1. Introduction

Our Service enables users to submit content (including images, videos, and metadata) to participate in research, feedback, and data collection programs with participating brands and partners.

2. Data Controller

The Service is operated by:

• Registered in: UAE
• Contact email: info@tupicmoment.com

For users in the European Economic Area (EEA), we act as a data controller under applicable data protection laws.

3. Types of Data We Collect

3.1 Information You Provide

• Account information (name, email, phone number if provided)
• Profile information (optional demographics such as age range, location region, gender if voluntarily provided)
• Uploaded content (photos, videos, text, product feedback)
• Labels, tags, or metadata submitted with content
• Social media links if you choose to connect them
• Communications with support

3.2 Automatically Collected Data

• Device information (model, OS version, app version)
• IP address
• Usage logs and interaction data
• Approximate location derived from IP (not precise GPS unless explicitly enabled)

3.3 Validation Data

• Votes or confirmations on your submission
• Quality scores generated by the system
• Timestamp and interaction logs

4. Purpose of Data Processing

• To operate and improve the Service
• To validate user-submitted content
• To provide rewards, credits, or incentives
• To generate anonymized or aggregated insights
• To provide licensed data access to participating brands
• To detect fraud, spam, or misuse
• To comply with legal obligations

5. Legal Basis for Processing (GDPR Compliance)

For users in the EEA, processing is based on:

• Consent (for uploading content, optional profile data)
• Contract performance (providing the Service)
• Legitimate interest (fraud prevention, platform security)
• Legal obligations where applicable

You may withdraw consent at any time.

6. Content Ownership and Licensing

You retain ownership of content you submit. However, by uploading content, you grant us:

• A non-exclusive, worldwide license to store, process, analyze, and display the content within the Service
• The right to provide licensed access to brands and partners for research, marketing insights, or product development

Where required, we may remove identifying information or aggregate or anonymize data before sharing. Brands receive usage rights, not ownership of your identity.

7. Public Posting and Social Sharing

Some programs may require or encourage sharing content publicly (for example on social media with watermark or tag). This is always optional unless clearly stated in a specific campaign.

If you choose to publish content publicly, it becomes subject to the privacy policies of those external platforms.

8. Data Sharing

We may share data with:

• Participating brands (licensed access to approved content or insights)
• Service providers (cloud hosting, analytics, fraud detection)
• Legal authorities where required by law

We do not sell user identity data to advertisers.

9. International Data Transfers

Data may be processed in the UAE, EU, or other jurisdictions where our service providers operate. Where required, we use:

• Standard Contractual Clauses (SCCs)
• Adequate safeguards for cross-border transfers

10. Data Retention

We retain data only as long as necessary:

• Account data: until account deletion
• Uploaded content: until deleted by user or program completion
• Logs and analytics: limited retention for security and compliance

You may request deletion at any time.

11. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access your data
• Correct inaccurate data
• Request deletion
• Restrict processing
• Object to processing
• Data portability

Requests can be sent to: data@tupicmoment.com

12. Children’s Privacy

The Service is not intended for users under 16 (or applicable local age). We do not knowingly collect data from children.

13. Security Measures

We implement:

• Encryption in transit and at rest
• Access control policies
• Fraud and abuse monitoring
• Regular security reviews

No system is completely secure, but we take reasonable measures to protect data.

14. UAE Compliance

We process personal data in accordance with:

• UAE Federal Decree Law No. 45 of 2021 (PDPL)
• Applicable local data protection regulations

Users in the UAE may contact us regarding data rights or complaints.

15. Changes to This Policy

We may update this Privacy Policy periodically. Users will be notified of material changes within the app or via email.

16. Contact

For privacy inquiries, contact us at:

• Email: info@tupicmoment.com
• Address: 1ONE, Jumeirah Gulf Estate, UAE