to be aware that the Controller may be required to reveal Personal Data upon request of public authorities.

g. The Right to Object

You have the right to object, on grounds relating to Your particular situation, at any time to the Processing of Your Personal Data.

h. The Right to Restrict of Processing of Your Personal Data

In some situations, You have the right to restrict the Processing of Your Personal Data. In case of restriction of Processing, Services may be provided incorrectly.

i. The Right to Data Portability

You have the right to be provided with a copy of Your Personal Data in a structured, machine-readable, and commonly used format.

8. Change of the controller

We have the right to purchase a new, sell or transfer Our Company. Your information will likely be among the items transferred in these types of transactions.

We have the right to sell or otherwise transfer Personal Data during a merger, acquisition, bankruptcy, reorganization, liquidation, and similar transactions. We will do Our best to guarantee the same level of security as We provide by Ourselves.

9. Age limitations

To the extent prohibited by applicable law, We do not allow using of Our Website and/or Services by anyone younger than 18, or other age, if it is stated by applicable law in Your jurisdiction.

If You learn that anyone younger than the legal age has unlawfully provided Us with Personal Data, please contact Us immediately and We will take all necessary steps to remove such information.

10. Changes to this privacy policy

We may, at Our sole discretion, revise this Privacy Policy and periodically update this document with the changes. We encourage You to review Our Privacy Policy to stay informed at least once a month. If We make changes that materially alter Your privacy rights, We will provide additional notice via email. If You disagree with the changes to this Privacy Policy, please do not use Our Website.

11. Governing law

This Privacy Policy is governed by and construed in accordance with the laws of Ukraine, namely the Law of Ukraine “On Personal Data Protection” of 01.06.2010 and EU Regulation No 2016/678 of 26.04.2016.

All disputes arising out of or in connection with this Privacy Policy shall be finally settled by arbitration according to the Rules of Arbitration of the Commercial Arbitration Center of the Ukraine Chamber of Commerce and Industry (Commercial Arbitration Center), by one or more arbitrator(s) appointed in accordance with the Arbitration Rules. The language of the arbitration shall be English. The place of arbitration shall be Kyiv.

12. Warranty and limitations of the liability

We take reasonable and appropriate measures to protect the Personal Data We collect through the Website to prevent unauthorized or unlawful access, disclosure, or destruction. Unfortunately, no Data transmission or storage system can be guaranteed to be 100% secure. As a result, while We strive to protect Your Data, We cannot ensure or warrant the security of any information You transmit to Us.

Please note that We do not collect or process Your Personal Data that You provided to third sites or services (including, but not limited Upwork or other services). We collect, process, and store only the Personal Data that You provide Us at Our Website. You use the Website and provide Us with Your Data at Your own risk.

We expressly disclaim any representation or warranty, express or implied, with respect to any breaches of security, damage to Your device, or any loss or unauthorized use of Your data.

13. Contact Us

If You have any questions or concerns about the Privacy Policy of Upfeed or if at any time You decide that We should no longer hold any of Your Personal Data, please let Us know via [email protected]

This Privacy Policy relates solely to the Website, if not stated otherwise within this document.

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