Privacy Policy

1Who controls your data

Upfling is operated by the operator of upfling.host, a sole trader established in the United Kingdom.

We have not appointed a Data Protection Officer. Upfling is a small team operation that does not carry out large-scale monitoring or process special category data as a core activity, so the statutory requirement to appoint one does not apply. Privacy questions go to privacy@upfling.host and are answered by the operator personally.

2What we collect

We have kept this list concrete rather than writing the usual catch-all. It is an inventory of what is actually stored.

Account information

Your name, email address and authentication details are held by Clerk, our authentication provider. Our own database stores only the account identifier Clerk gives us, not your email, not your name, not your password. When we need your email address to send you something, we ask Clerk for it at that moment.

Sites and files

• The files you upload, and their names and paths.
• The title, description and subdomain you choose for each site.
• Any custom domain you connect.
• Storage used, and when each site was created and updated.

File paths and site titles are whatever you typed. If you name a file after a person, that name is personal data and we hold it.

IP addresses

We record the IP address of whoever creates a site, and we keep it for as long as the site exists.

Your IP address is also sent to Cloudflare when the anti-bot check runs on our upload and report forms, and to Sentry when the dashboard reports an error (see below).

Content scanning records

Each scan produces a record of what was checked and what was found. It includes file paths and short extracts from your files where something matched (for example, a URL a scanner rule flagged). It does not include a copy of your whole site.

Billing

Payments are handled entirely by Stripe. We never see or store your card details. Our database holds only the link between your Stripe customer record and your account, so we know which subscription belongs to whom. Your name, email and billing address are held by Stripe.

3What we do not collect

We use product analytics on the Upfling dashboard. Where the law requires consent before information is stored on your device it is obtained first, and until then analytics operates without cookies; elsewhere cookies are set by default. You may run analytics with cookies, without them, or turn it off entirely. The Cookie Notice sets out what each state collects and carries the controls.

This does not extend to:

• The sites you host with us. We add no analytics or tracking code to them. The only addition to a free-plan page is a visible Upfling badge.
• Visitors to your hosted sites. Our hosting servers do not log their IP addresses or browsers, regardless of your own analytics setting.
• Advertising. We do not carry out behavioural advertising and do not sell or share personal data for anyone else's marketing.
• Per-site traffic statistics. The analytics feature advertised on paid plans has not yet been released; this section and the Cookie Notice will be updated when it is.

We do not ask for or store special category data: health, biometrics, political opinions and so on. Please do not put such data in a site title or a support email.

4Why we are allowed to process it

Under UK GDPR Article 6, we rely on:

• Performance of a contract: holding your account, storing and serving your files, taking payment. Without this data there is no service.
• Legitimate interests: recording creator IP addresses, rate limiting, content scanning, moderation records and abuse reports. Our interest is in keeping Upfling from being used for phishing and malware, which also protects every other user and the people who would otherwise be victims. We have weighed this against your privacy and consider it proportionate: the data is narrow, it is not used for anything else, and hosting without it is not realistically operable.
• Legitimate interests: analytics carried out without cookies, where nothing is stored on or read from your device. Our interest is in understanding how the service performs and where it fails. The measurements are aggregate, are not linked to your account, and are not used to make decisions about you. You can object at any time using the "off" control in the Cookie Notice. Analytics that does use cookies rests on your consent instead, not on this basis.
• Legal obligation: keeping financial records, and responding to lawful requests and valid takedown notices.

You can object to processing based on legitimate interests. See your rights below.

5How long we keep things

These periods are enforced by scheduled jobs, not by a promise to remember:

• Deleted sites sit in your trash for 14 days, then are permanently deleted. The files are removed from storage and the database records are destroyed. This is a real deletion, not a flag.
• Sites created but never claimed are deleted after 24 hours.
• After you cancel a paid plan, you have 30 days before sites over the free-plan limit are suspended, with a reminder 7 days beforehand. They are suspended, not deleted.
• Account data is held by Clerk for as long as your account exists and is deleted when you delete the account.
• Billing records are kept for six years after the end of the relevant accounting period, as UK tax law requires.

Moderation and security records are kept indefinitely. That covers enforcement actions, content scan results, abuse reports and the IP block list. A block list that forgets is not a block list, and a repeat-infringer policy needs history to work against. Entries stay on the block list even after a block is lifted, marked as lifted. We rely on legitimate interests for this, and we intend to introduce a defined limit as the service matures; until we do, this page says "indefinitely" because that is the truth.

6Who else processes your data

We use the following providers to run Upfling. They process data on our instructions under a data processing agreement. This is the complete list. Google and Meta receive conversion tracking data as described in the Cookie Notice. The analytics provider receives nothing if you have turned analytics off.

We may also disclose data where we are legally required to, or where it is necessary to establish or defend a legal claim (for example, passing details of an infringing site to a rights holder who has sent a valid notice, or reporting illegal material to the authorities).

We do not sell personal data, and we would not transfer it to anyone else without telling you first, except as part of a sale of the business, in which case the buyer would be bound by this policy until they gave you notice of any change.

7Error monitoring

We use Sentry to find out when something in the software breaks. It deserves its own section because of what it collects.

On the dashboard at upfling.host (that is, the pages you sign in to and use), error reports include your IP address and the headers of the request that failed, alongside the error itself and your account identifier. We have this switched on deliberately: without the request context, a large share of reports are not diagnosable, and we are a small team operation that cannot reproduce every fault by hand. The legal basis is legitimate interests in keeping the service working.

If you would rather your IP address were not sent to Sentry from the dashboard, tell us at privacy@upfling.host and we will treat it as an objection under Article 21.

8Live chat

We use tawk.to to provide a live chat widget at upfling.host. It does not load on sites hosted with us. The widget loads on every page, for every visitor, regardless of consent state or region. It is not gated on consent because it exists to offer help, and the operator has decided it should always be available.

tawk.to sets cookies on your device (__tawkuuid, TawkConnectionTime, and session identifiers) and processes your IP address, browser and device information, and anything you type into the chat. These cookies are set unconditionally, including for visitors in the EEA and UK who have not given consent. The legal basis is legitimate interests in providing support to every visitor.

tawk.to is listed in the sub-processor table below. Processing takes place in the United States under a data processing addendum.

9Sending data outside the UK

All of the providers above are headquartered in the United States, and Cloudflare processes data across a global network by design. Personal data therefore leaves the UK.

Those transfers are made under the UK International Data Transfer Agreement, or the UK Addendum to the European Commission's standard contractual clauses, as set out in each provider's data processing agreement linked in the table above. You can ask us for details of the safeguards that apply.

10Your rights

Under UK data protection law you have the right to:

• Access: get a copy of the personal data we hold about you.
• Rectification: have inaccurate data corrected.
• Erasure: have data deleted, where we have no overriding reason to keep it.
• Portability: receive data you gave us in a machine-readable form.
• Restriction: have us pause processing while a dispute about accuracy or legitimate interests is resolved.
• Objection: object to processing we base on legitimate interests, including the Sentry processing described above.

Email privacy@upfling.host from the address on your account, or tell us how else to verify it is you. We respond within 30 days. There is no charge unless a request is manifestly unfounded or excessive.

Requests are handled by hand. We do not yet have a self-service export button. That does not change the deadline.

Some data survives an erasure request. We keep records of enforcement action, abuse reports and blocked IP addresses on the basis of legitimate interests, because deleting them on request would let anyone erase the evidence of their own abuse. We also keep billing records for as long as tax law requires. We will tell you if we rely on either of these.

If you are unhappy with how we have handled your data, you can complain to the Information Commissioner's Office at ico.org.uk. We would appreciate the chance to put it right first.

11Deleting your data yourself

You do not need to ask us for most of this:

• A single site: delete it from your dashboard. It goes to the trash and is permanently destroyed after 14 days.
• Your whole account: delete by contacting us at privacy@upfling.host. This removes your identity data from Clerk.
• Billing details: managed through the Stripe customer portal, linked from your billing page.

Deleting your account does not automatically delete sites you still have published. Delete the sites first if that is what you want.

12Children

Upfling is not intended for children under 16 and we do not knowingly collect their personal data. If you believe a child has given us personal data, email privacy@upfling.host and we will delete it.

13Changes to this policy

When this policy changes, the "last updated" date at the top changes with it. If a change materially affects how we use your personal data (a new provider receiving it, a new purpose, a longer retention period), we will email account holders before it takes effect.