Privacy Policy
Privacy Notice
This notice explains how personal data is processed when you use UpSearch.
Last updated: February 20, 2026
1. Data Controller
- Legal name: Cleveland & Phan Consulting ApS
- Company type: Anpartsselskab (ApS)
- CVR number: 44675293
- Registered address: Alsgade 2, 3. tv, 1764 København V, Denmark
- Privacy contact: michael@clepha.com
2. Data We Process
- Account data such as name, email, and organization details.
- Service data such as search queries, document metadata, and workspace actions.
- Technical data such as IP address, browser details, and security logs.
- Support and communication data when you contact us.
3. Purposes and Legal Bases
| Purpose | Legal Basis |
|---|---|
| Create and manage user accounts, authentication, and access controls | GDPR Art. 6(1)(b) - Performance of a contract |
| Operate, secure, and improve the service, including fraud and abuse prevention | GDPR Art. 6(1)(f) - Legitimate interests |
| Meet accounting, tax, and legal recordkeeping obligations | GDPR Art. 6(1)(c) - Legal obligation |
| Send optional product updates or marketing communication | GDPR Art. 6(1)(a) - Consent (when required) |
4. Retention and Recipients
- We keep personal data only for as long as needed to provide the service and meet legal obligations.
- Data may be processed by hosting and infrastructure providers acting as processors.
- If data is transferred outside the EU/EEA, appropriate safeguards are applied, such as SCCs.
5. Your Rights
Under GDPR, you have rights to access, rectification, deletion, restriction, portability, and objection. You can also withdraw consent where processing is based on consent. To exercise rights, email michael@clepha.com.
You can lodge a complaint with Denmark's supervisory authority (Datatilsynet). See: datatilsynet.dk.
6. Related Policies
Read our Cookie Policy and Terms and Conditions.