Last updated: October 22, 2025

1. Who We Are and How to Contact Us

Controller: Upwordo, Kortvelyessy, Segantinistrasse 127, Zurich, Switzerland

Contact: upwordo.com/contact

2. Scope

This Policy applies to the Upwordo website and apps, including free and subscription features. Additional terms may apply where you access the Services through Apple or Google.

3. Data We Collect

1. Account and contact data: name, email address, country.
2. Usage and device data: app interactions, feature usage, crash logs, device information, diagnostics.
3. Cookies and similar technologies: used for analytics, performance, and marketing.
4. Payment data: handled by payment processors or app stores. We receive limited information such as payment status and tokens.
5. Communications: messages you send to us, including support requests.

We do not intentionally collect sensitive personal data.

4. Purposes and Legal Bases

1. Providing and maintaining the Services, including authentication, content delivery, and support. Legal basis: contract performance and legitimate interests.
2. Improving and securing the Services, including analytics and debugging. Legal basis: legitimate interests.
3. Marketing communications where permitted, including newsletters. Legal basis: consent or legitimate interests, depending on jurisdiction. You can opt out at any time.
4. Compliance with legal obligations and enforcing our terms. Legal basis: legal obligation and legitimate interests.

Where we rely on consent, you can withdraw it at any time. Where we rely on legitimate interests, we balance our interests against your rights.

5. Cookies and Tracking

We use cookies and SDKs to understand usage and improve performance. On the website we present a cookie banner or settings that let you manage preferences where required. You can also control cookies through your browser or device settings. Blocking certain cookies may affect functionality.

6. Children’s Privacy

The Services are not specifically directed to children under 13. If you are under the age where parental consent is required in your country, you must obtain parental consent before creating an account or using paid features. If we learn we have collected personal data from a child contrary to law, we will delete it. Parents can contact us through the contact form.

7. Sharing of Personal Data

1. Service providers who process data for us, including hosting, analytics, crash reporting, communications, and payments.
2. App stores when you subscribe through those platforms.
3. Professional advisers and authorities where legally required or to protect our rights.
4. Buyers or successors in the event of a merger, acquisition, or asset transfer.

We do not sell personal data.

8. International Transfers

We may transfer personal data outside Switzerland and the EEA. Where we do, we use appropriate safeguards such as adequacy decisions or Standard Contractual Clauses, and we assess transfer risks.

9. Data Retention

We keep personal data only as long as needed for the purposes described, including for legal, accounting, or reporting requirements. Typical retention periods include:

1. Account data: for the life of the account and for a reasonable period after closure.
2. Usage analytics: retained in aggregated or pseudonymized form where possible.
3. Support records: retained to document requests and resolutions.

10. Your Rights

Subject to legal limits, you have the right to:

1. Access your personal data and obtain a copy.
2. Rectify inaccurate or incomplete data.
3. Delete your data.
4. Restrict or object to processing, including processing based on legitimate interests and direct marketing.
5. Data portability for information you provided to us.
6. Withdraw consent where processing is based on consent.

How to exercise your rights:

1. Use in app or account settings where available.
2. Submit a request via upwordo.com/contact. We will verify your identity and respond without undue delay.
3. EU and Swiss users can complain to a supervisory authority. In Switzerland, contact the FDPIC. In the EU, contact your local data protection authority.

11. Security

We use technical and organizational measures appropriate to the risk, including encryption in transit, access controls, and log monitoring. No system is 100 percent secure.

12. Communications

We may send transactional messages about your subscription or account. You can opt out of marketing emails by using unsubscribe links or contacting us. Service announcements may still be sent.

13. Automated Decision Making

We do not perform automated decision making that produces legal or similarly significant effects without human involvement.

14. Changes to this Policy

We may update this Policy. Material changes will be communicated by reasonable means. The date at the top shows when it was last updated.

15. Contact

To contact the controller or exercise your rights: upwordo.com/contact.

Postal address: Upwordo, Kortvelyessy, Segantinistrasse 127, Zurich, Switzerland.