Privacy Policy

UpScrolled believes privacy is a fundamental right, not a feature, of a digital platform. This Privacy Policy explains how UpScrolled B.V. operating as UpScrolled (“UpScrolled,” “we,” “us,” or “our”) collects, uses, shares, and protects your information when you use our platform. This policy applies to information we collect when you use our websites, mobile apps, and other services that link to this Privacy Policy (collectively, the “Services”), as well as when you interact with us through support channels or other communications.

We may update this Privacy Policy from time to time. When we do, we will update the “Last Updated” date above. We encourage you to review this Privacy Policy periodically. Where required by law, we will provide additional notice of material changes through the Services.

What This Policy Covers

Our Approach. UpScrolled is built around you being able to share freely, connect safely, and build community. That means we aim to:

collect only the minimum information needed to operate the platform;
give users meaningful control over their data and visibility;
be transparent about how information is used or processed; and
take a safety-by-design approach.

This Privacy Policy explains:

what information we collect;
how we use that information;
what happens if we share information with others;
your choices and privacy rights; and
additional requirements for certain regions (including the EU and the United States).

Information We Collect

In general, we collect information you provide to us directly, information collected automatically when you use the platform, and information from certain third-party sources. You may provide information directly to us when you:

create an account;
communicate with us; or
sign up for updates or marketing communications.

When you make an account on our platform, you provide basic information to make a user profile. The information you provide may include:

display name and account handle;
your email address; and
month and year of birth.

When you use UpScrolled, we may automatically collect certain information about how you access and interact with the platform. This may include:

IP address;
browser type and language settings;
device type and operating system; or
connection details used to access the Services.

When you access UpScrolled, your IP address may indicate an approximate location (such as country or city). We may use this information to support platform functionality, such as language settings and compliance with regional legal requirements. If you choose to add a location tag to a post, we may collect precise location data at the time the tag is created. You can control this through your device settings.

We use technologies such as cookies, SDKs, and similar tools to:

understand how people use UpScrolled;
improve performance and functionality of the Services;
personalise certain features; or
analyse usage trends.

These technologies help us understand which features are used most often and how users interact with the platform.

Content and Media. When you choose to upload photos, videos, or other media, your device may ask you to grant UpScrolled access to your camera roll or storage. This permission is controlled entirely by your device settings and can be changed at any time. We collect information contained in the content you post or upload, including:

text;
images or photographs;
videos or livestreams; or
other content shared through the Services.

Information from Other Sources. In some cases, we may receive information from third parties. For example:

if you apply for account verification, we may use a third-party identity verification provider to confirm your identity;
if you use a third-party authenticator application for multi-factor authentication, we may receive confirmation data from that service; or
if you interact with UpScrolled through another platform or service, we may receive limited information from that provider.

Use of Information. We use the information we collect to operate, improve, and secure the Services. This includes using information to:

create and manage your account;
provide, maintain, and improve the platform;
allow you to create, share, and interact with content;
personalise your experience;
send technical notices, security alerts, and support messages;
send marketing communications;
analyse usage trends and platform performance;
conduct research, testing, surveys, and troubleshooting;
detect and prevent fraud, abuse, or illegal activity;
enforce our Terms of Service, Privacy Policy, and Community Guidelines;
comply with legal obligations; or
generate aggregated or de-identified data that cannot reasonably identify you.

Analytics. We may work with third-party analytics providers that help us understand how people use the platform. This information is typically aggregated or pseudonymised and used to help us improve the platform and understand user activity. These providers may use technologies such as cookies or SDKs to collect information, including:

IP address;
device information;
usage data; or
interaction patterns within the Services.

Disclosure of Information. We do not sell or trade your personal information to external parties. We may share information with trusted vendors or service providers who perform services for us, such as:

cloud hosting providers;
fraud prevention services;
customer support platforms; or
email and communication service providers.

These partners are required to process personal information in accordance with contractual obligations and applicable data protection laws.

Depending on your account settings, information associated with your profile or posts may be visible:

to other users of the platform;
to the public; or
through search engine indexing.

Legal Requirements. We may disclose information when required to do so by law or legal process, including:

court orders;
government legal orders;
law enforcement investigations; or
national security obligations.

In all of these cases we disclose only the minimum information required by law.

Government and Legal Requests. We may receive requests from governments or law enforcement agencies for user information. When responding to such requests, UpScrolled seeks to:

require a valid legal basis before disclosing information;
review requests for legality and scope;
disclose only the minimum information required by law; or
challenge requests that appear unlawful or overly broad where appropriate.

Platform Safety and Enforcement

We take the safety of our community seriously. In limited circumstances, we may need to share certain information to keep Upscrolled safe and trustworthy. Specifically, we may share information when necessary to:

enforce our Terms of Service, Privacy Policy, or Community Guidelines;
investigate abuse, spam, or malicious activity;
protect the rights or safety of users or the public; or
explain moderation or enforcement decisions.

Trusted Professional Advisors. We may disclose information to trusted professional advisors where necessary, such as:

Lawyers; or
business advisors.

Security. We work to protect your information using technical and organisational safeguards designed to secure personal data. These measures may include:

encryption of data in transit and, where appropriate, at rest;
access controls that limit internal access to authorised personnel;
monitoring systems designed to detect security incidents;
security reviews and testing of platform infrastructure; or
internal policies governing how employees handle personal data.

We implement reasonable safeguards designed to protect and maintain the safety and security of information; however, no system can be guaranteed to be completely secure.

Automated Systems and Moderation. UpScrolled uses a combination of automated tools and human review to help detect and address harmful activity on the platform. For certain categories of serious violations and illegal activity, automated systems may take action to detect and remove content in accordance with applicable law. For other enforcement decisions, automated tools may assist with identifying and prioritising content for review, with human moderators playing a central and final role in the process. These systems may assist with identifying:

spam or coordinated manipulation;
abusive or harmful content;
attempts to bypass platform rules; or
other activity that may violate our Terms of Service, Privacy Policy, or Community Guidelines.

Public Content. UpScrolled is a platform for sharing content with others. Even if you delete content from UpScrolled, copies of that content may remain elsewhere on the internet. UpScrolled does not control how third parties may store, reuse, or distribute information that has already been made public. Depending on your account settings, information you post may be visible to other users or to the public. Public content may be:

viewed by other users of the platform;
indexed by search engines;
shared or reposted by other users; or
copied, archived, or stored by third-party services outside of UpScrolled.

Data Access and Platform Protection. UpScrolled takes steps to protect the integrity and security of the platform and its users. Unauthorised access, collection, or use of data from the platform may result in enforcement actions, including technical restrictions or account suspension. This may include monitoring activity to detect:

automated scraping or bulk collection of platform data;
attempts to extract large volumes of user content or metadata;
activity designed to train automated systems or datasets without authorisation; or
other behavior that may violate our Terms of Service or platform policies.

De-Identified and Aggregated Information. UpScrolled may create and use aggregated, anonymised, or de-identified information that cannot reasonably be used to identify an individual. This information may be used for purposes such as:

analysing platform usage trends;
improving products and services;
conducting research and development; or
generating statistical insights about how the platform is used.

Your Choices

You have control over many aspects of your account and personal information.

Account Information. You may access or update certain information in your account at any time by visiting Account → Settings. You may delete individual posts at any time. You may also control:

whether your account is public or private;
who can see your posts;
what profile information is visible; or
what content you share.

Account Deletion. You may request deletion of your account through Account → Settings. When you request deletion:

your account will be placed in a deletion queue;
data directly associated with your account will be removed from active systems; and
you will receive confirmation once deletion is complete.

Cookies and Tracking Technologies. You can control or disable cookies through your browser settings. Please note that disabling cookies may affect some functionality of the Services.

Communications. You may opt out of marketing communications by following the unsubscribe instructions in the messages. Even if you opt out, we may still send non-promotional communications, such as security alerts or account-related notices.

Push Notifications. With your permission, we may send push notifications to your mobile device. You can disable push notifications through your device settings.

Data Retention. We keep personal information only for as long as necessary to provide the Services and fulfill the purposes described in this policy. Different types of information are retained for different periods depending on their purpose. In general:

Account information is retained for as long as your account is active. When you delete your account, we begin the process of deleting your personal information from our systems.
Content you have posted may take additional time to be removed from backup systems, and copies may continue to exist elsewhere on the internet through search engines, web archives, or third-party services, this is outside of our control.
Safety-related data may be retained for a longer period where required by law or necessary to comply with legal obligations, resolve disputes, enforce our policies, or prevent repeat violations.

International Data Transfers. UpScrolled is headquartered in the Netherlands, and we process and store information on servers located in Ireland. When we transfer personal data across borders, we take steps to ensure appropriate safeguards are in place, such as:

standard contractual clauses;
contractual data protection commitments; or
other legally recognised safeguards.

You may request information about these safeguards by contacting us.

Additional Information for Individuals in Europe

If you are located in the European Economic Area or United Kingdom, the following rights apply under the General Data Protection Regulation (GDPR) and the UK GDPR respectively.

Legal Basis for Processing. We process personal data where we have a legal basis to do so, including as set out below:

To perform our contract with you, including to provide you with the Services, and to enforce the Terms of Service, Community Guidelines and Supplemental Terms as defined in the Terms of Service;
For legitimate business reasons pursued by us or a third party, only where those reasons are not overridden by your fundamental rights and freedoms. This includes processing your personal data for the purposes of detecting and preventing abuse or illegal activity, sending marketing communications, personalising your experience, improving the Services, and analytics;
To comply with legal obligations, including tax, accounting and reporting obligations and responding to government and legal requests; or
With your consent. You may withdraw consent at any time where processing is based on consent.

Minimum Information Retention. Retention periods may vary depending on the type of information and the purposes for which it was collected. We retain personal information only for the legally minimal amount of time:

to provide and maintain the Services;
to comply with legal obligations;
to resolve disputes and enforce agreements; or
to protect the safety and integrity of the platform.

Your Data Protection Rights. Subject to applicable law, you may have the right to:

access your personal data;
request correction of inaccurate information;
request deletion of your personal data;
request restriction of certain processing;
object to certain processing activities; or
receive your personal data in a portable format.

Right to Lodge a Complaint. You have the right to lodge a complaint with the supervisory authority in the country in which you live or work or where the alleged violation occurred. A full list of EEA supervisory authorities can be found here. In the UK, you may contact the Information Commissioner’s Office here.

Age Requirements. Users must be at least 16 years old to sign up for our services. UpScrolled does not knowingly collect or process personal data from individuals under 16 years of age. If we become aware that personal data from a user under 16 has been collected, we will take steps to delete the information as required by applicable law.

Data Controller. For the purposes of applicable data protection laws, the data controller responsible for personal data processed through the Services is:

UpScrolled B.V.
Keizersgracht 391 A, 1016EJ Amsterdam, Netherlands

UK Representative. We have appointed a data protection representative for the UK. You may contact our representative at:

Email: upscrolled@datarep.com
Webform: www.datarep.com/data-request
Mail: DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom

IMPORTANT: when mailing inquiries, it is essential that you mark your letters for ‘DataRep’ and not ‘UpScrolled B.V.’, or your inquiry may not reach our data protection representative in the UK. Please refer clearly to UpScrolled B.V. in your correspondence. On receiving your correspondence by the representative, we are likely to request evidence of your identity, to ensure your personal data and information connected with it is not provided to anyone other than you.

Data Protection Officer. UpScrolled has appointed a Data Protection Officer (DPO) responsible for overseeing privacy and data protection compliance.

Data Protection Officer
Email: privacy@upscrolled.com

Additional Information for Certain U.S. States

We do not sell or trade personal information and do not engage in targeted advertising as defined under applicable state privacy laws. Residents of certain U.S. states, including California, may have additional privacy rights. We collect and disclose certain categories of personal information, including:

identifiers such as name or email address;
internet activity information, such as IP address or device data;
Approximate geolocation information derived from IP address (such as country or city);
audio or visual content such as photos or videos; or
inferred information based on activity.

Your Privacy Rights. We will not discriminate against you for exercising your privacy rights.

Depending on your location, you may have the right to:

access your personal information;
request correction of inaccurate information;
request deletion of your personal information; or
request information about disclosures to third parties.

Data Protection Officer. UpScrolled has appointed a Data Protection Officer (DPO) responsible for overseeing privacy and data protection compliance.

Data Protection Officer
Email: privacy@upscrolled.com

You may contact the DPO for matters including:

questions about this Privacy Policy;
exercising your privacy rights;
concerns about data processing; or
complaints related to data protection.

Children

UpScrolled is intended for users 16 years of age or older. Individuals under 16 are not permitted to create accounts or use the Services. If we learn that personal information from a person under 16 has been collected, we will investigate and delete the information unless obliged by law. Parents or guardians who believe a child has provided personal information should contact safety@upscrolled.com.

Contact Us

If you have questions about this Privacy Policy or about how your information is handled, please contact us. This Privacy Policy is written in English and may be translated into other languages. If any differences occur between translations and the English version, the English version controls.

Previous privacy policy

This policy describes the information we process to support the UpScrolled platform. Additional tools and information can be found in the UpScrolled app settings.

1. Information We Collect

The data gathered while utilising the UpScrolled platform can be categorised into two distinct groups.

1.1. Information you provide us.

When registering, you are required to provide information essential for platform usage. This includes a display name (e.g., “User”), a handle (e.g., @User), a password, an email address, and your date of birth. Your date of birth is never displayed to other users and is used solely to verify your age in accordance with our Terms of Service.You may also provide additional information in your bio. While profile information such as your display name, bio, and handle is always publicly visible, you may choose to use either your real name or a pseudonym.Preferences are also collected when you customise your settings, enabling us to respect your choices accordingly.

1.2. Information we collect when you use UpScrolled app.

When using the UpScrolled platform, we may gather information regarding your usage patterns to enhance functionality, maintain security, uphold respectfulness, and tailor the experience to your preferences.Usage Information. This encompasses various aspects of your activity on UpScrolled, including:

Posts and other content you generate, alongside details like posting date and the UpScrolled app version used.
Interactions with content from other users, such as shares, likes, downloads, bookmarks, comments, as well as instances where you or others are mentioned or tagged.
Your engagements with fellow platform users, including those you follow, those who follow you, and metadata associated with messages.
Communication with us via email, with relevant information collected regarding the interaction and its content.
Tracking of links interacted with across the platform, including those embedded in emails sent to you.
The utilisation of various components of the platform, including the video or photo editor, user journey analytics, and other features, may entail the collection of data even if it is not necessarily identifiable.

Device Information. We may collect data pertaining to the devices you employ to access UpScrolled, covering:

Connection details such as IP address, browser type, and related parameters.
Device specifics like type, operating system, carrier, language, and memory capacity configurations.
Location Information: We may collect information about your approximate location, derived from your IP address. This information is not precise and may indicate details such as your country, city, or district. This is a standard practice to support core platform functions.

Inferred Identity Information. We might gather or receive data used to deduce your identity, including:

Device association with your account upon signing in, and potential linkage with other devices based on settings.
Use of provided information (e.g., email addresses) to establish connections with your UpScrolled account, potentially inferring additional identity details based on shared components.
Identity inference when accessing UpScrolled without signing in, based on collected information.

Log Information. Even if you haven’t created an account or are signed out, we may receive information when you interact with our platform, including:

IP address, browser details, operating system, referral sources, access times, visited pages, approximate location data, mobile carrier details and device identifiers.
Cookies and Similar Technologies: We employ cookies and similar tools for enhanced website usage data collection and platform operation, albeit not mandatory for many platform functions like searches and viewing public profiles.

Crash Reports and Diagnostics. We use third-party service to collect crash reports and diagnostic information to improve the functionality and performance of our app. This section explains what data we collect, how we use it, and how we ensure compliance with privacy regulations.

Device Information: Model, operating system version, and app version.
Crash Details: Error messages, stack traces, and data about the actions leading to the crash. They do not include your personal message content, photos, videos, or the contents of device memory.
User Interactions: Information about how the app was being used when the crash occurred.
Anonymized Identifiers: Randomly generated user or session IDs (when applicable).

2. How We Use Information

Describing how we utilise the information we gather can be complex due to the intricacies of our platform’s operational systems. Nonetheless, we’ve identified five primary ways in which we leverage this information, aimed at enhancing your experience while maintaining transparency. If you have any unanswered questions, feel free to contact us.

2.1. Operate, Improve, and Personalise Services

We may utilise collected data to operate the UpScrolled platform effectively. This includes enhancing and customising your experience by providing more relevant content, suggesting connections, and refining our algorithms (if applicable). Your control over personalised content is paramount, and you can adjust these settings within your account preferences. Additionally, your contact information may aid others in locating your account, subject to your settings. If you do not see such settings in your account preferences, it indicates that we are not employing such methods yet.

2.2. Foster Safety and Security

Ensuring the safety and security of our users, platform, and your account is of utmost importance. We employ collected information to verify identities, authenticate accounts, and safeguard against fraudulent activities and unauthorised use. Furthermore, we assess and maintain the safety and quality of content on UpScrolled by enforcing policies, terms, and applicable laws.

2.3. Measure, Analyse, and Improve Services

Collected data is utilised to measure and analyse the platform’s effectiveness and user behaviour, aiding in its continuous improvement. Understanding how you interact with UpScrolled helps us enhance its functionality and user experience.

2.4. Communicate Platform Updates

We use gathered information to keep you informed about platform updates, policy changes, and terms revisions, ensuring transparency and clarity in our communication with users.

2.5. Research

Information shared with us or collected is utilised for research, surveys, product testing, and troubleshooting purposes. This assists us in refining and enhancing the overall operation of the platform.

The platform will handle the data in compliance with the applicable regulations outlined in the General Data Protection Regulation ((EU) 2016/679) (“GDPR”).

By delineating these key usage areas, we aim to provide clarity on how your information contributes to the functionality and integrity of the UpScrolled platform.

3. Sharing Information

Understanding how we share your information, why we do so, and how you can control it is crucial. There are three main ways we share your information:

3.1. When You Post and Share

With the General Public: By posting content on UpScrolled, you’re consenting to its disclosure to the widest audience possible. This includes your profile information (e.g., name/pseudonym, handle, profile pictures), which can be viewed by anyone, even those not signed in to UpScrolled. Additionally, UpScrolled content may appear in search engine results outside of the platform.
With Other UpScrolled Users: Depending on your settings, we may share interactions you have with other users’ content, such as likes, and the people you choose to follow.

3.2. With Third Parties & Third-Party Integrations

We use service providers to host, process, and analyse data on our behalf under strict data processing agreements. They may not use your data for their own purposes. Categories include cloud hosting, content delivery, analytics, crash reporting, and customer support.

3.3. When Required by Law, to Prevent Harm, or in the Public Interest

We may disclose or preserve information only when required by valid Australian legal process. This includes:

Non-content data in response to a subpoena, court order, or similar lawful process.
Content data only with a search warrant or equivalent issued by an Australian authority with jurisdiction.
Foreign government requests, which must first proceed through a Mutual Legal Assistance Treaty (MLAT) or another recognized channel that results in valid Australian legal process.
Emergencies involving an imminent risk of death or serious harm, where we may disclose the minimum necessary information.
Address fraud, security, or technical issues.
Safeguard the safety of individuals or the integrity of our platform, including prevention of spam, abuse, or malicious activity.
Provide explanations for content or account removals.
Protect our rights, property, or the rights and property of our users.

4. How Long We Keep Information

We maintain different types of information for varying durations:

4.1. Profile Information and Content

We retain your profile information and usage data, including the content you post, your interactions with others, and how you engage with content on the platform, for the duration of your account’s existence or until such content is removed. Retaining this information is necessary in order to provide you with access to our products and services.

4.2. Communication Records

When you communicate with us, for example by email, we retain records of the communication and its content for up to 18 months. In some cases, we may keep this information longer if it is necessary to meet our legal obligations or to establish, exercise, or defend legal rights.

4.3. Violation of Rules

In cases where you violate our rules and your account is suspended, we may retain the identifiers used to create the account (e.g., email address) indefinitely. This measure aims to prevent repeat policy offenders from creating new accounts.

4.4. Legal Compliance and Safety

Upon a valid preservation request or legal hold, we retain only the specific data necessary for the required period; otherwise, our standard retention schedule applies.

4.5. Other data points

Operational and diagnostic data such as crash reports, error logs, and related technical information are retained solely for functionality, performance, and security purposes. These records are not used to identify users and are stored for a maximum of 12 months, after which they are deleted.

4.6. Public Content Reminder

It’s important to note that public content may persist elsewhere even after removal or dissociation from the UpScrolled platform. Search engines and other third parties may retain copies of your posts for extended periods, governed by their own privacy policies.

By outlining these data retention practices, we aim to uphold transparency and accountability regarding the storage and handling of user information on the UpScrolled platform. If you have any concerns or questions regarding data retention, please feel free to contact us.

5. Take Control

5.1. Access, Correction, Portability

You maintain the ability to access, correct, or amend the information you have provided to us by editing your profile and adjusting your account settings.To ensure privacy protection and security maintenance, we may take measures to verify your identity before granting access to your personal information or fulfilling requests for deletion, portability, or other related actions. In certain instances, we may decline access, correction, or portability requests, particularly if identity verification is unsuccessful.At present, we do not yet offer a self-service download tool for your data; however, this functionality will be made available in a future update.

5.2. Deleting Your Information

Through your account settings, you have the option to request the deletion of your account. Upon initiating such a request, your account and associated data will be promptly
queued for deletion. A confirmation email will be sent to you once the deletion process is completed. While physical deletion may take some time, data association linked to your account will be promptly removed from our service where feasible and become inaccessible by other users or public.

5.3. Authorised Agent Requests

If you are an authorised agent seeking to submit a request related to access, modification, or deletion of your information, or that of another individual on their behalf, you may also
contact us. Additional information may be required for verification purposes to process such requests.

6. Your Rights and Ours

We offer UpScrolled to users worldwide and extend many privacy tools and controls universally. However, your experience may vary slightly depending on your location to ensure compliance with local regulations.

6.1. Legal Bases for Data Usage

UpScrolled has meticulously identified the legal grounds enabling the collection, usage, sharing, and processing of your information. It’s important to note that we do not engage in the sale of your personal information.

6.2. Data Movement to Support UpScrolled Functionality

UpScrolled facilitates seamless global interactions among users from diverse countries. To ensure the smooth and reliable operation of our service, information needs to be transferred across borders and between different countries. For instance, if you’re conversing with someone in Europe or the United States while residing in a Middle Eastern country, data must traverse these regions to facilitate the interaction, aligning with your expectations.

Additionally, we leverage data centres and cloud providers situated across various parts of the world to bolster our service delivery. However, our primary aim is to physically store data within Ireland. This approach enables us to maintain consistency in our service while prioritising data protection and privacy compliance.

7. UpScrolled’s Audience

Our platform is not intended for children, and individuals under the age of 16 are prohibited from using it. Moreover, users must be of legal age to consent to the processing of their personal data in their respective countries. In certain jurisdictions, we may permit a parent or guardian to provide consent on behalf of a minor.

8. Changes To This Privacy Policy

The latest edition of this Privacy Policy regulates our handling of your personal data, and we reserve the right to update it as necessary. Should revisions occur, and if we deem the changes to be significant, we will notify you and offer the opportunity to review the updated Privacy Policy before you proceed with using UpScrolled.

9. General

The UpScrolled Privacy Policy is currently available in both Arabic and English. While we endeavour to ensure the accuracy of translations with future updates, in the event of any discrepancies or inconsistencies, the English versions of the UpScrolled Privacy Policy will prevail. You acknowledge that Arabic or English shall serve as the authoritative language for interpreting and constructing the terms of the UpScrolled Privacy Policy.

10. How To Contact UpScrolled

We value your feedback and encourage you to reach out if you have any thoughts or questions about this Privacy Policy. Your input is important to us, and we’re here to address any concerns you may have. Please feel free to contact us at any time!

Privacy Policy

أمير ناثو

أمير ناثو

Amir Nathoo

Amir Nathoo

غابرييلا بورد

غابرييلا بورد

بادي كوسغريف

بادي كوسغريف

Gabriella Bord

Gabriella Bord

Paddy Cosgrave

Paddy Cosgrave

Paul Biggar

Paul Biggar