Section 01
Who We Are
Upgrade2Phone ("we", "us", "our") is an independent phone upgrade advisory service operating in the United Kingdom. We provide free phone upgrade quotes, network comparisons, handset advice, and general guidance to consumers looking to upgrade their mobile devices.
For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, Upgrade2Phone is the data controller responsible for your personal information.
You can contact us regarding any data protection matters at:
Section 02
Information We Collect
We collect two broad categories of information: information you give us directly, and information collected automatically when you use our website.
Information you provide to us:
- Your name, when you provide it during a phone call or enquiry
- Your phone number and/or email address, if you share these with our advisors
- Details about your current mobile contract, network provider, and handset
- Your preferences regarding data allowances, device type, and monthly budget
- Any other information you choose to share with us when seeking advice
Information collected automatically:
- Your IP address and approximate geographic location (country/region level)
- The type of browser and device you are using to access our website
- Pages visited, time spent on pages, and how you navigated to our site
- Referring website or search engine that brought you to us
- Cookie identifiers and session data (see Section 6 for full details)
We do not collect sensitive personal data such as financial information, identification documents, or biometric data. We will never ask for your bank details, passwords, or National Insurance number.
Section 03
How We Use Your Information
We use the personal information we collect for the following specific purposes:
| Purpose | Description |
|---|---|
| Providing upgrade quotes | To search available network deals and generate a personalised upgrade recommendation based on your current contract details and preferences. |
| Customer communication | To follow up on your enquiry if you have requested a callback or further information, and to answer any questions you have raised. |
| Service improvement | To understand how visitors use our website so we can improve navigation, content, and the overall user experience. |
| Legal compliance | To comply with applicable UK law, regulation, or a lawful request from a public authority or court order. |
| Fraud prevention | To detect and prevent fraudulent or abusive use of our services and to protect the safety of our customers and staff. |
We do not use your information to build automated profiles, make automated decisions that legally or significantly affect you, or engage in any form of profiling for advertising purposes.
Section 04
Legal Basis for Processing
Under the UK GDPR, we must have a lawful basis for every way we process your personal data. We rely on the following legal bases:
- Legitimate interests — When you contact us for a quote or advice, we process the information you provide in order to respond to your request and deliver our service. This is in both your interest and ours.
- Consent — Where we send you follow-up marketing communications (e.g. deal alerts by email), we will have asked for your explicit consent beforehand. You may withdraw this consent at any time by emailing us at info@upgrade2phone.online.
- Legal obligation — In certain circumstances, we may be required to process your data to comply with a legal duty, such as responding to a lawful request from a regulatory authority.
- Vital interests — In rare circumstances, we may need to process information to protect someone's life or safety.
Section 05
Who We Share Your Data With
We do not sell, rent, or trade your personal data. We only share your information in the following limited circumstances:
- Service providers: We may share data with trusted third-party suppliers who help us operate our website or business (for example, web hosting providers or analytics services). These parties are contractually bound to handle your data securely and only for the specific purpose we have engaged them.
- Network partners: With your explicit consent, we may share relevant details with a network provider or retailer in order to process your upgrade or obtain a formal quote on your behalf.
- Legal requirements: We will disclose information if required to do so by law, court order, or a lawful request from a government or regulatory authority.
- Business transfers: In the event that Upgrade2Phone is acquired, merged, or its assets are transferred, your personal data may be passed to the new owner, subject to the same privacy commitments set out in this policy.
All third parties with whom we share data are required to respect the security of your personal information and to treat it in accordance with applicable UK data protection law.
Section 06
Cookies & Tracking
Our website uses cookies — small text files stored on your device — to help us provide a better browsing experience. We use the following categories of cookies:
- Essential cookies: Required for the website to function correctly. These cannot be disabled as they are necessary for basic functionality such as page navigation and security.
- Analytics cookies: Used to understand how visitors interact with our site (e.g. which pages are most visited, how long visitors stay). This data is aggregated and anonymous. We use this to improve our content and user experience.
- Preference cookies: Remember choices you make on our site (such as your preferred language or region) so we can provide a more personalised experience on return visits.
You can control and manage cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of our website. For more information on managing cookies, visit allaboutcookies.org.
Section 07
Data Retention
We retain personal data only for as long as is necessary for the purposes for which it was collected, in line with our legal obligations and legitimate business needs.
- Enquiry and quote information is retained for up to 12 months from the date of your initial contact, after which it is securely deleted.
- Where you have given consent for marketing communications, we retain your contact details until you withdraw your consent or ask us to delete your data.
- Website analytics data (which is aggregated and anonymised) may be retained for up to 24 months for trend analysis and service improvement.
- Any data we are required to retain for legal or compliance reasons will be held for the minimum period required by the applicable law.
When data is no longer required, it is deleted or anonymised in a manner that ensures it cannot be recovered or reconstructed.
Section 08
Your Rights Under UK GDPR
As a resident of the United Kingdom, you have a number of important rights in relation to the personal data we hold about you. These rights are:
- Right of access — You have the right to request a copy of the personal data we hold about you (known as a Subject Access Request).
- Right to rectification — If you believe any information we hold is inaccurate or incomplete, you have the right to ask us to correct it.
- Right to erasure — Also known as the "right to be forgotten", you may ask us to delete your personal data where there is no compelling reason for us to continue processing it.
- Right to restrict processing — You may request that we limit how we use your data in certain circumstances, for example while a complaint is being investigated.
- Right to data portability — Where we process your data on the basis of consent or contract, you may request a copy in a commonly used, machine-readable format.
- Right to object — You have the right to object to processing based on our legitimate interests. We must stop unless we have compelling legitimate grounds that override your interests.
- Right to withdraw consent — Where we rely on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, please contact us at info@upgrade2phone.online. We will respond to all verified requests within 30 days in line with our legal obligations.
If you are unhappy with how we have handled your data, you have the right to lodge a complaint with the UK's data protection authority, the Information Commissioner's Office (ICO), at ico.org.uk.
Section 09
Data Security
We take the security of your personal data seriously and have implemented appropriate technical and organisational measures to protect it against unauthorised access, loss, destruction, or alteration. These include:
- Secure HTTPS encryption for all data transmitted via our website
- Restricted access to personal data on a strict need-to-know basis
- Regular review and testing of our security measures and data handling practices
- Staff awareness of their data protection responsibilities
- Secure deletion procedures for data that is no longer required
While we take every reasonable precaution, no method of electronic transmission or storage is 100% secure. In the unlikely event of a data breach that poses a risk to your rights and freedoms, we will notify you and the ICO in accordance with our legal obligations.
Section 10
Third-Party Links
Our website may contain links to third-party websites, including network providers and handset manufacturers. These sites have their own privacy policies, which we encourage you to review. We are not responsible for the privacy practices or the content of any external websites.
The inclusion of a link to a third-party website does not constitute our endorsement of that site, its content, or its privacy practices.
Section 11
Children's Privacy
Our services are intended for adults aged 18 and over. We do not knowingly collect or process personal data from children under the age of 18. If you believe that a child has provided us with personal information without appropriate parental consent, please contact us immediately at info@upgrade2phone.online and we will take prompt steps to delete that information.
Section 12
Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or the services we offer. When we make material changes, we will update the "Last updated" date at the top of this page.
We encourage you to review this policy periodically so that you are always aware of how we handle your personal information. Continued use of our website or services after any changes are posted constitutes your acceptance of the updated policy.
If we make significant changes that materially affect how we use your data, we will take reasonable steps to notify you directly where we hold your contact details.
Section 13
Contact Us
If you have any questions, concerns, or requests relating to this Privacy Policy or the way we handle your personal data, please do not hesitate to get in touch. We are committed to resolving any issues promptly and transparently.
You can reach us by:
- Email: info@upgrade2phone.online
- Telephone: 02038 965 877
Our team is available Monday to Friday, 9:00am–7:00pm, and Saturday, 10:00am–5:00pm. We aim to respond to all written enquiries within 3 business days.