GDPR COMPLIANCE: Upskrol fully complies with the General Data Protection Regulation (GDPR) (EU) 2016/679. This privacy policy explains how we collect, use, and protect your personal data.
1. Data We Collect
We collect the following categories of personal data:
Category
Data Types
Purpose
Legal Basis
Account Data
Email address, username, encrypted password, profile picture, bio
Create and manage your account, authenticate you, display your profile
Contract performance (Art. 6(1)(b))
User Content
Videos, comments, likes, saved videos, watch history
Provide core app functionality, personalize feed, enable social interactions
Contract performance (Art. 6(1)(b))
Device Information
IP address, device type, operating system, browser type, app version
Legal/Government Authorities: Compliance with court orders, DMCA notices, legal requests - As required by law
We do NOT sell your personal data to third parties.
6. International Data Transfers
EU Standard Contractual Clauses (SCCs) with our service providers
Data Processing Agreements (DPAs) with all third-party processors
GDPR-compliant data transfer mechanisms
7. Your Rights (GDPR & CCPA)
For EU Residents (GDPR):
Right to Access: Request a copy of your personal data
Right to Rectification: Correct inaccurate or incomplete data
Right to Erasure ("Right to be Forgotten"): Request deletion of your data
Right to Restrict Processing: Limit how we use your data
Right to Data Portability: Receive your data in a machine-readable format
Right to Object: Object to processing based on legitimate interests
Right to Withdraw Consent: Withdraw consent for optional data collection
Right to Lodge a Complaint: File a complaint with the Dutch Data Protection Authority
For California Residents (CCPA):
Right to Know: Request disclosure of data collected and shared
Right to Delete: Request deletion of personal data
Right to Opt-Out: Opt-out of data sales (we do not sell data)
Right to Non-Discrimination: Equal service regardless of rights exercised
How to Exercise Your Rights:
Email privacy@upskrol.com with your full name and username, the right you wish to exercise, and any specific data requests. We respond within 30 days (GDPR requirement).
8. Data Security
Encryption: Passwords hashed with bcrypt, data encrypted at rest and in transit (TLS 1.3)
Access Control: Strict role-based access to user data
Monitoring: Security logging and intrusion detection
Regular Audits: Security assessments and vulnerability scans
9. Cookies and Tracking
Essential cookies: Authentication, security, app functionality (cannot be disabled)
Analytics cookies: Understand usage patterns (can be disabled in settings)
Preference cookies: Remember your preferences
10. Children's Privacy
Upskrol is intended for users aged 16 and older. We do not knowingly collect data from children under 16. If we discover a user under 16, we will delete their account and all associated data.
11. Account Deletion
In-app: Settings → Account → Delete Account
Email request: Send request to privacy@upskrol.com