Privacy Policy

Last updated: September 30, 2026

1. Introduction and who we are

Upstream Technology respects your privacy and processes personal information lawfully, fairly and transparently. This Privacy and Cookie Policy explains what personal information we collect through upstream-technology.com (the “Website”), why we collect it, how we use and protect it, who we share it with, and the rights you have.

The Website is operated by Upstream Technology South Africa (Pty) Ltd, a mining technology solutions company within the De Beers Group (“Upstream Technology”, “we”, “us” or “our”). For the purposes of the Protection of Personal Information Act 4 of 2013 (“POPIA”), we are the responsible party. Where the EU or UK General Data Protection Regulation (“GDPR”) applies, we are the controller.

DetailInformation
Registered nameUpstream Technology South Africa (Pty) Ltd
Head officeDBM Gardens, Golf Park 2, Raapenberg Road, Pinelands, Cape Town, 7405, South Africa
Johannesburg facilityWest Campus, Cnr Crownwood & Booysens Reserve Roads, Theta, Johannesburg, 2013, South Africa
Emailup***********@**********up.com
Telephone+27 21 658 3229
Websitehttps://upstream-technology.com

1.1 Scope

This policy applies to personal information collected through the Website, including its contact and enquiry forms, and to information collected automatically when you browse it. It applies to visitors, prospective and existing clients, suppliers and anyone who contacts us through the Website.

It does not apply to third-party websites we link to, such as the De Beers Group website, which have their own privacy policies. Personal information of our employees, and information processed under a signed client contract, is governed by separate notices and agreements.

1.2 Acceptance

By using the Website or submitting a form, you acknowledge that you have read this policy. Where we rely on your consent (for example, for analytics cookies), we ask for it separately and you may withdraw it at any time.

2. Legal framework and definitions

We process personal information in line with POPIA and its regulations, the Electronic Communications and Transactions Act 25 of 2002 and the Consumer Protection Act 68 of 2008, where applicable. Where you are located in the European Economic Area or the United Kingdom, we also apply the principles of the GDPR and UK GDPR to that processing.

TermMeaning in this policy
Personal informationAny information relating to an identifiable, living natural person and, under POPIA, an identifiable existing juristic person (for example, a company).
ProcessingAny operation on personal information, including collecting, recording, storing, using, sharing, updating or destroying it.
Data subjectThe person (or company) to whom the personal information relates. You, when you use the Website.
Responsible party / controllerThe party that decides why and how personal information is processed. Upstream Technology.
Operator / processorA party that processes personal information on our behalf under contract, such as our hosting or analytics providers.
CookieA small text file stored on your device by a website, used to remember information about your visit. Similar technologies include local storage, pixels and scripts.
Special personal informationInformation about religion, race, health, biometrics, political persuasion, sex life, trade union membership or criminal behaviour. We do not request or knowingly collect it through the Website.

3. Personal information we collect

We collect only what we need to respond to you, run the Website securely and understand how it is used. We collect it in three ways: information you give us, information collected automatically, and information from third parties.

3.1 Information you give us (contact and enquiry forms)

Our forms are built with Forminator Pro. When you submit a form, we collect:

FieldRequiredPurpose
First name and last name (full name)First name requiredTo identify and address you
CompanyRequiredTo understand which organisation the enquiry relates to
Email addressRequiredTo reply to your enquiry
Phone numberOptionalTo call you back where that is quicker or you prefer it
Reason for contactRequiredTo route your enquiry to the right team
MessageOptionalTo understand your request

We also record the date and time of submission and, for security and spam prevention, may record your IP address and browser details with the entry. Forms use hidden anti-spam fields (a “honeypot”) that are not visible to people and should be left blank.

Please do not include special personal information or confidential third-party information in the message field.

3.2 Information collected automatically

When you visit the Website, our server, plugins and analytics tools automatically collect technical information, including:

  • IP address (Google Analytics does not log or store full IP addresses for users in the EU, and we do not use it to identify you)
  • Browser type and version, device type, operating system and screen resolution
  • Pages viewed, time on page, links clicked, files downloaded (such as brochures and PDFs) and the page that referred you
  • Approximate location (country or city) derived from your IP address
  • Date and time of access, and server and security logs, including failed login attempts and suspicious requests

See section 6 (Cookie Policy) for the cookies and similar technologies used.

3.3 Comments

The Website does not currently offer public comments. If comments are enabled in future, we will collect the data shown in the comment form, your IP address and browser user agent string to help with spam detection. An anonymised string created from your email address (a “hash”) may be sent to the Gravatar service to check whether you use it. After approval, your profile picture and comment become visible to the public.

3.4 Media

We do not accept uploads from visitors. Website administrators who upload images should avoid images with embedded location data (EXIF GPS), because visitors can download and extract that data.

3.5 Information from third parties

We may receive aggregated, non-identifying reports from Google Analytics and Google Search Console (through Site Kit), and security threat data from WPMU DEV Defender. We do not buy personal information or combine it with data from data brokers.

4. How we use your information and our lawful basis

We use personal information only for the specific, explicitly defined purposes below, and we do not process it in a way that is incompatible with those purposes (POPIA sections 13 and 15).

PurposeInformation usedLawful basis (POPIA s11 / GDPR Art. 6)
Responding to enquiries and requests for information, quotes or technical supportForm dataSteps at your request before entering a contract; our legitimate interest in responding to business enquiries
Managing an existing client or supplier relationshipForm data, correspondencePerformance of a contract
Routing your enquiry to the correct division or De Beers Group companyForm dataLegitimate interest
Understanding how the Website is used and improving content and performanceAnalytics and cookie dataConsent (analytics cookies)
Keeping the Website and our systems secure, preventing spam, fraud and abuseIP address, logs, security dataLegitimate interest; legal obligation
Backing up the Website so it can be restored after an incidentAll Website data, including form entriesLegitimate interest
Sending you information about our products and servicesName, company, emailConsent, or existing client relationship (POPIA s69)
Complying with law, regulators, court orders and enforcing our rightsAny relevant informationLegal obligation; legitimate interest

We do not use automated decision-making or profiling that produces legal or similarly significant effects on you. We do not sell your personal information.

5. Third-party services and WordPress plugins

The Website runs on WordPress and uses the plugins and services below. Some run entirely on our server; others send data to the provider, which then acts as our operator (processor) or, in Google’s case for certain purposes, an independent controller.

Service / pluginProviderWhat it doesPersonal information involvedData leaves our server?
WordPress coreWordPress.org (open source)Content management systemAdmin login data; comment data if enabledNo
ElementorElementor Ltd (Israel)Page builder and site designBrowsing data via local storage; loads Google FontsFonts are requested from Google servers
Crocoblock JetEngine and JetSmartFiltersCrocoblock (Ukraine)Custom content listings and filteringFilter selections in the URL or sessionNo
Rank Math SEORank Math (MyThemeShop)Search engine optimisation, sitemaps, redirects, 404 monitoringRequested URLs and, if 404 logging is enabled, IP and user agentNo
Site Kit by GoogleGoogle LLCConnects the Website to Google Analytics and Search ConsoleAnalytics identifiersYes, to Google
Google Analytics 4Google LLC / Google Ireland LtdVisitor statisticsCookie IDs, truncated IP, device and usage dataYes, to Google (USA and elsewhere)
Google Maps (embedded on Contact page)Google LLCShows our office locationsIP address, browser data; Google may set cookiesYes, to Google
Google FontsGoogle LLCTypographyIP address and browser data when fonts loadYes, to Google
WPMU DEV DashboardIncsub LLC (USA)Manages and updates WPMU DEV pluginsSite and admin account dataYes, to WPMU DEV
Forminator ProIncsub LLC (WPMU DEV)Contact and enquiry formsForm fields, submission time, IPStored in our WordPress database; email notifications sent to our team
Defender ProIncsub LLC (WPMU DEV)Security: firewall, malware scanning, login protection, IP lockouts, audit loggingIP address, user agent, login attempts, requested URLsAudit logs and threat data may be stored with WPMU DEV
Hummingbird ProIncsub LLC (WPMU DEV)Performance, caching and CDNIP address when assets are served from the WPMU DEV CDNYes, if CDN is enabled
Smush ProIncsub LLC (WPMU DEV)Image compression and optimisation, image CDNImages uploaded by admins; visitor IP when images are served by CDNYes, images processed and served by WPMU DEV
Snapshot ProIncsub LLC (WPMU DEV)Website backupsFull copy of the site, including form entries and user dataYes, encrypted backups stored in WPMU DEV cloud storage
Branda ProIncsub LLC (WPMU DEV)Admin branding, login screen and cookie noticeConsent preferenceNo

WPMU DEV’s privacy policy is available at wpmudev.com/privacy-policy. Google explains how it uses data from sites that use its services at policies.google.com/technologies/partner-sites. Elementor, Crocoblock and Rank Math publish their own privacy policies on their websites.

5.1 Embedded content from other websites

Pages on this Website may include embedded content, such as Google Maps and downloadable documents. Embedded content from other websites behaves as if you had visited that website directly. Those websites may collect data about you, use cookies, embed additional tracking and monitor your interaction with the embedded content, including if you are logged in to an account with them.

5.2 Google Analytics

We use Google Analytics 4, connected through Site Kit, to understand how visitors use the Website. Analytics runs only after you accept analytics cookies. We have:

  • Enabled Google’s data-processing terms and, where applicable, Standard Contractual Clauses
  • Disabled Google Signals and advertising features
  • Set data retention to 14 months

You can opt out of Google Analytics on all websites by installing the Google Analytics Opt-out Browser Add-on.

6. Cookie Policy

We use strictly necessary cookies to run the Website and, only with your consent, analytics cookies to understand how it is used. We do not use advertising or retargeting cookies.

6.1 What cookies are

Cookies are small text files placed on your device when you visit a website. They let the site remember your actions and preferences for a period of time. First-party cookies are set by upstream-technology.com; third-party cookies are set by other domains, such as google.com. Session cookies are deleted when you close your browser; persistent cookies remain until they expire or you delete them.

6.2 Categories we use

CategoryPurposeConsent needed?
Strictly necessarySecurity, login, form submission, load balancing and remembering your cookie choiceNo, the Website cannot work properly without them
FunctionalRemembering preferences and enabling embedded content such as mapsYes
AnalyticsMeasuring visits and usage through Google AnalyticsYes
MarketingNot usedNot applicable

6.3 Cookies and similar technologies on this Website

Cookie / technologySet byCategoryPurposeDuration
Cookie notice consent cookieBranda Pro (upstream-technology.com)Strictly necessaryStores your cookie consent choiceUp to 12 months
wordpress_test_cookieWordPressStrictly necessaryChecks whether your browser accepts cookies (login page)Session
wordpress_[hash], wordpress_logged_in_[hash]WordPressStrictly necessaryAuthenticates logged-in administratorsSession, or 14 days if “Remember me” is ticked
wp-settings-[UID], wp-settings-time-[UID]WordPressFunctionalStores admin dashboard preferences1 year
comment_author_[hash], comment_author_email_[hash], comment_author_url_[hash]WordPressFunctionalRemembers your details if you leave a comment (only if comments are enabled)1 year
Defender security cookiesDefender ProStrictly necessaryLogin protection, two-factor authentication and lockout handling for administratorsSession to 30 days
Elementor local storage (e.g. elementor)ElementorStrictly necessaryStores page-builder and popup display state in your browserPersistent until cleared
_gaGoogle AnalyticsAnalyticsDistinguishes unique visitors2 years
_ga_[container-id]Google AnalyticsAnalyticsMaintains session state2 years
NID, AEC, SOCS and similarGoogle (Maps, google.com)FunctionalSet by Google when the embedded map loads; used for preferences and securityUp to 13 months

Cookie names and durations may change when providers update their software. We review this list periodically; the list shown in the cookie banner is the most current.

6.4 Managing cookies

  • Cookie banner: when you first visit, you can accept or reject non-essential cookies. You can change your choice at any time using the cookie settings link in the Website footer.
  • Browser settings: you can block or delete cookies in your browser. Guidance is available for Chrome, Safari, Firefox and Edge.
  • Google Analytics opt-out: see section 5.2.

Blocking strictly necessary cookies may stop parts of the Website, such as forms, from working.

7. Sharing, transfers, retention and security

7.1 Who we share your data with

We share personal information only where necessary, and only with:

  • De Beers Group companies, where your enquiry relates to their products, services or operations, or for shared IT, security and compliance functions
  • Operators (service providers) listed in section 5, including our hosting provider, WPMU DEV and Google, under written agreements that require them to keep the information confidential and secure (POPIA section 21)
  • Our web development and maintenance agency, which may access the Website and its database to maintain, update and secure it
  • Professional advisers, such as auditors and legal counsel, under a duty of confidentiality
  • Regulators, law enforcement or courts, where the law requires it or to protect our rights, property or safety
  • A buyer or successor, if our business or part of it is sold or restructured, subject to this policy

7.2 Where your data is sent (cross-border transfers)

Some of our providers, including Google and WPMU DEV, store or process data outside South Africa, mainly in the United States and the European Union. We transfer personal information across borders only as permitted by POPIA section 72, for example where the recipient is bound by law, binding corporate rules or an agreement providing adequate protection (such as Standard Contractual Clauses), or where the transfer is needed to respond to your request.

7.3 How long we keep your data

We keep personal information only as long as needed for the purpose it was collected, or as required by law (POPIA section 14).

InformationRetention period
Form submissions in the Website database24 months after submission, then deleted, unless the enquiry becomes a client relationship
Enquiries forwarded to our email and CRMFor the duration of the business relationship plus the period required by law (generally 5 years for commercial records)
Google Analytics data14 months
Security logs and IP lockouts (Defender)Up to 12 months
Website backups (Snapshot)Rolling backups, overwritten within 90 days
Comments (if enabled) and their metadataIndefinitely, so follow-up comments can be approved automatically
Registered user accounts (administrators)While the account is active; users can see, edit or delete their profile information at any time (except their username)

When retention ends, we delete or de-identify the information securely.

7.4 How we protect your data

We take appropriate, reasonable technical and organisational measures to prevent loss, damage, unauthorised destruction and unlawful access (POPIA section 19), including:

  • HTTPS (TLS) encryption across the Website
  • Firewall, malware scanning, login protection, two-factor authentication and IP lockouts through Defender Pro
  • Encrypted, off-site backups through Snapshot Pro
  • Restricted administrator access on a need-to-know basis, with strong passwords and audit logging
  • Regular updates to WordPress core, themes and plugins

No internet transmission is completely secure. If we become aware of a security compromise affecting your personal information, we will notify the Information Regulator and you as required by POPIA section 22.

8. Your rights

Under POPIA (and the GDPR where it applies) you have the right to:

  • Be informed that your personal information is being collected
  • Access the personal information we hold about you and request details of who has received it
  • Correct or update inaccurate, incomplete or out-of-date information
  • Delete or destroy information we are no longer authorised to keep
  • Object to processing based on legitimate interest, and to direct marketing at any time
  • Withdraw consent where we rely on it (for example, analytics cookies), without affecting earlier processing
  • Data portability and restriction of processing (GDPR)
  • Not be subject to decisions based solely on automated processing
  • Lodge a complaint with the Information Regulator or your local supervisory authority

To exercise a right, contact our Information Officer using the details in section 11. We may ask you to verify your identity. Access requests are handled under our PAIA Manual using Form 2 of the POPIA Regulations; we respond within 30 days. You can also request an exported file of the personal data we hold about you, including data you provided through the Website, and request that we erase it. This does not include data we must keep for administrative, legal or security purposes.

9. Children’s information

The Website is intended for businesses and adults. We do not knowingly collect personal information from anyone under 18. If you believe a child has sent us personal information, contact us and we will delete it.

10. Direct marketing

We send electronic marketing only to existing clients about similar products and services, or to people who have given consent (POPIA section 69). Submitting an enquiry form does not sign you up for marketing. Every marketing message includes a free way to unsubscribe.

11. Information Officer and complaints

Questions, requests or complaints about this policy or your personal information can be sent to:

If you are not satisfied with our response, you may complain to the Information Regulator (South Africa):

12. Links to other websites

The Website links to third-party websites, including the De Beers Group website and downloadable documents hosted elsewhere. We are not responsible for their privacy practices and encourage you to read their privacy policies.

13. Changes to this policy

We may update this policy to reflect changes in law, our practices or the plugins and services we use. The updated version will be posted on this page with a new “Last updated” date. Where changes are significant, we will highlight them on the Website.

14. Contact us

Upstream Technology South Africa (Pty) Ltd

Secret Link