Privacy policy

1. Who we are

Upbrite is operated by Conclude Limited, a company registered in England and Wales. When this policy refers to "we", "us", or "our", it means Conclude Limited.

If you have any questions about this policy or how we handle your personal data, please contact us at privacy@upbrite.com.

2. What data we collect

We collect the following personal data:

• Email address — when you join our waitlist or create a subscriber account. • Mood check-in data — numerical mood ratings (1–5) you submit before and after each audio session. This data is linked to your account. • Listen history — records of which sessions you have accessed, used to support the mood tracking feature. • Payment information — processed securely by Stripe and Memberful on our behalf. We do not store your card details. • Technical data — IP address, browser type, and device information collected automatically when you use our service. This data is used for security and to diagnose technical issues.

3. How we use your data

We use your personal data for the following purposes:

• To provide and operate the Upbrite service, including delivering audio sessions and displaying your mood tracking history. • To send you service-related emails, including notifications about new content and account updates. • To send you marketing emails about Upbrite, where you have consented to receive them. You can unsubscribe at any time. • To process subscription payments securely through our payment partners. • To improve the service by understanding how it is used. • To comply with our legal obligations.

4. Legal basis for processing

We process your personal data on the following legal bases under UK GDPR:

• Contract — processing necessary to deliver the service you have subscribed to. • Legitimate interests — processing necessary for our legitimate business interests, including improving the service and maintaining security, where these interests are not overridden by your rights. • Consent — for marketing emails. You may withdraw consent at any time by clicking unsubscribe in any email or contacting us at privacy@upbrite.com. • Legal obligation — where we are required to process data to comply with applicable law.

5. Who we share your data with

We share your personal data with the following third parties, solely to operate the service:

• Memberful — subscription and account management. Memberful processes your email address and subscription status. • Stripe — payment processing. Stripe processes your payment information securely. • Kit (formerly ConvertKit) — email marketing platform. Your email address is stored here when you join our waitlist or opt in to marketing. • Supabase — database hosting. Your mood check-in and listen history data is stored here. • Amazon Web Services (AWS) — audio file storage and delivery. • Vercel — website hosting and infrastructure.

All third parties are required to handle your data securely and in accordance with applicable data protection law. We do not sell your personal data to any third party.

6. International transfers

Some of our third-party service providers operate outside the UK and European Economic Area. Where this occurs, we ensure appropriate safeguards are in place, including reliance on Standard Contractual Clauses or adequacy decisions, to protect your personal data in accordance with UK GDPR.

7. How long we keep your data

We retain your personal data for as long as your account is active or as necessary to provide the service. If you close your account, we will delete or anonymise your personal data within 30 days, except where we are required to retain it for legal or regulatory purposes.

Mood check-in and listen history data is retained for the duration of your subscription to enable the trend tracking feature. You may request deletion of this data at any time.

8. Your rights

Under UK GDPR, you have the following rights regarding your personal data:

• Right of access — you may request a copy of the personal data we hold about you. • Right to rectification — you may ask us to correct inaccurate or incomplete data. • Right to erasure — you may ask us to delete your personal data in certain circumstances. • Right to restrict processing — you may ask us to limit how we use your data. • Right to data portability — you may request your data in a structured, machine-readable format. • Right to object — you may object to processing based on legitimate interests or for direct marketing. • Rights related to automated decision-making — we do not make automated decisions that produce legal or similarly significant effects.

To exercise any of these rights, please contact us at privacy@upbrite.com. We will respond within one calendar month. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

9. Cookies

Upbrite uses a single session cookie (upbrite_session) to keep you signed in to your account. This cookie is strictly necessary for the service to function and does not track you across other websites.

We do not currently use advertising, analytics, or third-party tracking cookies. If this changes, we will update this policy and request your consent where required.

10. Security

We take the security of your personal data seriously. We use industry-standard measures including encrypted connections (HTTPS), encrypted session cookies, and access controls to protect your data. Payment data is handled exclusively by our PCI-compliant payment partners and is never stored on our own systems.

No method of transmission over the internet is completely secure. While we take all reasonable steps to protect your data, we cannot guarantee absolute security.

11. Children

Upbrite is not directed at children under the age of 16. We do not knowingly collect personal data from anyone under 16. If you believe we have inadvertently collected such data, please contact us at privacy@upbrite.com and we will delete it promptly.

12. Changes to this policy

We may update this privacy policy from time to time. When we make material changes, we will notify you by email or by posting a notice on the Upbrite website. The date at the top of this page shows when the policy was last updated. Continued use of the service after any changes constitutes acceptance of the updated policy.

13. Contact us

If you have any questions, concerns, or requests relating to this privacy policy or your personal data, please contact:

Conclude Limited privacy@upbrite.com

You also have the right to complain to the Information Commissioner's Office (ICO): www.ico.org.uk Helpline: 0303 123 1113