Privacy Policy

1. Introduction

Mindcom Media Ltd ("Company," "we," "us," or "our"), a company registered in England and Wales (Company Number: 07097944), operates the Upside platform at https://joinupside.io(the "Service"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service.

By accessing or using the Service, you agree to this Privacy Policy.

2. Information We Collect from Meta Platforms

To provide our ad-management services, we request access to data from your Meta accounts (Facebook and Instagram). Our use of this data is strictly limited to the following:

• Authentication: We use Meta Login to verify your identity and securely connect your Business Manager assets.
• Ad Management: We access Ad Account IDs, Page IDs, and Campaign metadata to allow you to create and manage advertisements.
• Performance Tracking: We retrieve aggregated performance metrics (impressions, clicks, spend) to provide ROI reporting in your Upside dashboard.

3. Legal Basis for Processing (GDPR)

We process your personal data under the following legal bases:

• Contract performance: Necessary to provide the Service (e.g., launching ads you have configured).
• Consent: You provide explicit consent when you click "Allow" on the Meta OAuth permissions screen.
• Legal obligation: Retaining transaction records for UK tax and accounting purposes.

4. Data Deletion & Revocation

We provide a clear and easy path for users to manage or delete their data:

• Self-Service Disconnection: You may disconnect your Meta assets at any time through the "Settings" menu in the Upside dashboard. This immediately invalidates and deletes our stored access tokens.
• Manual Deletion Request: You may request the permanent deletion of all your personal data by emailing admin@joinupside.io. We will process these requests within 30 days.
• Platform Revocation: You may revoke our app's access via your Facebook "Business Integrations" settings at https://www.facebook.com/settings?tab=applications.

5. Data Security

We implement industry-standard technical measures, including TLS/SSL encryption for data in transit and AES-256 encryption for data at rest. Access tokens are stored in a secure vault and are never exposed to other users or unauthorized third parties.

6. No Sale of Data

Mindcom Media Ltd does not sell, rent, or trade any data obtained through Meta APIs to third parties, data brokers, or advertising networks. Your data is used exclusively to facilitate the services you have requested within the Upside platform.

7. Contact Us

If you have questions about this policy or our data practices, please contact our Data Protection Officer: