Privacy Policy

up103 respects your privacy and is committed to handling personal information responsibly, transparently, and securely.

This Privacy Policy explains how up103 (“up103”, “we”, “us” or “our”) collects, uses, stores and shares information when you:

• visit up103.com;
• use the up103 application;
• create or manage an account;
• upload, enter or otherwise provide study material;
• use learning, review or content-generation features;
• contact us or provide feedback; or
• otherwise interact with our services.

We refer to these websites, applications and related functionality collectively as the “Service.”

By using the Service, you acknowledge that your personal information will be handled as described in this Privacy Policy.

1. Who is responsible for your data?

up103 is the data controller for personal information processed in connection with the Service. This means that up103 determines why and how that information is processed.

For privacy-related questions, requests or concerns, you can contact us at:

Email: privacy, at this domain

2. Information we collect

The information we collect depends on how you use up103.

We aim to collect only information that is reasonably necessary to operate, improve and protect the Service.

2.1 Account information

When you create or use an up103 account, we may collect information such as:

• your email address;
• account identifiers;
• authentication information;
• account status;
• account creation and login timestamps; and
• preferences associated with your account.

up103 may use passwordless or link-based authentication. Where authentication is handled using a secure authentication service, up103 does not need to receive or store a traditional password.

2.2 Study content

up103 is designed around learning material you choose to provide.

Depending on the features you use, this may include:

• photographs of handwritten notes;
• typed study notes;
• vocabulary;
• grammar points;
• example sentences;
• study-session information;
• learning materials;
• URLs or links you choose to submit;
• text extracted from material you provide; and
• other information you deliberately add to your learning profile.

We refer to this collectively as “Study Content.”

Your Study Content is used to provide personalised learning functionality.

You should avoid including personal information about yourself or other people in Study Content unless it is genuinely necessary for your use of the Service.

2.3 Learning profile information

up103 may analyse your Study Content and activity to build a representation of what you have studied.

This may include information such as:

• grammar points you have studied;
• vocabulary you have encountered;
• estimated familiarity with learning material;
• previous study sessions;
• learning history;
• generated learning items;
• review history;
• content difficulty;
• study progress; and
• other information used to personalise the Service.

This information may change over time as you use up103.

The purpose of this profile is to adapt learning material to you rather than treating all learners as having the same knowledge.

2.4 Generated learning content

When you use up103, we may create and store content associated with your account, such as:

• Korean texts;
• dialogues;
• monologues;
• translations;
• explanations;
• audio;
• study items;
• review materials;
• decks or exports; and
• metadata relating to generated material.

Generated content may be based partly on your Study Content and learning profile.

2.5 Usage and technical information

When you access up103, certain technical information may be collected automatically.

This can include:

• IP address;
• browser type;
• operating system;
• device type;
• approximate location derived from an IP address;
• pages or screens viewed;
• referring pages;
• date and time of access;
• feature interactions;
• session information;
• diagnostic information;
• application errors;
• performance data; and
• similar technical information.

We use this information to operate, secure, understand and improve the Service.

2.6 Communications and feedback

If you contact us, send feedback, report a problem or communicate with up103, we may retain:

• your email address;
• the contents of your message;
• attachments you provide;
• support history; and
• information necessary to respond to your request.

Feedback may also be used to improve up103.

Where possible, product feedback used for analysis may be aggregated or separated from directly identifying information.

2.7 Payment information

If up103 offers paid plans or other purchases, payment processing may be handled by a specialist payment provider.

up103 may receive information such as:

• whether a payment succeeded;
• subscription status;
• plan;
• transaction identifier;
• billing country;
• renewal or cancellation status; and
• limited billing information.

Where payments are processed by a payment provider, up103 does not need to receive or store your full payment-card details.

3. How we use your information

We use personal information for purposes including the following.

Providing the Service

This includes:

• creating and maintaining your account;
• authenticating you;
• saving your learning history;
• processing Study Content;
• building and updating your learning profile;
• generating personalised learning materials;
• generating audio;
• providing reviews;
• creating exports or learning decks;
• synchronising information associated with your account; and
• providing other features you request.

Personalising your learning experience

We may use your study history, learning profile and previous interactions to determine what content is appropriate for you.

For example, up103 may use grammar or vocabulary you have already studied when generating new comprehensible-input material.

Maintaining and improving up103

We may use information to:

• understand how features are used;
• identify confusing or poorly performing features;
• measure product performance;
• debug errors;
• improve reliability;
• develop new features;
• evaluate generated content; and
• improve the overall learning experience.

Where reasonably possible, we use aggregated or de-identified information for this type of analysis.

Security and abuse prevention

We may process information to:

• protect user accounts;
• investigate suspicious activity;
• detect abuse;
• prevent fraud;
• maintain system security;
• enforce usage restrictions; and
• protect up103, its users and its infrastructure.

Communicating with you

We may use your contact information to send:

• authentication messages;
• important account notifications;
• security notices;
• changes to the Service;
• responses to support requests; and
• other operational communications.

These are service communications rather than marketing messages.

Marketing

If we introduce optional newsletters, product announcements or other marketing communications, we will send them only where permitted by applicable law.

Where consent is required, you can withdraw that consent at any time.

4. Our legal bases for processing

Where the UK GDPR, EU GDPR or similar data-protection legislation applies, we need a lawful basis for processing personal information.

The basis depends on what we are doing with the information.

Our legitimate interests include operating a secure, reliable and useful learning service, understanding how the Service performs, preventing misuse and improving up103.

Where we rely on legitimate interests, we consider whether those interests are outweighed by your rights and interests.

Where we rely on consent, you may withdraw that consent at any time.

5. Automated and AI-assisted processing

up103 uses automated systems as part of providing the Service.

For example, automated processing may be used to:

• interpret Study Content;
• extract relevant language-learning information;
• identify grammar or vocabulary;
• maintain your learning profile;
• determine suitable learning material;
• generate text;
• generate audio;
• create explanations or translations; and
• personalise study content.

To provide these features, relevant information may be securely transmitted to specialised processing services acting on up103's behalf.

We limit the information provided to these services to what is reasonably necessary for the relevant function.

up103 does not use automated processing to make decisions about you that produce legal effects or similarly significant effects, such as decisions concerning employment, credit, insurance or access to essential services.

The automated processing used by up103 is intended to personalise and operate a language-learning product.

6. How we share information

up103 does not sell your personal information.

We also do not share Study Content with advertisers for behavioural advertising.

We may disclose information to organisations that help us operate the Service.

These may include providers of:

• cloud hosting and database infrastructure;
• authentication systems;
• email delivery;
• analytics;
• application monitoring;
• security and fraud prevention;
• AI-assisted content processing;
• language processing;
• audio generation;
• payment processing;
• customer support infrastructure; and
• other technical services necessary to operate up103.

These service providers may process information on our behalf only for relevant operational purposes and subject to appropriate contractual or legal safeguards where required.

We may also disclose information in the circumstances described below.

Legal requirements

We may disclose information where we reasonably believe disclosure is necessary to:

• comply with applicable law;
• respond to a valid legal request;
• comply with a court order;
• protect the rights or safety of up103 or another person;
• investigate fraud or abuse; or
• establish, exercise or defend legal claims.

Business transactions

If up103 is involved in a merger, acquisition, financing, restructuring, sale of assets or similar transaction, information may be transferred as part of that transaction.

Any receiving organisation would remain subject to applicable data-protection requirements.

7. International data transfers

up103 may use infrastructure and service providers located in different countries.

Account and learning information may be stored using infrastructure located within the European Economic Area, but some processing may take place outside the United Kingdom or European Economic Area where necessary to operate particular features.

Different countries may have different data-protection laws.

Where applicable law requires safeguards for an international transfer of personal information, we use an appropriate legal mechanism. Depending on the circumstances, this may include:

• an adequacy decision or adequacy regulation;
• Standard Contractual Clauses;
• the UK International Data Transfer Agreement;
• the UK Addendum to Standard Contractual Clauses; or
• another legally recognised transfer mechanism.

8. How long we keep information

We do not keep personal information indefinitely simply because we can.

Retention depends on the type of information and why we need it.

Account information

We generally retain account information while your account remains active and for as long afterwards as reasonably necessary to complete deletion, resolve disputes, meet legal obligations or protect the Service.

Study Content and learning profiles

Study Content, learning profiles and generated learning materials may be retained while your account remains active so that up103 can provide a continuous personalised learning experience.

If your account is deleted, this information will normally be deleted or de-identified, subject to limited technical, legal and backup-retention requirements.

Technical information

Server logs, security data and diagnostic information are generally retained only for as long as they remain reasonably necessary for security, troubleshooting, performance analysis or legal purposes.

Analytics information

Analytics information may be retained in aggregated or de-identified form for longer periods where it can no longer reasonably be associated with an identifiable user.

Backups

Deleted information may remain temporarily in encrypted or protected backups until those backups are overwritten according to our normal backup cycle.

We do not restore deleted information from backups except where required for disaster recovery, security or similar operational purposes.

9. Cookies and similar technologies

up103 may use cookies and similar technologies on its website and application.

These can include:

Essential technologies

These are necessary to provide functionality such as:

• authentication;
• security;
• session management;
• fraud prevention; and
• maintaining user preferences.

Essential technologies may be used without consent where permitted by law because the Service cannot operate properly without them.

Analytics technologies

We may use analytics technologies to understand information such as:

• how many people use up103;
• which pages or features are used;
• how users navigate the Service;
• whether pages are functioning correctly; and
• general product-performance trends.

We use this information to understand and improve up103.

Depending on the technology, configuration and law that applies to you, we may ask for consent before using analytics technologies or provide a simple way to opt out.

Advertising

up103 does not currently use your Study Content for advertising or create advertising profiles from your learning data.

If our use of advertising or tracking technology materially changes, we will update this Privacy Policy and obtain consent where required.

10. Your Study Content belongs to you

Providing Study Content to up103 does not transfer ownership of that content to us.

You give up103 the limited permission necessary to process the material in order to operate and improve the features you choose to use.

For example, we may need to:

• store a photograph of your notes;
• extract text from it;
• analyse the language within it;
• add relevant information to your learning profile; and
• use that profile to generate personalised study material.

We do not claim ownership of your original Study Content.

You remain responsible for ensuring that you have the right to upload or submit content to up103.

11. Sensitive information

up103 is a language-learning service and is not designed to collect sensitive personal information such as:

• health information;
• biometric identifiers;
• political opinions;
• religious beliefs;
• sexual orientation;
• information about a person's sex life;
• trade-union membership; or
• criminal-offence information.

Please avoid including unnecessary sensitive personal information in photographs, notes or other Study Content.

12. Data security

We use technical and organisational measures designed to protect personal information against:

• unauthorised access;
• accidental loss;
• destruction;
• alteration;
• improper disclosure; and
• misuse.

Measures may include, where appropriate:

• encrypted communications;
• access controls;
• authentication controls;
• restricted production access;
• infrastructure security;
• monitoring;
• backups;
• software-security practices; and
• separation of user accounts.

No online service can guarantee absolute security.

If you believe your account or information may have been compromised, contact us as soon as possible.

13. Your privacy rights

Depending on where you live, you may have legal rights concerning your personal information.

For users covered by UK or European data-protection law, these may include the following.

Right of access

You may ask whether we process personal information about you and request a copy of that information.

Right to correction

You may ask us to correct inaccurate or incomplete information.

Right to deletion

You may ask us to delete personal information in certain circumstances.

Deleting your up103 account will generally result in deletion of the information associated with that account, subject to limited legal, security and backup requirements.

Right to restriction

In certain circumstances, you may ask us to temporarily restrict how your information is processed.

Right to data portability

Where applicable, you may request certain information you provided to us in a structured, commonly used and machine-readable format.

Right to object

Where processing is based on legitimate interests, you may have the right to object to that processing.

You have an absolute right to object to processing of your personal information for direct marketing.

Rights relating to consent

Where processing is based on your consent, you may withdraw that consent at any time.

Withdrawal does not affect processing that was lawful before consent was withdrawn.

Rights concerning automated decisions

You may have rights concerning decisions made entirely through automated processing where those decisions have legal or similarly significant effects.

As explained above, up103 does not use its learning-personalisation systems to make this type of decision.

14. Exercising your rights

To exercise a privacy right, contact:

privacy, at this domain

Please describe what you would like us to do.

We may need to verify your identity before fulfilling a request in order to prevent somebody else from gaining access to or deleting your information.

We will respond within the period required by applicable law.

Some rights are subject to exceptions. For example, we may need to retain certain information where required by law or where necessary to establish, exercise or defend legal claims.

15. Deleting your account

You may request deletion of your up103 account and associated personal information.

You can do this through any account-deletion functionality provided within the Service or by contacting us.

Following an account-deletion request, we will delete or de-identify personal information that we no longer need, subject to:

• legal obligations;
• fraud and security requirements;
• dispute resolution;
• backup retention; and
• establishment or defence of legal claims.

Some aggregated or genuinely anonymised information may remain because it no longer identifies you.

16. Children

up103 is designed primarily for independent language learners and is not specifically directed at young children.

If you are below the age at which you may lawfully agree to the processing of your personal information or enter into applicable online-service terms in your country, you should use up103 only with the involvement of a parent or legal guardian where required.

If we become aware that personal information has been collected from a child in circumstances that do not comply with applicable law, we will take appropriate steps to delete it.

Parents or guardians who believe a child has provided personal information improperly may contact us.

17. Third-party content and services

up103 may allow you to:

• submit links to external material;
• interact with content hosted elsewhere;
• export learning materials;
• download files; or
• use generated content in another application.

Third-party websites, applications and services operate under their own privacy policies.

Once information has been deliberately exported from up103 and provided to another service at your direction, the other service's handling of that information is outside up103's control.

We recommend reviewing the privacy practices of services you choose to use.

18. Aggregated and anonymised information

We may create aggregated or anonymised information from Service activity.

For example, we may analyse:

• how often a feature is used;
• typical study-session patterns;
• overall content-generation performance;
• commonly studied grammar categories; or
• general application-performance metrics.

Where information has been genuinely anonymised so that an individual can no longer reasonably be identified, it is no longer personal information under data-protection law.

We may use such information for analytics, research, product development and improvement of up103.

19. Changes to this Privacy Policy

up103 will evolve over time, and the way we process information may change as we introduce new features.

We may update this Privacy Policy to reflect:

• changes to the Service;
• changes to how information is processed;
• new legal requirements;
• security developments; or
• changes to our business operations.

When we make changes, we will update the “Last updated” date at the top of this page.

If a change materially affects how we use personal information, we may provide additional notice through the Service or by email where appropriate.

20. Complaints

If you have a concern about how up103 handles your personal information, we encourage you to contact us first so that we can investigate it.

If UK data-protection law applies to you, you may also have the right to make a complaint to the UK Information Commissioner's Office (ICO).

If you are located in the European Economic Area, you may have the right to complain to the data-protection authority in the country where you live or work.

These rights are available to you regardless of whether you contact up103 first.

21. Contact

For questions about this Privacy Policy, your personal information or your privacy rights, contact:

up103
Email: privacy, at this domain