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KeepUpp Legal Info

This Privacy Policy applies to the processing of personal data in relation with the mobile application named "KeepUpp" ("KeepUpp " or the "App ") by KeepUpp SRL ("we ", "us " or "our "), incorporated and operating under the laws of Belgium (VAT Number: BE0775.702.664), having its registered office at Drève Richelle 161 M/57, 1410 Waterloo, Belgium.

If you don't live in the European Region, KeepUpp SRL provides the Services to you under specific Terms of Service and Privacy Policy.

Click here for the KeepUpp Contract Summary and for information we are required by the European Electronic Communications Code to provide.

We provide the services, including the App, to you ("Services ") if you live in a country or territory in the European Economic Area (which includes the European Union), and any other included country or territory (collectively referred to as the "European Region ") under the Terms of Service and this Privacy Policy.

1. Purpose

1.1Our Privacy Policy ("Privacy Policy") explains our data practices, including the information we process to provide our Services.

1.2For example, our Privacy Policy talks about what information we collect and how this affects you. It also explains the steps we take to protect your privacy, like building our Services and giving you control over who you communicate with on our Services.

1.3This Privacy Policy applies to all of our Services unless specified otherwise.

1.4Please also read our Terms of Service ("Terms"), which describe the terms under which you use and we provide our Services.

2. Information We Collect

2.1 Overview

2.1.1 The types of information we receive and collect depend on how you use our Services. We require certain of Your Account Information in accordance with our Terms to deliver our Services and without this we will not be able to provide our Services to you. For example, you must provide your mobile phone number, first name and last name, and gender to create an account to use our Services.

2.1.2Our Services have optional features which, if used by you, require us to collect additional information to provide such features. You will be notified of such a collection, as appropriate. If you choose not to provide the information needed to use a feature, you will be unable to use the feature. For example, you cannot share your Precise Location Information with your contacts if you do not enable location sharing on your device. Permissions can be managed through your device-based settings on both Android and iOS devices.

2.2 Information you provide

2.2.1Your Account Information. You must provide your mobile phone number, first name, last name, gender, and choose a username to create a KeepUpp account. If you don't provide us with this information, you will not be able to create an account to use our Services. You can add other optional information to your account, such as a profile picture, and "about" information.

2.2.2Status Information. You can choose to share your Status, which is also end-to-end encrypted.

2.2.3Precise Location Information. We enable you to share your Precise Location Information from your device when you choose to use location-related features, like when you decide to share your current location with, or send live location to your contacts, or view locations nearby. Precise Location Information that you share with your contacts is encrypted so we cannot see it. You can control your Precise Location Information sharing in your in-app settings and your device-based settings.

2.2.4You may also provide content that is not encrypted which means that we can see it. This includes your profile picture, your "about" information and names and descriptions of your groups.

2.2.5Your Connections. You can use contact upload and provide us with the phone numbers in your device address book on a regular basis, including those of users of our Services and your other contacts. We also collect information on users who contact you that aren't in your device address book and any users you've unshared or who have unshared you.

2.2.6Your Group Information. You can create, join, or get added to groups and broadcast lists, and such groups and lists get associated with your account. You give your groups a name. You can provide a group profile picture or description. We also collect information about when groups are created or updated.

2.2.7Customer Support Information And Other Communications. When you contact us for customer support or otherwise communicate with us, you may provide us with information related to your use of our Services, including copies of your messages, any other information you deem helpful in order for us to understand and resolve your query, and how to contact you (e.g., an email address). For example, you may send us an email with information relating to app performance or other issues. We also collect information on how you use our customer support features (e.g., the searches you make on our Help Center) and any feedback you give us on the customer support experience.

2.2.8Account Access Information. When you sign up or log-in to our Service, we verify your login.

2.3 Automatically Collected Information

2.3.1Usage Information. We collect information about your usage of our Services. This includes collecting information about your activity (including how you use our Services), how you interact with others using our Services, and the time, frequency, and duration of your activities. This also includes information about the features you use.

2.3.2Log And Troubleshooting Information. We collect information about how our Services are performing when you use them, like service-related diagnostic and performance information. This information includes log files, timestamps, diagnostic or crash data, website performance logs and error messages or reports.

2.3.3Device And Connection Information. We collect device and connection-specific information when you install, access, or use our Services. This includes information such as hardware model, operating system information, battery level, signal strength, app version, browser information, mobile network, connection information including whether you are using wifi or cellular data, mobile operator or internet service provider (ISP), language and time zone, IP address, device operations information and identifiers.

2.3.4General Location Information. Even if you do not choose to use our precise location-related features, we use IP addresses and other information like phone number area codes, to estimate your general location (e.g., country).

2.3.5Cookies. We collect information using cookies to operate and provide our web-based Services and website.

2.3.6User Choices. We collect information about your in-app settings, privacy settings and records about when you accepted our Terms. Only you are in control of your privacy settings which can be used to change who can see your “last seen”, profile photo, “about” information, Status updates, read receipts or add you to groups. We also collect information about whether you have enabled push notifications.

2.3.7Authentication Information. To verify and grant appropriate authorisations as you use the Services, we create and store authentication codes which are a security measure to ensure only you are accessing your account.

2.4 Information Third Parties Provide About You

2.4.1Information Others Provide About You. We receive information about you from other users. For example, when other users you know use our Services, they may provide your phone number if they use contact upload just as you may provide theirs. We require each of these users to have lawful rights to collect, use, and share your information before providing any information to us.

2.4.2User Reports. Just as you can report other users, other users or third parties may also choose to report to us your interactions with them or others on our Services; for example, to report possible violations of our Terms or policies. When a report is submitted to us through the reporting tools, we receive information from the reporter on both the reporting user and those reported.

2.4.3Businesses. When businesses you interact with while using our Services provide us with information about their interactions with you, we require each of these businesses to act in accordance with applicable law. Some businesses might be working with third-party service providers to help manage their communications with their customers. For example, a business may give such third-party service providers access to its communications to send, store, read, manage or otherwise process them for the business. To understand how a business processes your information, including how it might share your information with third parties, you should review that business's privacy policy or contact the business directly.

2.4.4Third-Party Services. We receive information about bad actors and abuse and app verification information from anti-abuse services to promote safety, security and integrity. For example, when we become aware of a scam encouraging individuals to contact a phone number via KeepUpp, we might share that phone number with third-parties so we can investigate the KeepUpp account. We also allow you to use our Services in connection with third-party services. If you use our Services with such third-party services, we may receive information about you from them. Please note that when you use third-party services, the terms and privacy policies of the company that offers those services will govern your use of those services.

3. Information Shared By You And By Us With Third Parties

3.1You share your information as you use and communicate through our Services, and we share your information to help us operate, provide, improve, understand, customise and support our Services.

3.2Send Your Information To Those With Whom You Choose To Communicate. You share user content when you communicate through our Services. You are in control of what you are sending when you send your information to the individual or business KeepUpp users you choose to communicate with. Please be mindful that, once you have sent user content to a KeepUpp user, they can store or reshare it with others on and off our Services.

3.3Information Associated With Your Account. Those users who have access to your KeepUpp profile can see your information.

3.4Information Shared By KeepUpp With KeepUpp's Users. We share your information with other KeepUpp users to suggest these users to contact you.

3.5Third-Party Services. When you, or other users you interact with, use third-party services that are linked through our Services, the providers of those services or products may receive the information about you that you or others share with them. If you interact with a third-party service through our Services, information like your IP address and technical information showing that the request comes from a KeepUpp app, may be provided to the provider of such service or products. Please note that when you use third-party services, their own terms and privacy policies will govern your use of those services and products.

3.6Third-Party Service Providers. We work with third-party service providers to help us provide our Services. When we share information with third-party service providers in this capacity, we require them to use your information on our behalf in accordance with our instructions and terms. We work with the following different types of third-party service providers: (i) telecommunications technology providers to send you SMS messages, or call you, to verify your account. To be able to provide these services, these providers receive Your Account Information (phone number) and Account Access Information (verification codes to enable you to verify a new phone number or device connected to your account). The providers we currently use are located in Sweden, the Netherlands, the UK and the United States (b) a content safety technology service provider that helps us to maintain the safety and integrity of the Services by detecting and helping us to prioritize harmful material for our reviewers to assess. To provide these services, this provider receives certain images from User Reports (images), Your Account Information (profile picture) and Your Group Information (group profile picture). The provider we currently use is located in the United States; and (c) a location data provider to enable you to share your location or a nearby place with other KeepUpp users. To be able to provide these services, this provider receives Precise Location Information (your current location and other locations you choose on the map). The provider we currently use is located in the United States.

4. How And Why We Process Your Information And Our Legal Basis For Processing

4.1Under applicable data protection law in the European Region (such as the GDPR), companies must have a legal basis to process information. We rely on different legal bases to process your information for the various purposes described in this Privacy Policy.

For each legal basis below, we describe the purposes of our processing (why we process your information) and our processing operations (how we process your information to achieve each purpose).

4.2You also have particular rights available to you depending on which legal basis we use, and we have explained these below. You should know that no matter what legal basis applies, you always have the right to request access to, rectification of, and erasure of your information.

4.2Processing Necessary To Perform Our Contract With You. We process information as necessary to conclude and perform our contract with you, our Terms. This processing is set out below. We process your information:

4.3.1To operate, provide, improve, customize, and support our Services

4.3.2To assist you in creating and managing your KeepUpp account by:

  • collecting and verifying your phone number by sending you a verification code via SMS or by calling you.
  • checking the operating system and other features of your device to set up KeepUpp correctly on your device and running security checks to make sure you don't already have an account or a phone number that is banned from KeepUpp.
  • recording your User Choices, including the Terms you accepted, your privacy settings and the users you have unshared.
  • facilitating you adding additional Account Information such as a profile picture, "about" information which is displayed to people who have your phone number, in line with your privacy settings.
  • changing the phone number or email address associated with your KeepUpp account when you update it.
  • deleting your account, at your request or in accordance with our Terms. We may take steps to ban your account if there is a breach of our Terms, for example a breach of our "Acceptable Use of Our Services" terms.
  • enabling you to re-register your account when it has been deactivated or locked.

4.3.3To generally operate, provide and improve our Services, we:

  • analyse log information to resolve crashes and user issues.
  • collect information for troubleshooting, diagnostics and debugging.
  • collect and aggregate metrics to monitor service performance, reliability, and efficiency, so we can ensure and optimise service quality.
  • test out new features to see if they work, undertake experimentation to evaluate the impact of new features and track adoption metrics (e.g. percentage of users updating their Status).
  • collect and aggregate activity and system events to understand at coarse breakdowns like country level or application version level how and how often the service is being used.

4.3.4To help you discover if your contacts are KeepUpp users when you choose to sync your device's address book using contact upload, we:

  • regularly identify other KeepUpp users in your address book and store cryptographic hash values of the phone numbers of your contacts who are not KeepUpp users, so we can quickly update your KeepUpp contacts if those contacts sign-up to KeepUpp at a later date.
  • remove contacts from your KeepUpp contact list if one of your contacts no longer has an account or activate the "Unshare" function in KeepUpp.

4.3.5To send your some of your information to other KeepUpp users to suggest them to contact you

4.3.6To allow you to create and connect in Groups to communicate with multiple contacts at the same time, we:

  • check that phone numbers you are trying to add to a group are KeepUpp users and check to ensure that their admission to the group is in line with their privacy settings.
  • check to ensure that the group name and optional group description meets KeepUpp requirements.
  • store information about the group and its participant users (including any pending participant users) to ensure that the appropriate privileges are applied and assign the creator of the group as an admin so that they can control and personalise the group's information and settings.
  • when a group is active, log when you send invites to new group participants and expire non-accepted invitations within a set period.
  • notify participants in the group of certain key changes to the group, such as changes to the group name, description or profile picture.
  • temporarily store information to protect you from being re-added to groups you chose to leave and store the phone numbers of participants who are banned from groups to ensure that they cannot rejoin. This information is also used to help identify any suspicious users or abusive behaviour where there is a high turnover of participants.
  • appoint a new random group admin when the current admin (or admins) leave the group/delete their account.
  • delete a group when its last member leaves.

4.3.7To ensure the safety, security, and integrity of our Services. We use information we have and apply automated data processing techniques and, in some instances, conduct manual (human) review to:

  • verify accounts on an ongoing basis, and check that user sign-ups are genuine.
  • log events and aggregated counts about Group and user actions on our Services (like the number of groups joined) and related sequences like patterns in registration and repetitive or identical User Reports to identify and investigate suspicious users, abusive behaviour or where a fake KeepUpp app or an imitation of our Services is being used.
  • investigate and address violations of our Terms. For example, we may ban your account when we learn that you are engaged in infringing activities.
  • detect, prevent and combat harmful or unlawful behaviour, such as to combat scraping by bad actors at scale, to detect and prevent spam, and bad experiences.
  • collect app verification information from anti-abuse services to aid our integrity-related efforts.

4.3.8Transfer, store or process your information outside the European Economic Area. As the KeepUpp service operates globally, with users and businesses around the world, we need to share information we collect globally, where the data centers we rely on are located and externally with our Third-Party Service Providers. We carry out necessary transfers outside the European Economic Area, including to the United States and other countries to:

  • operate and provide our Services. We also allow you to share information and connect with your family and friends around the globe; and
  • allow us to fix, analyse and improve our Services.

4.3.9Communicate with you on Services-related issues, we:

  • identify relevant Service-related notifications for you, send them to you and keep a log when you have received the notification. For example, when our Terms are updated we'll provide a notification about the update.

4.3.10Provide customer support by:

  • processing requests for support and/or searches you make within the KeepUpp Help Center, in the app or via the KeepUpp website.
  • responding when you request our help such as assisting with your account login or verification process.

4.3.11When we process information you provide to us as necessary to perform our contractual relationship with you, under applicable data protection laws you have the right to port it.

The other legal bases we rely on when processing your information and the circumstances in which we rely on them are set out below:

4.4Your Consent. We process information for the purposes described below when you have given us your consent to enable particular product features in your device-based settings. We process your information for collecting information through the device-based settings which you have enabled, for example:

  • sharing your device's Precise Location Information if you choose to use our location-related features. You can share your current location with or send your live location to your contacts or view a nearby place on your map. When your live location is being shared, the live location control in your privacy settings shows which chats your live location is being shared in. Precise Location Information which you share in your chats is end-to-end encrypted which means that it cannot be seen by KeepUpp.
  • accessing your camera and / or photo gallery if you choose to share photos or media with your KeepUpp contacts. Photos and media that you share in your personal chats are end-to-end encrypted.

4.5When we process your information based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before the consent is withdrawn. To exercise your rights, visit your device-based settings and your in-app settings.

4.6Compliance With A Legal Obligation. We process information to comply with a legal obligation including, for example, to access, preserve or disclose certain information if there is a valid legal request. For processing information when we comply with a legal obligation including, for example, to access, preserve or disclose certain information if there is a valid legal request from a regulator, law enforcement or others. For example, a search warrant or production order from law enforcement authorities to provide information in relation to an investigation, such as your profile picture or IP address.

4.7Protection Of Your Vital Interests Or Those Of Another Person. We process your information for protecting your vital interests or those of another person. We apply automated processing techniques and conduct manual (human) review. We share information with law enforcement and others, in circumstances where someone's vital interests require protection, such as in the case of emergencies. These vital interests include protection of your or someone else's life, physical or mental health, wellbeing or integrity or that of others. In protecting such vital interests we aim to combat harmful conduct and promote safety, integrity and security. For example, we investigate reports of harmful conduct and take appropriate action, such as sharing information with relevant authorities, where there is a risk of imminent harmful conduct such as an attack or where a person's safety is at risk.

4.8 Legitimate Interests. We rely on our legitimate interests or the legitimate interests of a third-party, such as our users, where they are not outweighed by your interests or fundamental rights and freedoms ("legitimate interests"):

4.8.1In our interest to measure the use of our Services and count the people who interact with the KeepUpp services in order to inform and improve product direction and development and to enable provision of accurate and reliable reporting. Therefore:

  • we count users and events for reporting to identify how many users KeepUpp has (and similar metrics) so we can share these metrics with affiliates, regulators and the public.
  • we validate metrics to understand how and how often our Services are used in order to inform and improve product direction and development and forecast future adoption of the service or features.

4.8.2It is in our interest and in the interest of KeepUpp users to prevent and address fraud, unauthorized use of KeepUpp, violations of our Terms and policies, or other harmful or illegal activity. It is in our interest to protect ourselves (including our rights, personnel, property or products), our users or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm. The general public and industry partners/peers such as other online platforms and technology companies have a legitimate interest in having abusive or illegal behaviour investigated and combated. Therefore:

  • we preserve and share information with others including law enforcement and to respond to legal requests. This includes responding to legal requests where we are not compelled by applicable law but have a good faith belief it is required by law in the relevant jurisdiction or sharing information with law enforcement or industry partners/peers such as other online platforms and technology companies to combat abusive or illegal behaviour. For example, we preserve a snapshot of user information when requested by law enforcement where necessary for the purposes of an investigation.
  • We may also report illegal or infringing content to law enforcement, government or other authorities.

4.8.3It is in our interest and in the interest of KeepUpp users to respond to complaints, prevent and address fraud, unauthorized use of KeepUpp, violations of our Terms and policies, or other harmful or illegal activity. It is in our interest to seek legal advice and protect ourselves (including our rights, personnel, property or products), our users or others, including as part of investigations or regulatory inquiries and litigation or other disputes. To this end, we preserve and share information when we seek legal advice or seek to protect ourselves in the context of litigation and other disputes. This includes matters such as violations of our Terms and policies.

4.8.4It is in our interest and in the interest of KeepUpp users to secure KeepUpp systems and fight spam, threats, abuse, or infringement activities and promote safety and security on the Services. It is also in our interest to ensure our Services are used in accordance with the Terms. To promote safety, integrity and security outside of the performance of our contract with you, we:

  • log User Reports and patterns of account compromises to understand the techniques being used by the bad actors that interfere with the Services.
  • analyse users' Device and Connection Information to identify and investigate patterns of suspicious behaviour or violations of our policies and Terms

4.8.5It is in our interest and in the interest of KeepUpp users to continuously improve and develop the customer support we provide. To improve the KeepUpp customer support service, we:

  • track information about your interactions with our customer support team to understand if issues are being resolved in a timely manner and whether the information provided in our FAQs are helpful.
  • run quality assurance checks on our interactions with our customers
  • request and review information you provide in customer satisfaction feedback surveys.
  • log search queries in our Help Center to build an index of common search queries to keep our help centre up to date with relevant content.

4.8.6You have the right to object to, and seek restriction of, this processing.

5. How To Exercise Your Rights

5.1Under applicable data protection law, you have the right to access, rectify, port, and erase your information, as well as the right to restrict and object to certain processing of your information.

5.2This includes the right to object to our processing of your information for direct marketing and the right to object to our processing of your information where we are pursuing our legitimate interests or those of a third-party. We will consider several factors when assessing an objection including: your reasonable expectations; the benefits and risks to you, us, other users, third parties; and other available means to achieve the same purpose that may be less invasive and do not require disproportionate effort. Your objection will be upheld, and we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons.

5.3You can object to our processing of your information and learn more about your options to restrict the way we use your information by going here. If we use your information for direct marketing, you can always object and opt out of future direct marketing messages using the unsubscribe link in such communications.

5.4You can access or port your information by contacting us as provided for in article 12.

5.5When we process information you provide to us based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. To withdraw your consent, please contact us.

5.6You have the right to lodge a complaint with KeepUpp's lead supervisory authority under the GDPR, the Belgian Data Protection Authority, or any other competent data protection supervisory authority.

6. Retention Of Your Information

6.1We store information for as long as necessary for the purposes identified in this Privacy Policy, including to provide our Services, or for other legitimate purposes, such as complying with legal obligations, enforcing and preventing violations of our Terms, to fight spam, or protecting or defending our rights, property and users. The storage periods are determined on a case-by-case basis that depends on the following factors:

6.2The nature of the information and why it is collected and processed. The length of time we will keep your information will generally be determined by how long we need that information to provide you with our Services, including any optional features you use and to provide customer support. For example:

  • As described above, we require certain of Your Account Information to deliver our Services. We need to keep it for the lifetime of your account so that we can maintain your account.
  • We keep your User Choices for the lifetime of your account.
  • We keep Authentication Information for the lifetime of your account.
  • We only need to keep other information as long as necessary to provide optional features to you, such as Your Connections as long as you use contact upload.
  • We keep information collected using Cookies for 90 days.
  • We generally keep customer support communications for 30 days after they have been dealt with or 90 days after we receive them, whichever is sooner.
  • We generally keep User Reports for 90 days.

6.3In certain cases, we need to keep your information for longer for legal reasons. In certain cases, we also keep your information for legal reasons, including after your account has been deleted. We keep your information:

  • To respond to a legal request or to comply with applicable law when we have a legal obligation to retain information. For example, if we receive a valid legal request, such as a preservation order or search warrant, related to your account, we preserve your information after you delete your account.
  • To deal with and resolve requests and complaints. For example, we generally retain correspondence relating to data subject requests under GDPR for a year, in case those requests are not resolved and this correspondence is required in order to handle any resulting complaints. In such cases, the correspondence is then retained while those complaints are being resolved.
  • For litigation or regulatory matters. For example, we preserve your information where it is reasonably necessary for reasons related to a legal claim or complaint, such as where we are subject to a regulatory investigation or we need to defend ourselves in legal proceedings about a claim related to your information or respond to a regulator in relation to a complaint made by you or someone else.
  • Issues relating to the safety, security and integrity of our Services and to protect rights, property and users. For example, we keep information where it is necessary to investigate misuse of our Services, such as spam and other bad experiences. If we disable an account for violating our Terms, we also preserve information about that user for safety, security and integrity purposes.

6.4The actual information that we keep and how long we keep it for depends on the nature of the reason in question.

  • Operational Retention Needs. We need to store information in certain cases for operational needs. We also store information where necessary for troubleshooting and debugging issues with the Services. We keep the information that we store for this purpose for up to 90 days, provided longer storage is not necessary for investigating and resolving a specific issue, or for legal reasons.
  • Messaging. We retain the information that we process to convey your messages or calls (which includes information like your phone number, the time and date you make a call or send a message, or the duration of your calls) in accordance with the specific rules and requirements under the EU Directive 2002/58/EC, where applicable, as long as it is needed for transmitting the communication, operating our Services, ensuring the safety and security of our Services, or to comply with legal obligations under applicable law. When we do not need the information for any of these purposes anymore, we delete or anonymize it.

7. Deleting Your Information

7.1When you delete your KeepUpp account or when it is deleted as a result of inactivity or for any other reason, we delete the information we have about you, apart from the information listed below which we retain in limited circumstances. As a rule, when your KeepUpp account is deleted for any reason whatsoever, all information included in your KeepUpp account is definitively deleted and is not recoverable even when our Service Providers keep limited technical backup of our data's.

7.2Deleted Information. Your Account Information are deleted from our servers. You will be removed from all KeepUpp groups. Note that for technical reasons it takes up to 90 days from the beginning of the deletion process to delete or de-identify your KeepUpp information. Copies of your information may also remain after the 90 days for a limited time in the backup storage that we use to recover lost information in the event of a disaster, software error, or other information loss event.

7.3Information We Retain After Your Account is Deleted. If we are analysing or investigating a security incident, in order to maintain the security of our Services, we need to retain Log and Troubleshooting Information associated with the incident that we are reviewing past the normal 90 day deletion period. Copies of certain log records remain in our database but are disassociated from personal identifiers which are used for example to measure performance, reliability and efficiency and to operate and improve our Services. Your account initially was linked to these records by a randomly generated identifier. To disassociate this information when your account is deleted, we delete the link between this identifier and your account as part of the account deletion process.

7.4Copies of your information may also be retained for legal reasons after you delete your account in the circumstances described. The information that may be retained and length of time we need to retain it will depend on the specific legal reason we need to retain it for.

8. Managing Your Information

8.1If you would like to manage, change, limit, or delete your information, you can do that through the following tools:

  • Settings. You can manage your contacts groups or use our "Unshare" feature to manage who you communicate with on our Services.
  • Changing Your Mobile Phone Number, Email, Profile Name and Picture, and "About" Information. If you change your mobile phone number you must update it using our in-app change number feature and transfer your account to your new mobile phone number. You can also change your email address, profile name, profile picture, and "about" information at any time.
  • Deleting Your KeepUpp Account. You can delete your KeepUpp account at any time using our in-app "Delete Account" feature in your in-app settings. Once you initiate the deletion process for your account, that account can no longer be used (i.e. you cannot log in or re-register or access any content as it will be deleted).

8.2Be mindful that if you only delete KeepUpp from your device without selecting the in-app delete my account option in your in-app settings, the information we collect will be stored on our servers for a longer period. KeepUpp accounts are generally deleted from our servers after 120 days of inactivity Users are not alerted when this occurs.

Please remember that when your account is deleted, it does not affect your information related to the groups you created (such as group names), or the information other users have relating to you.

9. Working With Authorities, Advisors And Industry Partners

9.1We access and share your information described in the information we collect section, including sharing with regulators, law enforcement, other government agencies, industry partners/peers such as other online platforms and technology companies, our advisors such as external lawyers who act for us, and others in accordance with this Privacy Policy if we have a good-faith belief that it is necessary to:

  • respond pursuant to applicable law or regulations, court orders, legal process, or government requests. For example, sharing with regulators, law enforcement, or other government agencies in response to legal requests or sharing with civil litigants pursuant to court orders;
  • detect, investigate, prevent, or address fraud and other illegal activity or security and technical issues. For example, we access and share information with law enforcement, other government agencies, or industry partners such as other online platforms and technology companies to identify and prevent bad actors using our Services for illegal purposes; or
  • protect the rights, property and safety of our users, ourselves or others, including to prevent death or imminent bodily harm. For example, sharing with law enforcement, in emergency situations where we learn that a person's life is at risk.

9.2The processing we carry out will depend on the circumstances.

10. Transferring Information Outside The EEA As Part Of Our Global Operations Third-Party Content

10.1We share information described in the Information We Collect section of this Privacy Policy globally with third parties in accordance with this Privacy Policy and our Terms. This includes places where the data centers we rely on are located, and where external Third-Party Service Providers are located (which includes the United States). These transfers are necessary and essential to enable us to provide the Services set forth in our Terms and globally to operate and provide our Services which allow you to communicate with users and businesses on KeepUpp around the world.

10.2When information controlled by KeepUpp is transferred or transmitted to, or stored and processed in, the United States or other third countries outside of the European Economic Area, we rely on the following transfer mechanisms:

  • Adequacy Decisions: We rely on decisions from the European Commission where they recognize that certain countries and territories outside of the European Economic Area ensure an adequate level of protection for personal information. These decisions are referred to as "adequacy decisions".
  • Standard Contractual Clauses: We utilize standard contractual clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK, where appropriate).

10.3While transfers to countries that don't have an adequacy decision typically take place on the basis of the standard contractual clauses, in certain circumstances, transfers can also take place on the basis of exemptions provided for under data protection law. For example, sharing with law enforcement, in emergency situations where we learn that a person's life is at risk.

11. Updates To Our Privacy Policy

11.1We may amend or update our Privacy Policy. We will provide you notice of amendments to this Privacy Policy, as appropriate, and update the "Last Modified" date at the top of this Privacy Policy. Please review our Privacy Policy from time to time.

12. Contact Us

12.1The Data Protection Officer for KeepUpp can be contacted here.

12.2If you have questions about our Privacy Policy, please contact us or write us here:

KeepUpp SRL
Privacy Policy
Drève Richelle 161 M/57
1410 Waterloo
Belgium

13. Data Protection Authority

13.1If necessary, you have the right to lodge a complaint with the national data protection authority concerning the collection and processing of your personal data by us.

13.2For Belgium, you should contact the Data Protection Authority (DPA): https://www.autoriteprotectiondonnees.be.

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