Privacy Policy

Introduction

U Up Pty Ltd ("U Up", "we", "our", "us") operates a technology platform for structured booking requests. This policy explains what we collect, why, where it goes, and what we deliberately do not collect.

U Up is a booking platform. We charge a booking fee, we connect two adults, and we try to know as little about them as possible while doing it.

Three things worth stating plainly

• We never see your identity documents. Age and identity checks are carried out by a specialist provider on their own systems. We receive a result, not the evidence behind it.
• We never handle a provider's fee. That is paid in person, directly, and never passes through any account we control.
• We never see your exact address. Address lookup runs on our own servers. Nothing is sent to a third party.

This policy is written to meet the Privacy Act 1988 (Cth) and the Australian Privacy Principles, and it follows the Office of the Australian Information Commissioner's age-assurance guidance of 17 March 2026.

Information we collect

From clients

• Email address - account identity and booking confirmations. Held for the life of the account.
• Mobile number - one-time passcode verification and booking notifications. Life of the account.
• An age-check result - whether you are over 18, the method used, and when. Life of the account.
• Booking records - provider, time, duration and status. Held 7 years for tax and record-keeping obligations.
• Payment records - amount, timestamp, last four digits and card descriptor. Held 7 years.
• Device and log data - IP address, user agent and timestamps, for security and abuse investigation. Held 12 months.

We do not collect from clients: date of birth, government identity documents, facial images or other biometrics, home address, or payment card numbers.

From providers

• Email address and mobile number - account identity and notifications. Life of the account.
• Working name, suburb, stated age, rates and availability - the listing itself. Life of the listing.
• An identity verification result - pass or fail, the method, and a timestamp. Life of the account plus 2 years.
• Listing photographs. Life of the listing.
• A 30-day liveness re-check result. Only the most recent result is kept.
• Booking records. Held 7 years.
• A service address for a booking - held only for as long as the booking needs it, and deleted once the booking is complete.

We do not retain from providers: the identity document itself, or the image from a liveness check. Both are handled by our verification provider and are never stored by U Up.

From people without an account

If you contact us, for example to report content, we collect only what you send us, plus your email address if you provide one. Reports may be made anonymously.

How the age check works

This is the part most people want to understand, so it gets its own section.

Age assurance is carried out by Persona, an independent specialist verification provider. It is not carried out by U Up.

The normal path: a photograph, no document

You take a photograph with your camera. Persona estimates your age from it and tells U Up whether you are over 18. The image is handled by Persona and never reaches U Up. Because it is an estimate, the threshold is set conservatively.

The fallback: only if the estimate cannot resolve

If the estimate cannot place you confidently above the threshold, you are offered a document check instead. This exists so that nobody is locked out by an estimate, and so that a government document is never the only route available. It is a fallback, not the default.

What U Up stores, in full

Whether you are over 18, which method was used, and when the check happened. No date of birth. No document. No image. No biometric template.

This follows the OAIC's age-assurance guidance of 17 March 2026, which requires verification inputs to be destroyed once their purpose is met and expressly permits retaining a binary result, the method used, and a timestamp.

The check runs once. A returning client is never asked again. And it fails closed: if the check errors, times out, or the provider is unavailable, access is refused rather than granted.

Who we share information with

We use a small number of service providers, and each receives only what it needs.

• Persona - identity and age check inputs, which are never passed to U Up. Used for age and identity verification.
• Our payment processor - card details, entered directly into their hosted fields. Used to process the platform booking fee.
• OVHcloud, Sydney - hosts our application and database.
• Amazon SES, Sydney - email address and message content, for transactional email.
• Cloudflare - IP address and request metadata, for bot and abuse prevention.
• An SMS provider - mobile number and message content, for one-time passcodes and booking notifications.

Address data is deliberately not on this list. We self-host the Geoscape G-NAF address dataset, so address lookup happens entirely on our own infrastructure. No client or provider address is transmitted to any third party.

We do not sell personal information. We do not share it for advertising. We do not use it to train machine-learning models.

Overseas disclosure

Under Australian Privacy Principle 8 we must tell you when personal information may be disclosed outside Australia, and where practicable name the countries involved.

Held in Australia

Our application, database and backups are hosted in Sydney. Transactional email is sent from an Australian region. Address lookup never leaves our own infrastructure.

Disclosed overseas

Persona processes verification data outside Australia, in either the United States or the European Union. We have asked Persona to confirm which region applies to our account and will name it here as soon as we have it.

Cloudflare operates a global edge network, so request metadata such as an IP address may be processed in a country outside Australia depending on where you connect from.

Our SMS provider and our payment processor may also process information outside Australia. We are confirming the arrangements for each and will name the countries here.

We disclose only what each provider needs. In the case of identity and age verification, U Up never receives the underlying document, image or date of birth at all, so there is nothing of that kind for us to hold or disclose onward.

Sensitive information

Australian privacy law treats information about a person's sexual practices or orientation as sensitive information, with higher protection than ordinary personal information.

We recognise that using U Up may itself imply something of that kind. Our response is structural rather than procedural.

• We collect the minimum that lets a booking happen.
• We never ask a client for identity documents.
• We hold whether someone is over 18, not their birth date.
• The booking workflow uses predefined responses rather than free text, so there is no message history describing what anyone did.
• Location is held at suburb level for listings.

The design goal is that a breach of U Up would reveal as little as possible, rather than that a large sensitive dataset is well guarded.

Cookies and analytics

U Up uses cookies and similar technologies to keep you signed in, to remember preferences, to keep the platform secure, and to understand how the website and platform are used.

You can control cookies through your browser settings. Blocking some cookies may affect how the platform works.

More detail is set out in U Up's Cookie Policy.

Security

• Information is encrypted in transit and at rest.
• Card details never touch U Up's systems. They are entered into the payment provider's hosted fields, which keeps U Up at PCI DSS SAQ-A, the lightest assessment level and one available only to merchants that never handle card data.
• Access to production data is restricted to those who need it, and is logged.
• Identity documents and verification images are held by our verification provider under its own security and retention controls. U Up never receives them.
• Age-restricted material is withheld on the server from anyone who has not passed an age check, and the same rule is applied independently on the image route.

No system is perfectly secure. The next section explains what happens if something goes wrong.

More detail is set out on U Up's Security page.

Your rights

You may:

• Ask what we hold about you. We respond within 30 days.
• Correct it if it is wrong.
• Delete your account. We remove your personal information except where the law requires us to keep records, principally booking and payment records for tax purposes.
• Complain. To us first, at the address in section 12. If you are not satisfied, to the Office of the Australian Information Commissioner at oaic.gov.au. You do not need our permission and you do not need to come to us first.

If there is a data breach

We maintain a documented data-breach response plan.

Where a breach is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner as required by the Notifiable Data Breaches scheme.

Given the sensitivity of this category, our working assumption is that any breach involving user identity is a serious-harm breach unless it is clearly demonstrated otherwise.

Changes to this policy

If we change what we collect or who we share it with, this page is updated first, and material changes are notified to account holders before they take effect.

The updated version is posted here with a revised "Last Updated" date.

Contact us

For any privacy question, to ask what we hold about you, to correct it, to delete your account, or to make a complaint, contact U Up Pty Ltd.