Last updated: 26 March 2026
This AI Features and Data Use Notice (the "AI Notice") explains how Upstrive GmbH ("Upstrive," "we," "us," or "our") uses artificial intelligence-based features in the Upstrive mobile application and related services (together, the "Services").
This AI Notice is intended for users of our consumer-facing Services and should be read together with our Privacy Policy and Terms of Service.
Key point: When you interact with AI-powered features in the Services, you are interacting with an automated system and not with a human.
This AI Notice describes:
| Topic | What it means |
|---|---|
| AI functionality | What our AI-powered features do |
| AI data processing | What personal data and other information may be analyzed by AI systems |
| AI providers | When third-party service providers help us process data to generate AI outputs |
| User controls | What choices you have and how to withdraw from optional AI processing |
| AI limitations | What AI outputs can and cannot be relied on for |
This AI Notice is designed to support transparency under applicable privacy and AI laws, including European data protection rules and emerging AI transparency requirements for chatbot-like systems.1 2
Upstrive uses AI to support and enhance the in-app experience. Depending on the feature you use, AI may be used to:
| AI use case | Example |
|---|---|
| Generate short in-app text | Display messages or guidance through an in-app avatar or assistant |
| Support chat-style interaction | Respond to user questions or prompts inside the App |
| Provide contextual suggestions | Recommend relevant content, exercises, or next steps based on the user’s current in-app context |
| Improve safety and reliability | Detect abuse, harmful inputs, or technical problems affecting AI features |
Unless we expressly state otherwise for a specific feature, our AI tools are used to support your experience inside the Services and are not used to make legal, medical, employment, insurance, credit, education-admission, or similarly significant decisions about you.1 3
When you use AI-powered features, one or more of the following categories of data may be processed:
| Category of data | Examples |
|---|---|
| User-submitted inputs | Chat messages, prompts, questions, free-text responses, uploaded content, feedback |
| Contextual app data | Current screen, feature state, recent interactions, completed activities, user progress |
| Account and preference data | Language settings, subscription tier, feature settings, and similar account-linked context |
| Technical and session data | Device type, app version, timestamps, session identifiers, crash/error context, abuse-prevention signals |
| AI-generated outputs | Responses, suggestions, summaries, safety classifications, moderation flags, and related metadata |
Where AI-generated outputs, summaries, classifications, or inferences relate to an identified or identifiable user, we treat them as personal data.
We process AI-related data for the following purposes:
| Purpose | Description |
|---|---|
| Deliver the AI feature you requested | Generate the message, response, or suggestion you asked for |
| Personalize in-app experience | Use current context and progress to tailor relevant content or responses |
| Maintain safety and integrity | Detect misuse, harmful behavior, security threats, or policy violations |
| Troubleshoot and improve service reliability | Investigate bugs, crashes, and feature failures using proportionate technical data and limited review where necessary |
| Meet legal obligations and defend rights | Preserve records where necessary for compliance, dispute handling, or lawful requests |
We do not present AI outputs as human-authored messages where they are machine-generated, and we seek to avoid misleading users about the nature or capabilities of AI features.1
If you are located in the EEA, UK, or another jurisdiction requiring a formal legal basis, we may rely on one or more of the following bases, depending on the feature and the specific processing involved:
| Processing activity | Typical legal basis |
|---|---|
| Generating an AI response you directly request as part of the Services | Performance of a contract |
| Optional AI features or optional contextual personalization | Consent and/or legitimate interests, depending on the feature and local law |
| AI safety, abuse prevention, logging, and technical reliability | Legitimate interests; legal obligation where applicable |
| Processing necessary to comply with law or respond to authorities | Legal obligation |
Where we rely on legitimate interests, we assess necessity, proportionality, and the impact on users, and we apply safeguards such as minimization, access restrictions, technical controls, vendor restrictions, and user rights mechanisms.
Where we rely on consent, you may withdraw consent at any time. Withdrawal does not affect processing carried out before withdrawal.
Our AI-powered features are not intended to process special categories of personal data except where we explicitly say otherwise for a specific feature and provide any required safeguards.
This means you should generally not submit the following through AI chat or free-text features unless we specifically request it for a lawful and clearly explained purpose:
| Sensitive or restricted content | Examples |
|---|---|
| Health or mental-health information | Diagnoses, symptoms, medication, therapy details, crisis details |
| Government identifiers | Passport numbers, social security numbers, national IDs |
| Financial secrets | Bank credentials, full payment card numbers, tax identifiers |
| Confidential third-party data | Another person’s private information, employer secrets, private documents |
| Emergency or crisis information | Information requiring urgent professional, medical, or emergency response |
We also seek to avoid using AI to infer sensitive traits or states about users unless clearly disclosed and lawfully justified. Regulators have emphasized that inferred sensitive information can itself create privacy risk.
Unless we clearly tell you otherwise in a separate notice and obtain any consent required by applicable law:
We do not use your personal data submitted through the Services to train general-purpose AI models for unrelated purposes.
We do not allow our third-party AI inference providers to use your personal data submitted through the Services for their own independent model training or unrelated product development purposes.
However, limited processing may still occur for closely related purposes such as:
| Limited related use | Meaning |
|---|---|
| Safety and abuse monitoring | Detecting malicious use, policy violations, or harmful content |
| Transient or limited technical logging | Maintaining system availability, debugging failures, and ensuring reliability |
| Quality assurance under controlled conditions | Reviewing limited excerpts or metadata where necessary to investigate an incident, improve a feature, or validate safety, subject to access controls and minimization |
If Upstrive introduces a separate program that uses user content for model improvement, evaluation, fine-tuning, or training beyond these limited purposes, we will describe it clearly and obtain additional consent where required by law.
To deliver AI-powered features, we may use third-party service providers acting on our behalf.
| Provider category | Example function |
|---|---|
| AI inference providers | Generate text responses or contextual suggestions |
| Hosting and infrastructure providers | Run the application and store supporting data |
| Moderation and safety providers | Help detect abuse or unsafe content |
| Diagnostics and observability providers | Help detect crashes, failures, and service issues |
Our providers are contractually restricted to processing personal data only for the purposes we authorize, subject to applicable law and appropriate safeguards. Where required, we put in place data processing agreements and cross-border transfer mechanisms such as standard contractual clauses.
Before publication, Upstrive should confirm and insert the names of any core AI inference providers if it wishes to provide a more specific public disclosure.
AI-related processing may involve service providers located outside your country, including outside the EEA or UK.
Where required by applicable law, we use appropriate safeguards for international transfers, such as adequacy decisions, standard contractual clauses, and supplementary technical or organizational protections.
You may contact us for more information about the safeguards relevant to your data.
We retain AI-related data only for as long as reasonably necessary for the purposes described in this AI Notice, including feature delivery, security, reliability, dispute handling, and legal compliance.
| AI-related data type | Typical retention approach |
|---|---|
| Prompts and user AI inputs | Retained only as long as necessary to provide the requested feature, maintain safety, and support configured retention cycles |
| AI outputs | Retained only as long as needed to display, support, or troubleshoot the feature, subject to deletion and backup cycles |
| Safety, moderation, and abuse flags | Retained for periods proportionate to safety and legal needs |
| Technical logs | Retained for limited periods proportionate to diagnostics and security |
Before publication, Upstrive should align this section with the actual configured retention periods in the product and vendor stack.
Our AI systems are designed to assist and support the user experience. They do not operate as fully autonomous substitutes for human judgment.
Depending on the feature and the context, authorized personnel may review limited AI-related data where reasonably necessary to:
| Reason for review | Example |
|---|---|
| Customer support | Help resolve a user-reported problem |
| Safety and abuse prevention | Investigate misuse or harmful activity |
| Technical troubleshooting | Diagnose errors, malfunctions, or inaccurate outputs |
| Legal compliance | Respond to complaints, disputes, or lawful requests |
Such review should be limited, proportionate, access-controlled, and documented where appropriate.
AI-powered features may use limited contextual analysis or personalization based on your recent use of the Services.
However, unless we clearly state otherwise, we do not use AI-powered features to make solely automated decisions that produce legal effects or similarly significant effects about you within the meaning of Article 22 GDPR.
If a specific feature ever involves a higher-impact use case, we will provide additional notice and any safeguards required by law.
AI-generated content can be useful, but it is not always accurate, complete, or appropriate for every situation.
You should understand the following limitations:
| Limitation | What it means for users |
|---|---|
| Possible inaccuracies | AI outputs may be incomplete, outdated, misleading, or wrong |
| Context sensitivity | Outputs depend on the inputs and context available at the time |
| No professional advice | AI content is not medical, psychological, legal, financial, or emergency advice |
| No crisis support | AI features are not designed to respond appropriately to urgent or dangerous situations |
You remain responsible for evaluating AI-generated content and for decisions you make based on it.
If you are experiencing a medical, mental-health, or safety emergency, do not rely on the AI feature. Contact appropriate emergency services or a qualified professional immediately.
Depending on the feature and your jurisdiction, you may be able to:
| Control | What it allows |
|---|---|
| Avoid using AI features | Refrain from entering prompts or activating AI-powered interactions |
| Withdraw optional consent | Turn off optional AI personalization or similar features where consent is the basis |
| Delete content or account | Request deletion subject to legal and technical limitations |
| Exercise privacy rights | Request access, correction, deletion, objection, restriction, portability, or complaint rights where applicable |
For more information about your broader privacy rights, please see our Privacy Policy.
Our AI-powered features are not directed to children under the minimum age allowed under our Terms and applicable law. If you are not old enough to use the Services lawfully, do not use the AI features.
We also recognize that AI systems can create elevated risks for vulnerable users. We therefore seek to use appropriate safeguards, including transparency, output limitations, and restrictions on high-risk uses.
We may update this AI Notice from time to time to reflect changes to the Services, our providers, legal requirements, or our AI processing practices.
If we make a material change, we will provide notice through the App, website, email, or other appropriate means where required by law.
If you have questions about this AI Notice or our use of AI-powered features, please contact us at:
Upstrive GmbH
Email: info@upstrivesystem.com
General contact: info@upstrivesystem.com
