UpMee — Privacy Policy and Cookie Policy

GDPR · Privacy

Privacy Policy

How UpMee Group OÜ collects, uses and protects your personal data.

Effective Date: 1 July 2023 · Last Updated: 1 July 2026

At UpMee Group OÜ ("UpMee", "we", "our", or "us"), we recognize that privacy is a fundamental right. We are committed to protecting the personal data of our clients, job candidates, website visitors, business partners, contractors, and all individuals whose information we process.

This Privacy Policy explains how we collect, use, disclose, store and protect personal data when you use our website, communicate with us, apply for employment opportunities, purchase our services, or otherwise interact with our company.

Introduction

At UpMee Group OÜ ("UpMee", "we", "our", or "us"), we recognize that privacy is a fundamental right. We are committed to protecting the personal data of our clients, job candidates, website visitors, business partners, contractors, and all individuals whose information we process.

This Privacy Policy explains how we collect, use, disclose, store and protect personal data when you use our website, communicate with us, apply for employment opportunities, purchase our services, or otherwise interact with our company.

Our objective is to ensure that all personal data is processed lawfully, fairly, transparently and securely in accordance with:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation – GDPR);
  • the Estonian Personal Data Protection Act (Isikuandmete kaitse seadus);
  • the Estonian Electronic Communications Act;
  • other applicable legislation of the European Union and the Republic of Estonia.

By using our services or our website, you acknowledge that you have read this Privacy Policy.

Who We Are

The controller of your personal data is:

Company
UpMee Group OÜ
Registry Code
16707575
Registered Office
Suur tn 12-1420307 NarvaIda-Viru CountyRepublic of Estonia
Website
https://upmee.net/

Whenever this Privacy Policy refers to "UpMee", "Company", "we", "our", or "us", it refers to UpMee Group OÜ acting as the Data Controller within the meaning of Article 4(7) GDPR.

Scope of this Privacy Policy

This Privacy Policy applies to all processing of personal data carried out by UpMee, including data collected through:

  • our corporate website;
  • recruitment activities;
  • contact forms;
  • online meetings;
  • customer onboarding;
  • contracts;
  • provision of recruitment services;
  • provision of HR services;
  • staffing services;
  • Employer of Record (EOR) services;
  • payroll coordination;
  • consulting services;
  • marketing communications;
  • newsletters;
  • cookies and similar technologies;
  • social media pages;
  • business correspondence;
  • customer support.

This Privacy Policy applies regardless of whether personal data is processed electronically, on paper, or by any other means.

Definitions

For the purposes of this Privacy Policy:

Personal Data
any information relating to an identified or identifiable natural person.
Processing
any operation performed on personal data including collection, recording, storage, organization, consultation, use, disclosure, transmission, restriction or deletion.
Data Subject
the individual whose personal data is processed.
Controller
the entity determining the purposes and means of processing personal data.
Processor
a third party processing personal data on behalf of the Controller.
Recipient
any person or organization to whom personal data is disclosed.
Website
the UpMee website located at https://upmee.net/ together with all associated pages.
Services
recruitment, staffing, Employer of Record services, HR consulting, payroll support, IT recruitment, executive search, workforce solutions and any related services provided by UpMee.

Principles of Data Processing

UpMee processes personal data in accordance with the principles established by Article 5 GDPR.

Personal data is:

  • processed lawfully, fairly and transparently;
  • collected only for specified and legitimate purposes;
  • adequate, relevant and limited to what is necessary;
  • accurate and kept up to date;
  • stored no longer than necessary;
  • protected against unauthorized access, loss, destruction or alteration;
  • processed using appropriate technical and organisational safeguards.

We regularly review our internal procedures to ensure continued compliance with applicable data protection laws.

Categories of Personal Data We Collect

Depending on the nature of our relationship with you, we may process different categories of personal data.

These may include:

Identity Information

  • full name;
  • date of birth;
  • nationality;
  • identification document details where required by law;
  • photograph (if voluntarily provided).

Contact Information

  • email address;
  • telephone number;
  • residential address;
  • mailing address;
  • country of residence.

Professional Information

  • curriculum vitae (CV);
  • employment history;
  • education;
  • certifications;
  • professional qualifications;
  • languages;
  • technical skills;
  • salary expectations;
  • work authorization status;
  • LinkedIn profile;
  • portfolio;
  • references.

Business Information

For representatives of corporate clients and suppliers we may process:

  • company name;
  • business address;
  • tax identification numbers;
  • VAT number;
  • position within the company;
  • corporate email;
  • business telephone number.

Financial Information

Where necessary for contractual purposes we may process:

  • bank account details;
  • invoicing information;
  • payment history;
  • accounting documents.

We do not store payment card details unless processed through certified payment providers.

Technical Information

When you visit our website we may automatically collect:

  • IP address;
  • browser type;
  • operating system;
  • language preferences;
  • device identifiers;
  • screen resolution;
  • referral URLs;
  • pages visited;
  • session duration;
  • approximate location;
  • cookies and similar identifiers.

Communication Data

We may retain records of communications including:

  • emails;
  • support requests;
  • contact form submissions;
  • meeting invitations;
  • calendar bookings;
  • chat conversations;
  • customer feedback.

Recruitment Information

For candidates we may additionally process:

  • interview notes;
  • recruiter assessments;
  • technical evaluation results;
  • references;
  • availability;
  • preferred work model;
  • visa status;
  • relocation preferences;
  • salary expectations.

Sensitive personal data will only be processed where permitted by applicable law or where explicit consent has been provided.

Sources of Personal Data

We obtain personal data directly from you whenever you:

  • contact us;
  • request information;
  • register for our services;
  • submit a CV;
  • complete forms;
  • sign agreements;
  • communicate by email or telephone;
  • participate in interviews;
  • subscribe to newsletters.

We may also obtain information from publicly available professional sources, including:

  • LinkedIn;
  • GitHub;
  • professional networking platforms;
  • company websites;
  • public business registers.

When permitted by law, we may receive personal data from:

  • clients;
  • recruitment partners;
  • referral partners;
  • business partners;
  • publicly available databases;
  • employment platforms.

Whenever personal data is collected indirectly, we take appropriate steps to inform the data subject in accordance with Articles 13 and 14 GDPR.

Purposes of Processing

We process personal data for one or more of the following purposes:

  • providing recruitment services;
  • matching candidates with employers;
  • performing staffing services;
  • delivering Employer of Record services;
  • providing HR consulting;
  • payroll administration;
  • customer support;
  • execution of contracts;
  • invoicing and accounting;
  • legal compliance;
  • fraud prevention;
  • website administration;
  • improving our services;
  • statistical analysis;
  • cybersecurity;
  • marketing communications;
  • responding to inquiries;
  • maintaining business relationships.

Each processing activity is supported by an appropriate legal basis under Article 6 GDPR.

Legal Basis for Processing

Depending on the circumstances, UpMee processes personal data on one or more of the following legal grounds:

  • your consent;
  • performance of a contract;
  • taking steps prior to entering into a contract;
  • compliance with legal obligations;
  • protection of vital interests;
  • legitimate interests pursued by UpMee or our clients, provided such interests do not override your fundamental rights and freedoms.

Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Disclosure of Personal Data

UpMee may share personal data only where necessary to provide our services, comply with legal obligations, protect legitimate interests, or where the data subject has provided consent.

Depending on the purpose of processing, personal data may be shared with:

  • our clients;
  • recruitment partners;
  • payroll providers;
  • accounting service providers;
  • legal advisers;
  • banks and payment institutions;
  • cloud hosting providers;
  • IT infrastructure providers;
  • email service providers;
  • customer support platforms;
  • identity verification providers;
  • government authorities where required by law;
  • courts and law enforcement authorities;
  • subcontractors assisting in service delivery.

All third parties processing personal data on our behalf are required to implement appropriate technical and organisational safeguards and process personal data only in accordance with our documented instructions.

We never sell personal data to third parties.

International Transfers

Because UpMee provides international recruitment and staffing services, personal data may occasionally be transferred outside the European Economic Area (EEA).

Whenever such transfers occur, we ensure that one of the safeguards provided by Chapter V GDPR applies, including:

  • an adequacy decision adopted by the European Commission;
  • Standard Contractual Clauses (SCCs);
  • Binding Corporate Rules;
  • approved certification mechanisms;
  • other lawful transfer mechanisms recognised by the GDPR.

Where appropriate, additional technical and organisational safeguards are implemented.

Data Retention

Personal data is retained only for as long as necessary to fulfil the purposes for which it was collected or to comply with legal obligations.

Typical retention periods include:

Recruitment Candidates

Up to 24 months after the completion of a recruitment process unless a longer retention period is based on your consent.

Clients

For the duration of the contractual relationship and thereafter for the period required by accounting, taxation and commercial legislation.

Contractors

For the duration of the agreement and the statutory retention period applicable under Estonian law.

Accounting Records

Accounting documents are retained in accordance with the Estonian Accounting Act, generally for 7 years.

Marketing Data

Until consent is withdrawn or a valid objection is received.

Website Logs

Server logs are retained only for the period necessary to ensure the security and proper functioning of our systems.

Once the applicable retention period expires, personal data is securely deleted, anonymised or archived where required by law.

Data Security

Protecting personal data is one of our highest priorities.

UpMee implements appropriate technical and organisational measures designed to safeguard personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

Our security measures include, where appropriate:

  • encrypted communication (SSL/TLS);
  • secure hosting infrastructure;
  • access control policies;
  • role-based permissions;
  • authentication mechanisms;
  • firewalls;
  • malware protection;
  • continuous software updates;
  • encrypted backups;
  • monitoring of security events;
  • incident response procedures;
  • employee confidentiality obligations.

Although no method of transmission or storage can be guaranteed to be completely secure, we continuously improve our security standards following industry best practices.

Rights of Data Subjects

Under the GDPR, every individual whose personal data we process has the following rights:

Right of Access

You may request confirmation as to whether we process your personal data and obtain a copy of such information.

Right to Rectification

You have the right to request correction of inaccurate or incomplete personal data.

Right to Erasure

In certain circumstances you may request deletion of your personal data ("Right to be Forgotten").

Right to Restriction of Processing

You may request that processing be temporarily restricted under the conditions established by Article 18 GDPR.

Right to Data Portability

Where processing is based on consent or a contract and carried out by automated means, you may receive your data in a structured, commonly used and machine-readable format.

Right to Object

You may object to processing based on legitimate interests or direct marketing.

Right to Withdraw Consent

Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Right Not to Be Subject to Automated Decision-Making

You have the right not to be subject to decisions based solely on automated processing where such decisions produce legal or similarly significant effects, except where permitted by applicable law.

Requests concerning your rights may be submitted to: [email protected]

We aim to respond within one month, unless a longer period is permitted under the GDPR.

Cookies and Similar Technologies

Our website uses cookies and similar technologies to:

  • ensure proper website functionality;
  • remember user preferences;
  • improve website performance;
  • analyse website traffic;
  • enhance user experience;
  • provide relevant content;
  • maintain security.

Some cookies are essential for the operation of the website.

Other cookies, including analytics and marketing cookies, are used only where required by applicable law and subject to your consent.

Detailed information is available in our separate Cookie Policy.

Analytics

To improve our website and services, UpMee may use analytics solutions including:

  • Google Analytics 4;
  • Google Tag Manager;
  • Microsoft Clarity;
  • LinkedIn Insight Tag;
  • Meta Pixel;
  • other privacy-compliant analytical tools.

These tools help us understand website usage, visitor behaviour and service performance.

Where legally required, analytics cookies are activated only after obtaining user consent.

Marketing Communications

If you subscribe to newsletters or marketing communications, we may send information regarding:

  • recruitment opportunities;
  • company news;
  • HR insights;
  • events;
  • webinars;
  • service updates;
  • promotional offers.

You may unsubscribe at any time using the unsubscribe link included in every marketing email or by contacting us directly.

Recruitment

As an international recruitment company, UpMee processes personal data of candidates in order to:

  • evaluate qualifications;
  • identify suitable vacancies;
  • present candidates to prospective employers;
  • arrange interviews;
  • communicate regarding recruitment processes;
  • verify professional experience where permitted by law.

Candidates are encouraged not to include unnecessary sensitive personal data in their CVs unless specifically required by applicable legislation.

Separate recruitment-specific information may be provided where appropriate.

Children

Our services are intended for individuals who have reached the legal age required to enter into employment or commercial relationships.

We do not knowingly collect personal data from children without the involvement or consent of a parent or legal guardian where required by law.

If we become aware that personal data has been collected from a child unlawfully, we will promptly delete such information.

Third-Party Websites

Our website may contain links to third-party websites, including clients, partners, social media platforms and external service providers.

We are not responsible for the privacy practices or content of external websites.

Users should review the privacy policies of those third parties independently.

Changes to this Privacy Policy

We reserve the right to amend this Privacy Policy at any time to reflect:

  • changes in legislation;
  • technological developments;
  • new services;
  • changes in processing activities;
  • regulatory guidance.

The updated version will always be published on https://upmee.net/

Where required by law, we will notify users of material changes.

Complaints

If you believe that the processing of your personal data violates applicable data protection legislation, you have the right to lodge a complaint with the competent supervisory authority.

For UpMee Group OÜ, the competent authority is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon).

You may also seek judicial remedies before the competent courts where permitted by applicable law.

Contact

If you have questions regarding this Privacy Policy or wish to exercise your GDPR rights, please contact:

Company
UpMee Group OÜ
Registry Code
16707575
Registered Office
Suur tn 12-1420307 NarvaIda-Viru CountyRepublic of Estonia
Website
https://upmee.net

Legal basis

This Privacy Policy was prepared in accordance with Regulation (EU) 2016/679 (GDPR) and the applicable legislation of the Republic of Estonia.

Cookies

How UpMee Group OÜ uses cookies and similar technologies on this website.

Effective Date: 1 July 2023 · Last Updated: 1 July 2026

This Cookie Policy explains how UpMee Group OÜ ("UpMee", "we", "our", or "us") uses cookies and similar technologies when you visit our website located at https://upmee.net/

This Policy should be read together with our Privacy Policy.

By using our website, you acknowledge that cookies may be used in accordance with this Cookie Policy. Where required by applicable law, we will request your consent before placing non-essential cookies on your device.

This Cookie Policy explains how UpMee Group OÜ ("UpMee", "we", "our", or "us") uses cookies and similar technologies when you visit our website located at https://upmee.net/

This Policy should be read together with our Privacy Policy.

By using our website, you acknowledge that cookies may be used in accordance with this Cookie Policy. Where required by applicable law, we will request your consent before placing non-essential cookies on your device.

The controller responsible for cookies placed through this website is:

Company
UpMee Group OÜ
Registry Code
16707575
Registered Office
Suur tn 12-1420307 NarvaIda-Viru CountyRepublic of Estonia
Website
https://upmee.net

Cookies are small text files stored on your computer, smartphone or other device when you visit a website.

Cookies allow websites to recognize your browser, remember your preferences and improve your browsing experience.

Cookies may also be used for security purposes, website analytics and performance measurement.

Cookies cannot access files stored on your device and do not normally identify you directly. However, some cookies may process personal data within the meaning of the General Data Protection Regulation (GDPR).

In addition to cookies, our website may use similar technologies, including:

  • Local Storage
  • Session Storage
  • Pixels
  • Tags
  • Beacons
  • SDKs
  • Browser Storage
  • Device Identifiers

These technologies perform functions similar to cookies and may also collect information regarding your interaction with our website.

We use cookies to:

  • ensure proper operation of the website;
  • remember your preferences;
  • improve website functionality;
  • maintain website security;
  • analyse website traffic;
  • understand visitor behaviour;
  • detect technical issues;
  • improve user experience;
  • measure the effectiveness of marketing campaigns;
  • personalize content where applicable.

Essential Cookies

These cookies are necessary for the website to function properly.

Without these cookies certain services cannot be provided.

Examples include:

  • user authentication;
  • session management;
  • security verification;
  • fraud prevention;
  • load balancing;
  • cookie consent preferences.

These cookies cannot be disabled through our consent banner.

Functional Cookies

Functional cookies remember choices you make while using our website.

Examples include:

  • preferred language;
  • time zone;
  • previously completed forms;
  • accessibility settings;
  • display preferences.

These cookies improve convenience but are not strictly necessary.

Analytics Cookies

Analytics cookies help us understand how visitors use our website.

We may analyse:

  • number of visitors;
  • pages viewed;
  • traffic sources;
  • navigation paths;
  • session duration;
  • bounce rate;
  • device information;
  • browser information.

The information collected is generally aggregated and used solely to improve our services.

Where required by law, analytics cookies are activated only after your consent.

Marketing Cookies

Marketing cookies help measure advertising performance and improve marketing communications.

Depending on the services used, they may:

  • remember advertising interactions;
  • measure campaign effectiveness;
  • prevent repeated advertisements;
  • provide more relevant advertising.

Marketing cookies are only used with your consent.

Some cookies placed on our website originate from trusted third-party providers.

Depending on the services implemented on the website, these providers may include:

  • Google
  • Microsoft
  • Meta (Facebook)
  • LinkedIn
  • Cloudflare
  • HubSpot
  • Calendly
  • YouTube
  • Vimeo

The list of providers may change as our services evolve.

Each provider maintains its own privacy and cookie policies.

Depending on the functionality available at a given time, UpMee may use cookies associated with:

Website Security

  • Cloudflare
  • reCAPTCHA

Analytics

  • Google Analytics 4
  • Microsoft Clarity

Advertising

  • LinkedIn Insight Tag
  • Meta Pixel

Website Performance

  • Google Tag Manager

Embedded Content

  • YouTube
  • Vimeo

Communication Tools

  • Contact Forms
  • Calendly

The actual cookies used may change over time as our website evolves.

Cookies may be stored for different periods.

Session Cookies

These are automatically deleted when you close your browser.

Persistent Cookies

These remain on your device until:

  • they expire;
  • you delete them;
  • you clear your browser data.

Their lifetime may range from a few days to several years depending on their purpose.

Essential cookies are processed based on our legitimate interest in ensuring the secure and proper functioning of the website.

Analytics, functional and marketing cookies are processed only on the basis of your consent where required under applicable law.

You may withdraw your consent at any time.

When you first visit our website, you will be presented with a cookie banner allowing you to:

  • Accept All Cookies;
  • Reject Non-Essential Cookies;
  • Customize Cookie Preferences.

Your preferences can be changed at any time.

Most browsers allow you to:

  • view stored cookies;
  • delete cookies;
  • block cookies;
  • receive notifications before cookies are stored;
  • disable third-party cookies.

Please note that disabling certain cookies may affect website functionality.

Browser settings can usually be found in:

  • Google Chrome
  • Mozilla Firefox
  • Microsoft Edge
  • Safari
  • Opera

Some of our technology providers may process information outside the European Economic Area.

Whenever international transfers occur, appropriate safeguards under Chapter V GDPR are implemented.

These safeguards may include:

  • Standard Contractual Clauses;
  • Adequacy Decisions;
  • other approved transfer mechanisms.

Where cookies involve the processing of personal data, you have the rights granted under the GDPR, including:

  • Right of Access;
  • Right to Rectification;
  • Right to Erasure;
  • Right to Restrict Processing;
  • Right to Data Portability;
  • Right to Object;
  • Right to Withdraw Consent;
  • Right to Lodge a Complaint.

More information is available in our Privacy Policy.

We may update this Cookie Policy from time to time to reflect:

  • legal changes;
  • technological developments;
  • website improvements;
  • new third-party services.

The latest version will always be available at https://upmee.net/

If you have any questions regarding this Cookie Policy or our use of cookies, please contact:

Company
UpMee Group OÜ
Registry Code
16707575
Registered Office
Suur tn 12-1420307 NarvaIda-Viru CountyRepublic of Estonia
Website
https://upmee.net

If you believe that your rights have been violated in connection with the use of cookies or the processing of your personal data, you have the right to lodge a complaint with the competent supervisory authority.

For UpMee Group OÜ, the competent authority is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon).

Legal basis

This Cookie Policy has been prepared in accordance with Regulation (EU) 2016/679 (GDPR), the Estonian Personal Data Protection Act, and applicable European data protection legislation.