Privacy Policy

Updated October 8, 2026

PREAMBLE

Our Privacy Policy (the "Charter") sets out how we treat the information we collect about you when you use the TURN UP Application ("the Application") and how you can control the application. use and disclosure of your personal data.

We attach great importance to protecting your privacy and personal data in the way we create, organize and implement our services. In order to maintain maximum protection with regard to the personal data we process, we will comply with the principles established by:

  • the OECD Council Recommendation on Guidelines for the Protection of Privacy and Transborder Flows of Personal Data
  • European Directive 95/46 / EC of 24 October 1995 on the protection of personal data until its repeal
  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46 / EC as from its implementation (the "New Regulation")
  • Law No. 78-17 of 6 January 1978 relating to computers, files and freedoms as amended in 2004 (the "Data Protection Act").

You are invited to read our Charter carefully. This Policy only applies to data collected directly on the Application and not to any data collected through any other website or application to which you may be redirected and through which your data would have been communicated to us. exclusion of data collected via Facebook.

I. DEFINITIONS

"Application" means the mobile application marketed under the name "TURN UP" created and published by SAS DATELY running on Android and iOS allowing access to User Services.

"Personal Account" means the account of the User allowing him to access the Services of the Application.

"Data" means any information relating to a person identified or that can be identified, directly or indirectly collected by DATELY such as the name, surname, photo and any other data provided by the User.

"Services" means the services provided by DATELY to Users, namely: (i) a connection service between Users and (ii) a private chat between Users.

"DATELY" means the simplified joint-stock company with a capital of 1,000 euros registered in the Paris Trade and Companies Register under number 837 545 086 and whose registered office is at 29, rue Henri Barbusse 91170 Viry-Châtillon,represented by its Chief Executive Officer Patrick Berczelly (contact@turn-up.app), which publishes and manages the Application operating the data processing and acting as data controller.

"User (s)" means any person who has opened a Personal Account on the Application and uses the Services.

II. MANAGING YOUR DATA

Through the Application, we collect the Data that you have provided to us by: (i) the creation of your Personal Account on the Application, (ii) your e-mails, or (iii) the use of the Services.

In this context, we may collect, in particular, the following Data depending on the security and use needs of the Application:

  • validate your registration and create your personal account
  • perform the linking services between the Users
  • allow you to use the Services offered on the Application
  • help us analyze your profile in order to bring you the best service
  • measure the number of downloads of the Application and perform statistical analysis to allow us to better understand the use of the Application by Users
  • send you e-mails of information or carry out the operations relating to the commercial prospecting including to carry out operations of solicitation, promotion, loyalty, survey and to send newsletters, being specified that you are informed of the faculty to refuse the collection of your Data to personal nature for this purpose, when collecting them
  • send you push notifications to inform you of any new content available on the Application, it being specified that you have the possibility to deactivate on your phone the sending of such notifications
  • enforce existing laws and regulations.

The data compulsorily collected - in a non-exhaustive way - by DATELY are the email address, surname, first name, date of birth, gender and photos.

The Application’s use and transfer to any other app of information received from Google Accounts will adhere to Google API Services User Data Policy, including the Limited Use requirements.

DATELY does not collect or process any data relating to your means of payment. These are managed directly, if necessary, by the Apple App Store, the Google Play Store of Android.

DATELY refuses to collect data from minor children. In the event of a User's lying about his date of birth and more particularly in case of fraudulent certification on his majority, the parents of the minor child are invited to inform DATELY by sending an email to contact@turn-up.app, in order to request the deletion of the data. DATELY undertakes to delete all personal data concerning the minor child as soon as possible.

III. YOUR RIGHTS - CLAIMS MANAGEMENT

You have a right of access, rectification, opposition and deletion of your Data in accordance with the provisions of articles 39 and 40 of the law n ° 78-17 of January 6th, 1978 relating to data processing, files and freedoms as amended in 2004.

To exercise these rights, you can send us an email at contact@turn-up.app or a postal mail to the following address: DATELY - Customer Service, 29, rue Henri Barbusse 91170 Viry-Chatillon.

As such, we will ask you to provide us with proof of your identity and specify the address to which we will send you the answer. If you are unable to prove your identity, the DATELY team reserves the right to refuse to respond to your request.

  • The right of access authorizes the User to interrogate DATELY in order to obtain the communication of the Data concerning him in an accessible form on the basis of article 39 of the Data-processing Law and Freedoms.
  • The right of rectification confers on the User the right to require that DATELY be rectified, completed, updated or deleted the Personal Data concerning him that are inaccurate, incomplete, equivocal, out of date or whose use, communication or preservation is prohibited on the basis of Article 40 of the Data Protection Act.
  • The right of opposition confers on the User the right to oppose, free of charge and in a discretionary manner, that his Data be used by DATELY for the purpose of prospecting, in particular commercial, on the basis of article 38 of the Data Protection Act.
  • The right of cancellation confers on the User the right to demand the free cancellation at no cost to the Data communicated to DATELY, within the limits of the legal obligations incumbent on DATELY as hosting provider.

We will answer you within two (2) months from the reception of your mail and will bring you, if necessary, the justification of our refusal to grant your request.

IV. DATA RETENTION

The Data you have entered in connection with the use of the Services are kept by us for the duration of your use of the Services for the purpose of using the service.

In accordance with Article 5.1 (e) of the GDPR, we retain your personal data only as long as necessary for the purposes for which it was collected. If your account remains inactive for more than three (3) years, all of your contact and profile data will be automatically anonymized or deleted, except where legal obligations require otherwise.

V. RECIPIENTS OF DATA

The Data about you that we collect and process is transmitted to our Google technical service provider who is bound by the same obligations of security and confidentiality in application of the Community provisions for servers located on the territory of the European Union and in accordance with the contracts concluded for those outside the territory of the European Union.

We also communicate some of your Data (first name, age, photo(s)) to other Users as part of the performance of the Services.

DATELY may also contract with authenticated and reliable subcontractors who may access, host and / or process certain personal data of Users on behalf of DATELY, according to its instructions, in compliance with the Charter and which guarantee the security and the confidentiality of Users' personal data. These subcontractors notably allow DATELY to establish statistics on the volumes of use and / or use of the Application and / or ensure the proper functioning of the Application.

Except for the above cases, we will only be able to share and share your Data with other providers and for other purposes after you have informed us and obtained your consent, as the case may be.

The personal data that the User has published in the Application are made strictly invisible by DATELY for non-registered users and third parties. The responsibility of DATELY can not be sought for data published on DATELY and disclosed by a User.

The profile of the User who does not match the search criteria of other Users will not appear on the news feed of these Users.

Mobile data: When the User uses the Application, DATELY collects server logs that may include information such as IP addresses, operating system, or application failures. DATELY is unable to access the browsing history of its Users.

VI. SECURITY

In accordance with Article 34 of the Data Protection Act, we are required to take all the necessary precautions to preserve the security of the Data and prevent it from being distorted, damaged, or unauthorized third parties having access to it.

Our concern is to preserve the quality and integrity of your Data. As such and in accordance with CNIL recommendations, we also ensure that our provider has implemented measures and / or installed devices to guard against attacks by injection of SQL code, scripts ... to guard against all unauthorized access, misuse, alteration, malicious or accidental destruction and unintentional loss of data.

We are committed to maintaining your Confidential Data and sharing it only in the above circumstances. As such, we guarantee that your Data are not communicated to institutions or governmental authorities, except in the cases provided by the provisions of Law No. 78-17 of 6 January 1978 relating to data processing, files and freedoms as amended in 2004, including for the purpose of responding to legal proceedings of any kind, to court orders, to any legal procedures or enforcement actions requested by the competent authorities.

VII. “DO NOT SELL OR SHARE” LINK

In compliance with the California Consumer Privacy Act (CCPA/CPRA) and similar U.S. state privacy laws (including Colorado, Connecticut, Florida, Oregon, Texas, Maryland, Minnesota, Montana, Delaware, Nebraska, New Hampshire, and New Jersey), we provide a “Your Privacy Choices” link within the Application.

This link allows users in eligible U.S. states to opt-out of the sale or sharing of personal information for targeted advertising or cross-context behavioral purposes.

This option is available directly in the app, from the login screen, under the label “Your Privacy Choices”. You may review or update your preferences at any time.

VIII. COOKIES AND TRACKERS ON THE TURN-UP.APP WEBSITE

As an exception to the preamble, this section applies to the turn-up.app website (the “Website”). When you visit it, cookies and other trackers may be stored on or read from your device. Except for strictly necessary trackers, they are only used with your consent, collected through the banner displayed on your first visit, in accordance with article 82 of the French Data Protection Act (loi Informatique et Libertés) and article 6.1 a) of the GDPR.

  • Necessary trackers: storing your cookie choices in your browser’s local storage. They do not require your consent.
  • Analytics: Google Analytics (Google Ireland Limited) measures traffic on the Website and the pages viewed in order to improve it. Without your consent, no Google Analytics cookie is stored; only technical signals, without cookies or persistent identifiers, may be sent to Google to estimate traffic.
  • Advertising: the Meta pixel (Meta Platforms Ireland Limited) and the TikTok pixel (TikTok Technology Limited) measure the performance of our advertising campaigns on Facebook, Instagram and TikTok, including visits to the Website and clicks to the App Store and Google Play. They are only loaded with your consent to the “Advertising” category.

The data collected by these trackers (cookie identifiers, IP address, browser and device type, pages viewed and actions taken on the Website) is sent to the companies listed above, which may process it outside the European Union, including in the United States, under the safeguards provided by the GDPR, such as the standard contractual clauses adopted by the European Commission. Meta and TikTok may also use this data for their own purposes, in accordance with their respective privacy policies.

Your choice is kept for six (6) months, after which you will be asked again. You can withdraw or change your consent at any time using the “Cookies” link at the bottom of every page of the Website. Refusing analytics and advertising trackers has no effect on your access to the Website.

IX. NOTIFICATION OF CHANGES

The creation of new services on our Application may involve the modification of our Charter which we will notify in this section.

In this case, the update date of the Charter will be updated and will indicate the day the changes were made.