Last updated: April 2025
This privacy policy aims to inform users of the Upster application (accessible at www.upster.ai) about the processing of personal data within the scope of its use.
Upster is published and operated by the company identified below. This policy applies to all users of the services offered through the Upster platform.
1. Data Controller
Publisher:
Company registration number (SIRET): 939 920 591 00012
EU VAT number: FR 12939920591
Address: 1 Avenue de la Gare, 40100 DAX, France
Contact email: contact@upster.ai
2. Purpose of Data Processing
Personal data is collected and processed for the following purposes:
- User authentication via Meta APIs (Facebook Login)
- Connecting to the user’s Instagram account to manage conversations with followers
- Accessing and processing conversations for AI-based automation
- Continuous improvement of Upster features
3. Legal Basis
Data processing is based on:
- The user’s explicit consent during authentication via Facebook Login
- The performance of a contract, i.e., the use of Upster services
- The legitimate interest of the publisher in maintaining and improving the application
4. Data Collected
The following data may be collected through Upster:
- Facebook / Instagram identifiers (via Facebook Login)
- Conversational data from the Messenger API
- Technical information related to application usage (logs, connection timestamps, etc.)
5. Data Retention
Collected data is retained for a maximum of 1 month from the date of collection, unless required otherwise by law or justified by a higher legitimate interest. After this period, the data is automatically deleted or anonymized.
6. Data Sharing and Subcontracting
Data may be shared with the following recipients:
- Internal teams of the publisher (support and maintenance)
- Meta Platforms Inc. services, via official APIs (Facebook Login, Messenger API)
No data transfers outside the European Union are carried out by the publisher.
All data is hosted securely in France, in data centers located in Paris, certified ISO 27001.
7. Cookies and Trackers
The Upster website may use trackers to:
- Monitor website performance
- Enhance the user experience
Users are informed via a cookie consent banner upon first visit. No non-essential cookies are set without the user’s explicit consent.
8. AI-Based Message Automation
Upster includes artificial intelligence features that automate the generation of personalized messages for Instagram followers.
These automated messages are designed to assist with commercial engagement, lead qualification, or call scheduling.
Automation is configured and supervised by the user, who retains full control over all messages distributed via the platform.
The generated messages carry no legal or binding effect on the recipients.
9. User Rights
In accordance with the GDPR, users have the following rights:
- Right of access
- Right to rectification
- Right to erasure (“right to be forgotten”)
- Right to restrict processing
- Right to object
- Right to data portability
To exercise any of these rights, please contact us at:
📧 contact@soarly.com
You also have the right to file a complaint with the French Data Protection Authority (CNIL) via www.cnil.fr.
10. Data Security
We implement strict technical and organizational measures to ensure the confidentiality, integrity, and availability of data, including:
- Secure hosting in France, in ISO 27001-certified data centers located in Paris
- Encryption of sensitive data
- Access control and activity logging
11. Policy Updates
This privacy policy may be updated at any time to reflect regulatory changes or new features introduced in Upster. Users will be notified of any significant changes.
12. Contact
If you have any questions regarding this privacy policy or your personal data:
contact@upster.ai