1. Who We Are

UPGR (“we”, “us”, “our”) is a phone subscription service based in Belgium. We are committed to protecting your personal data in compliance with the General Data Protection Regulation (GDPR) and Belgian data protection laws.

2. What Data We Collect

When you sign up for our waitlist, we collect:

• Email address — to notify you about our launch and service updates
• Device preferences — your selected plan, brand, color, and storage (optional)
• Survey responses — current device, upgrade frequency, referral source (optional)

3. Why We Collect It (Legal Basis)

We process your personal data based on your consent (Article 6(1)(a) GDPR), given when you voluntarily submit your email address. You can withdraw consent at any time by contacting us.

4. How We Use Your Data

• To keep you informed about our launch date and early access
• To understand demand for specific devices and configurations
• To improve our service before launch

We will never sell your data to third parties or use it for unrelated marketing.

5. Data Storage & Security

Your data is stored securely using industry-standard encryption. Our infrastructure is hosted in the EU. We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, or destruction.

6. Your Rights

Under the GDPR, you have the right to:

• Access — request a copy of your personal data
• Rectification — correct inaccurate data
• Erasure — request deletion of your data (“right to be forgotten”)
• Portability — receive your data in a structured, machine-readable format
• Withdraw consent — at any time, without affecting the lawfulness of prior processing

To exercise any of these rights, contact us at privacy@upgr.be

7. Data Retention

We retain your data for as long as necessary to fulfill the purposes described above. If you withdraw consent or request deletion, we will erase your data within 30 days.

8. Cookies

We use essential cookies only (language preference). We do not use tracking cookies or third-party analytics at this time.

9. Contact & Complaints

If you have questions about this policy or wish to file a complaint, contact us at privacy@upgr.be. You also have the right to lodge a complaint with the Belgian Data Protection Authority (GBA/APD) atwww.dataprotectionauthority.be.