Last updated: July 2025
This Privacy Policy for Clean UpUp explains which personal data we collect, store, use, and share ("process") when you engage with our services ("Services") in relation to Clean UpUp application and/or its website ("Application"). This includes instances when you:
- download, install, registering with, access or use the Application, and its services, or
- interact with us in other related ways, such as through sales, support, or marketing activities.
This Privacy Policy further describes how and why we collect your personal data; how we intend to use, store, protect and share your personal data, and what are your rights and how to exercise them.
Summary of Key Points
This summary outlines the key highlights of our Privacy Notice. For more detailed information on any specific topic, please refer to the sections below.
What personal data do we process? When you use our Services, we may process your personal information based on your interactions with us, the choices you make, and the products or features that you access. The personal data of users processed by the Company, in particular, are as follows:
- your name and surname, e-mail address and phone number which we may receive if you contact the Company,
- your Internet Protocol Address (IP address),
- materials, files, documents, images, photos, visual records, videos, graphics, media, contact list, choices, any content, record and other input and data which you have uploaded or transmitted to the Application,
- your order information if you make a purchase,
- (if you give us permission) identifier for advertisers designated in your mobile device used in accessing our services (The Identifier for Advertisers-IDFA), identifier for vendors/developers designated your mobile device (The Identifier for Vendors-IDVF), and Google Advertising ID (GAID), identifier for Firebase analytics.
Do we process sensitive personal data? No, we do not process any sensitive personal data. Please do not share with us any content that might have any sensitive personal data.
How do we process your information? We mainly process your personal data to deliver, enhance, and manage our Services, facilitate communication with you, safeguard security, prevent fraud, and comply with legal obligations. Additionally, your data may be processed for other purposes with your explicit consent. All processing activities are conducted only in accordance with valid legal bases.
When do we share personal information? We only share your personal data with third parties only when necessary to deliver our Services, comply with legal obligations, protect our rights, or prevent fraud and security threats. This may include service providers, business partners, and legal authorities. All data sharing is carried out in compliance with applicable data protection laws and is subject to stringent safeguards to ensure the security of your personal data.
How do we keep your personal data secure? We implement administrative and technical measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction, ensuring its security.
What are your rights? Depending on your region, you may have specific rights concerning your personal data. These rights may include the right to access, correct, delete, restrict processing, object to processing, and data portability. Additionally, you may have the right to withdraw your consent.
How can you exercise your rights? You can simply exercise your rights by reaching out to us directly. We will diligently review and address any request in compliance with applicable data protection laws.
1. The Data Controller and the Objective
Your personal data, which you provided/will provide to the Company, may be processed by our Company as "Data Controller".
The Company aims to process the personal data of users in accordance with general principles of privacy and the provisions of the applicable data protection legislation to the relevant person, and other applicable law and regulations.
We are committed to complying with this Privacy Policy in accordance with all applicable laws in each region in which we operate. To ensure compliance with regional legal requirements, we provide additional privacy notices for specific jurisdictions.
In accordance with this Privacy Policy, personal data are processed by the Company as a data controller in line with the basic principles named here: (i) being in accordance with law and good faith, (ii) being accurate and, where necessary, up-to-date, (iii) being processed for specific, explicit and legitimate purposes, (iv) being limited for the purpose for which they are processed and data minimization; and (v) being stored for the period stipulated in the relevant legislation or required for the purpose for which they are processed.
2. Collection of Personal Data and Method
The Company may process your following data for the purposes specified in this Privacy Policy.
Identity and Contact Information: When you contact us, such as via e-mail or our phone number, we may process your name, surname, phone number and e-mail address, (if relevant) other contact information and the content of your communication.
Technical Information: When you visit, use or engage our Services, we may collect the following information from such use of our Services:
- Usage Data: We may collect data on how you interact with our Services. This includes information about your access to and use of our Application, such as duration of the time spent on the Application, information on time and date of access, date/time stamps of your visit, visit data, screen recordings, the features you access, contents you view, searches, and actions you take within the Application, device event information (for example error reports), in-app/web purchase history.
- Log Data: We may collect your log data generated while you are using our Services/Applications. This log data includes internet traffic data, network movements, Internet Protocol ("IP") address, device name, device information, operating system version, visit data, browser type, version and settings, language preference, time zone, information about your use of Services, the configuration of the Application when utilizing our Service/Application, the time/date of your use of the Service/Application, and other statistics.
- Device Information: We may collect data about the device you use to interact with our Services, including the device name, device ID, its model, its manufacturer, region information, device's operating system, device identifiers, hardware model.
- Location Information: Please note that we may be able to determine the general area of your device's location when it interacts with our Services, based on the information associated with your IP address and the region information of the device.
- Identifiers: unique user ID; and device token ID (particularly, if you allow us to send notifications through your device).
User Content: We process the data that you provide when interacting with our Services, such as when you provide an Input to our Services.
This data includes materials, files, documents, images, photos, videos, visual and audio records, voice recording, graphics, media, choices, contact list and any content, input, record or data that you provide, upload, transmit, create, store, use, edit or share with or through the Application.
We may ask for your permission to access your device's photo file or gallery app or your preferred cloud services in order to provide our services, when you are using the Application, such as to generate output for photos you share (e.g., determining similar photos in your gallery). You can choose not to allow us to access your contact application (thereby the full contact list) photo file or gallery app or cloud services by either rejecting our access or later disabling such access in your mobile device settings. However, you may not be able to use essential features of our services if you choose to opt out.
Please note that we do not store any of your contact list, photos and videos (or images, materials, files, documents, visual records, graphics, media) on our servers; activities to process these will be carried out on your device or your own cloud services only.
Customer Transaction: We may collect order information directly from you, our marketing vendors or our payment processors.
This information includes order date, payment date, subscription type, billing period, billing document, payment amount, due amount, payment status and any associated transaction identifiers (e.g., billing id, your e-mail address). This information is used to process your orders, manage subscriptions, and ensure the proper handling of payments and subscriptions.
Please note that we do not collect your payment method details, such as your credit card number, as we do not directly process your payment.
Marketing Data: When you give us permission, we may collect your Usage Data; and an identifier for advertisers designated in your mobile device used in accessing our services (the Identifier for Advertisers-IDFA), an identifier for vendors/developers designated to your mobile device (the Identifier for Vendors-IDFV), Google advertising ID (GAID); identifier for Firebase analytics.
3. Purposes of Processing Personal Data and Legal Bases
Your personal data will be processed via automatic or non-automatic means for the purposes stated below, in accordance with the applicable legislation where it is expressly permitted by the laws, the establishment of a contract or direct relation to the execution or performance of the contract and for the legitimate interests of the Company provided that your fundamental rights and freedoms are protected, and in order to fulfil our legal obligations.
Your personal data is processed for the following purposes:
- execution of goods/services sales processes,
- execution of agreement processes,
- execution of company/product/service commitment operations,
- operation of our product,
- creating user accounts for the service recipients/application users,
- conducting storage and archive activities,
- execution of communication activities,
- conducting after-sales support services for goods/services,
- execution of activities in compliance with legislation,
- execution/auditing of business activities,
- execution of information security processes,
- conducting audit/ethical activities,
- conducting activities to ensure business continuity,
- compliance with legislation and protection of persons' rights, privacy and safety,
- providing information to authorized persons, institutions and organizations,
- prevention of crimes and other illegal acts,
- conducting activities for customer satisfaction,
- customizing our Services, understanding our users and their preferences to enhance user experience and enjoyment using our Services and improve our users' experience.
Additionally, if you give us explicit consent, your Marketing Data may be processed for conducting marketing analysis studies and executing advertising (including personalised advertisements)/campaign/promotion processes.
If you give us explicit consent, your identity and contact information may be processed for communicating with you to send information about marketing and informing about new products, services and applications and delivering you information regarding advertisements and promotions.
4. Third Party Websites/Applications, Cookies and Notifications
The Application may contain links to other websites or apps that are unknown to the Company and whose content is not controlled. These linked websites or apps may contain terms and conditions other than the Company texts. The Company cannot be held responsible for the use or disclosure of information that these websites or apps may process.
We collect information by fair and lawful means, with your knowledge and consent. We also let you know why we're collecting it and how it will be used. You are free to refuse our request for this information, with the understanding that we may be unable to provide you with some of your desired services without it.
Cookies: Cookies are little text files that are stored on the browser or hard drive of your computer or mobile device when you visit a webpage. We may use cookies when it is necessary for operating our Services, to enhance our Service performance and functionality, and to deliver content, including ads relevant to your interests. You can delete cookies which are already present on your computer and prevent the recording/location of cookies on your internet explorer.
Push Notifications: The Company may occasionally send you push notifications via its mobile applications or website regarding Application upgrades or notifications about our Services. You can always edit such communication and notifications through the settings on your device and stop receiving such communications and notifications.
5. Data Storage
Your data will be stored for the duration specified in the applicable legislation or until the purpose of processing ceases to exist.
The Company may continue to store your personal data, even after the expiry of the purpose of its use provided that it is required by other laws or separately a consent is granted by you in this regard.
In cases that you allow the Company to store your personal data for additional time by giving your consent, such data shall be immediately deleted, destructed or anonymized upon the expiry of such additional time or once the consent is withdrawn.
6. Technical and Administrative Measures
The Company stores the personal data it processes in accordance with relevant legislation for periods stipulated in relevant legislation or required for the purpose of processing. The Company undertakes to take all necessary technical and administrative measures and to take the due care to ensure the confidentiality, integrity and security of personal data.
In the event that the personal data is damaged as a result of attacks on the Application or on the Company system, despite the Company taking the necessary information security measures, or the personal data is obtained by unauthorized third parties, the Company notifies this situation to Users immediately and, if necessary, to relevant data protection authority and takes necessary measures.
7. Age Limitation
We do not permit the use of our application by children under the age of 16.
We do not knowingly collect or process personal data from anyone under the age of 16. If you learn that someone under the age of 16 has provided us with personal information, please contact us via email.
Users under 18 must have permission from their parents or legal guardians to use our Services.
8. Transferring Personal Data to Third Parties
Your following personal data may be transferred abroad to our service providers for the following purposes:
- Your Technical Information, Identity and Contact Information, Customer Information, and User Content for the purpose of conducting storage and archive activities (including cloud services and database services) that are required to maintain our operations.
- Your Technical Information for the purposes of correction of technical specifications, technical errors and defects that are required to maintain our operations.
The Company may also transfer your Marketing Data to service providers (incl. Google, Apple, Facebook SDK, Adjust and Firebase Analytics, which are embedded into our service) for the purpose of conducting marketing analysis studies and execution of advertising (including personalised advertising)/campaign/promotion processes.
We may have to share personal information with authorized public institutions and organizations, and judiciary bodies for the purpose of complying with our legal obligations and requirements on the legal basis that it is necessary in order to fulfill our legal obligation.
9. Your Rights as the Data Subject
You may request from the Company the exercise of the following rights regarding your personal data:
- Learn whether or not your personal data have been processed.
- Demand for information as to if your personal data have been processed.
- Learn the purpose of the processing of personal data and whether data are used in accordance with their purpose.
- Know the third parties in the country or abroad to whom your personal data have been transferred.
- In case the personal data is processed incompletely or inaccurately, request notification of the transactions made under this scope to third parties to whom personal data have been transferred.
- Request deletion, destruction or anonymization of personal data if the reasons for the processing have disappeared and request notification of the transactions made under this scope to third parties to whom personal data have been transferred.
- Object to the occurrence of any result that is to your detriment by means of the analysis of personal data exclusively through automated systems.
- Request compensation for the damages in case you incur damages due to unlawful processing of your personal data.
- Right to withdraw explicit consent from processing data based on explicit consent at any time.
In the request where you outline your rights as a data subject and specify the rights you wish to exercise, your request must be clear and understandable. Our Company will enable you to file such requests via email. In accordance with applicable law, our Company will finalize your requests, free of charge, within 30 (thirty) days at the latest, depending on the nature of the request.
10. Contact Information
If you have any questions or comments regarding this Privacy Policy that is not covered here or if you have any request or would like to exercise your rights, you may contact us via the following email address:
- Email: [email protected]
- Response time: We will respond to your requests within 30 days
11. Compliance
This privacy policy is designed to comply with:
- General Data Protection Regulation (GDPR)
- California Consumer Privacy Act (CCPA)
- App Store and Google Play privacy requirements
- Other applicable privacy laws and regulations
Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will state the date at the top of this Policy.
If we make material changes (changes that significantly affect your rights or the way we handle your data), we will provide you with prominent notice before the changes take effect. This notice may be provided through the Application interface (e.g., a pop-up notification), by sending an email to the address associated with your account (if applicable), or through other reasonable means appropriate to the circumstances.
We encourage you to review this Privacy Policy periodically. Your continued use of the Services after the effective date of any revised Privacy Policy constitutes your acknowledgment of the updated terms, unless applicable law requires a different form of acceptance (such as explicit consent for certain types of changes).