Privacy Policy

Effective date: 1 June 2025

1. Introduction

This Privacy Policy explains how NDEY Upper (“we”, “us”, “our”), operating from Högelmüllergasse 4, 1050 Wien, Austria, collects and uses personal data when you use our enhancement services and website (the “Service”).

2. Data we process

  • Account data: name, email address, authentication identifiers.
  • Payment data: processed by Stripe on our behalf; we receive limited billing information and payment status.
  • Content: images or videos you upload for enhancement. Unless you opt to keep results, uploads are deleted within 24 hours after processing completes.
  • Usage data: device information, IP address, logs, and basic analytics events to secure and improve the Service.
  • Cookies: essential cookies for authentication and security; optional analytics cookies (see Cookie Policy).

3. Legal bases (GDPR)

We rely on: contract performance, legitimate interests (e.g., fraud prevention, service improvement), consent (where required), and legal obligations.

4. How we use data

  • Provide, operate, and improve the Service
  • Process payments and manage token balances
  • Protect against abuse and secure our systems
  • Communicate with you about the Service and updates
  • Comply with legal and regulatory requirements

5. Sharing and disclosures

We do not sell personal data. We share data only with:

  • Service providers (e.g., hosting, authentication, analytics, customer support)
  • Stripe, as our payment processor
  • Authorities, when required by law or to protect rights and safety
  • Successors in a merger, acquisition, or asset transfer, subject to this Policy

6. International transfers

When transferring data outside the EEA, we use approved safeguards such as Standard Contractual Clauses.

7. Data retention

We retain account data while your account is active and as required by law. Uploads are deleted within 24 hours unless you choose to keep results.

8. Your rights

You may have rights to access, correct, delete, restrict, or port your personal data, and to object to certain processing. You can exercise these rights by contacting us at privacy@ndey-upper.com. We may need to verify your identity.

California residents may request information about categories of personal information disclosed for business purposes.

9. Cookies and analytics

See our Cookie Policy for details on the types of cookies we use and how to manage preferences.

10. Security

We use safeguards such as TLS encryption in transit, access controls, and regular updates. No method of transmission or storage is 100% secure.

11. Children

The Service is not directed to children under 13. If we learn a child has provided personal data, we will delete it promptly.

12. Changes

We may update this Policy. We will notify you of material changes via email or in‑app notice. Continued use after changes indicates acceptance.

13. Contact

For privacy questions or requests, contact privacy@ndey-upper.com. You may also contact our Data Protection Officer at dpo@ndey-upper.com.