Privacy Policy
This privacy policy contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights regarding your personal data and how to contact us or supervisory authorities in case of a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals and our wider operations in the European Economic Area (EEA).
Key terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our
UENetwork Ltd of 17 West View, Chirk, Wrexham, Wales, LL14 5HL
TINT & BLUSH LIMITED of 1386 London Road, Leigh On Sea, Essex, England, SS9 2UJ (as a data-sharing partner).
Personal data
Any information relating to an identified or identifiable individual
Data subject
The individual who the personal data relates to
Personal data we collect about you
The personal data we collect about you depends on the particular services we provide to you. We will collect and use the following personal data about you:
- Name
- Address (including country)
- Phone number
- Log-in credentials
- Your company name or website, if applicable
- Billing and payment information
- Communication preferences
- Any other information you voluntarily provide to us or that is necessary for us to provide the Services to you, such as agronomic data, farm production data, or any information about your land including digital shapefiles of field boundaries or field GPS coordinates
- Field boundaries or geo-location information with respect to fields
- User information, including the information entered and used to operate workflow apps you have installed and the performance information from those users
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing products and services to you.
How your personal data is collected
We collect most of this personal data directly from you—via our website and apps. However, we may also collect information:
- from publicly accessible sources, eg Companies House or HM Land Registry or equivalent;
- directly from a third party, eg:
- sanctions screening providers;
- credit reference agencies;
- customer due diligence providers;
- from a third party with your consent;
- from cookies on our website—for more information on our use of cookies, please see our cookie policy;
- via our IT systems.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, eg:
- where you have given consent;
- to comply with our legal and regulatory obligations;
- for the performance of a contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The table below explains what we use your personal data for and why.
| What we use your personal data for | Our reasons |
|---|---|
| Providing products and services to you | To perform our contract with you or to take steps at your request before entering into a contract |
| Preventing and detecting fraud against you or us | For our legitimate interest, i.e. to minimise fraud that could be damaging for you and/or us |
| Conducting checks to identify our customers and verify their identity; sanctions screening; compliance activities | Legal obligations or legitimate interests |
| To enforce legal rights or defend or undertake legal proceedings | Legal obligations or legitimate interests |
| Ensuring business policies are adhered to | Legitimate interests |
| Operational reasons (efficiency, training, quality control) | Legitimate interests |
| Ensuring confidentiality of commercially sensitive information | Legal obligations or legitimate interests |
| Statistical analysis to help manage our business | Legitimate interests |
| Preventing unauthorised access and modifications to systems | Legal obligations or legitimate interests |
| Protecting the security of systems and data | Legal obligations or legitimate interests |
| Updating and enhancing customer records | Contract performance, legal obligations, or legitimate interests |
| Statutory returns | Legal obligations |
| Ensuring safe working practices, staff administration and assessments | Legal obligations or legitimate interests |
| Marketing our services | Legitimate interests |
| External audits and quality checks | Legal obligations or legitimate interests |
| Sharing data during corporate transactions | Legal obligations or legitimate interests |
How and why we use your personal data — in more detail
More details about how we use your personal data and why are set out in the table below.
| Purpose | Processing operation | Lawful basis | Relevant categories of personal data |
|---|---|---|---|
| Communications with you not related to marketing | Sending communications required by data protection laws | Legal obligation (Article 6(1)(b)) | Your name, address, email, phone number, company details, username |
| Communications required by other applicable laws | Sending legally required notices | Legal obligation (Article 6(1)(b)) | Name, address, contact information, company details |
| Changes to terms, policies, or important updates | Sending updates about product/term changes | Legitimate interests (efficiency) | Name, address, contact information, username |
| Setting up and managing OnlyFans accounts | Collecting and processing personal data to create, manage, optimize accounts; promotion; collaboration | Contract performance (Article 6(1)(b)); Legitimate interests (Article 6(1)(f)) | Name, address, contact info, OnlyFans account data, billing data, Telegram username, content preferences, collaboration details |
How and why we use your personal data — sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
Marketing
We will use your personal data to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in using your personal data for marketing purposes. You can opt out of marketing communications at any time by contacting data@upperechelon.com or using unsubscribe links.
We may ask you to confirm or update your marketing preferences if you request further services or if laws change.
We will not share your personal data for marketing outside UENetwork Ltd. However, we may share with TINT & BLUSH LIMITED for marketing, but only where you have provided explicit consent.
Who we share your personal data with
We routinely share personal data with:
- third parties we use to help deliver our products and services to you, eg payment service providers, warehouses and delivery companies;
- other third parties we use to help us run our business, eg marketing agencies or website hosts;
- third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
- credit reference agencies;
- our banks;
- individuals and companies in Dubai and the USA who provide operational support, marketing, or service delivery;
- external auditors and professional advisors, e.g., lawyers, accountants, or consultants;
- law enforcement agencies, courts, tribunals, and regulatory bodies to comply with our legal and regulatory obligations;
- other parties that may acquire control or ownership of our business in connection with a significant corporate transaction or restructuring, including a merger, acquisition, or asset sale.
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
We or the third parties mentioned above occasionally also share personal data with:
- external auditors, eg in relation to the audit of our accounts, who will be bound by confidentiality obligations;
- professional advisors (such as lawyers or other advisors), bound by confidentiality obligations;
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with legal and regulatory obligations;
- other parties with or acquiring ownership of our business—information may be anonymised where possible, but confidentiality obligations always apply.
Who we share your personal data with — in more detail
More details about who we share your personal data with and why are set out in the table below.
| Recipient | Processing operation (use) by recipient | Relevant categories of personal data transferred to recipient |
|---|---|---|
| TINT & BLUSH LIMITED — Registered number 12748055, 1386 London Road, Leigh On Sea, Essex, England, SS9 2UJ | Operational support, account management, and promotional activities for content creators | Name, address, contact information, OnlyFans account details, payment information, Telegram username, content and promotional preferences |
| UENETWORK - FZCO, P.O. Box 4333, Dubai, United Arab Emirates | Management and operational support for content creators, including account setup, optimisation, and promotional activities | Name, address, contact information, OnlyFans account details, Telegram username, promotional preferences |
Who we share your personal data with — further information
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
Where your personal data is held
Personal data may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above.
Some of these third parties may be based outside the UK/EEA. For more information, including how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used. For example, we will only keep your data for five (5) years after you have deleted your account for compliance purposes.
Different retention periods apply for different types of personal data. Further details:
- Account information (e.g., OnlyFans account details, usernames, login credentials): for as long as the account is active and up to five (5) years after closure for compliance and legal purposes.
- Payment and billing information: seven (7) years (tax and financial regulations).
- Marketing preferences and communication records: up to two (2) years after last interaction unless opted out earlier.
- Social media account details (e.g., Telegram usernames) and promotional preferences: as long as required to provide services or until request for deletion.
- Operational and collaboration data shared with partner agencies: up to five (5) years after the collaboration or service agreement ends.
If you no longer have an account with us or we are no longer providing services, we will delete or anonymise your data after the relevant retention period.
Transferring your personal data out of the UK and EEA
It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In these cases we comply with applicable laws.
We transfer personal data to:
- service providers in UAE, specifically Dubai;
- service providers in the USA.
Under data protection law, we can only transfer your data to a country outside the UK/EEA where one of the following applies:
- The UK government has issued an adequacy regulation confirming the destination country ensures an adequate level of protection.
- (For EU transfers) The EU Commission has issued an adequacy decision.
- Appropriate safeguards (such as Standard Contractual Clauses) are in place.
- A specific legal exception applies.
Where we transfer your data outside the UK or EEA, we rely on adequacy regulations or Standard Contractual Clauses. If these mechanisms change, we will update this privacy policy accordingly.
International transfers of your personal data outside the UK — in more detail
More details about the countries outside the UK to which your personal data is transferred are set out in the table below.
| Recipient country | Recipient | Processing operation | Lawful safeguard |
|---|---|---|---|
| UAE | UENETWORK - FZCO, P.O. Box 4333, Dubai, UAE | Web and data hosting services enabling business operations | Adequacy regulation under the Data Protection Act 2018 |
| United States of America | Vida Salem, 3301 Michelson Dr #3228, Irvine CA 92612 | As above – operational, marketing, and service delivery functions | Adequacy regulation under the Data Protection Act 2018 |
International transfers of your personal data outside the EEA — in more detail
More details about the countries outside the EEA to which your personal data is transferred are set out in the table below.
| Recipient country | Recipient | Processing operation | Lawful safeguard |
|---|---|---|---|
| Dubai, UAE | UENETWORK - FZCO, P.O. Box 4333, Dubai, UAE | Management and operational support for content creators | Standard Contractual Clauses (EU GDPR Article 46(2)) |
| USA | Vida Salem, 3301 Michelson Dr #3228, Irvine CA 92612 | Collaboration and promotional activities for content creators | Standard Contractual Clauses (EU GDPR Article 46(2)) |
Transferring your personal data out of the UK and EEA — further information
If you would like further information about personal data transferred outside the UK/EEA, please contact us (see “How to contact us” below).
Your rights
You have the following rights, which you can exercise free of charge:
Access
The right to be provided with a copy of your personal data.
Rectification
The right to require us to correct any mistakes in your personal data.
Erasure (the “right to be forgotten”)
The right to require us to delete your personal data in certain situations.
Restriction of processing
The right to require us to restrict processing of your personal data in certain circumstances (e.g., if you contest the accuracy of the data).
Data portability
The right to receive personal data you provided to us, in a structured, commonly used and machine-readable format, and/or transmit that data to a third party—in certain situations.
To object
The right to object:
- at any time to your personal data being processed for direct marketing (including profiling);
- in certain other situations to our continued processing of your personal data (e.g., when processed for legitimate interests unless there are compelling grounds).
Not to be subject to automated individual decision making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
The right to withdraw consent
If you have provided us with consent to use your personal data, you have the right to withdraw that consent at any time.
You may withdraw consent by emailing: data@upperechelon.com
Withdrawing consent will not affect the lawfulness of our use of your personal data before the withdrawal.
For more information on each of these rights (including when they apply), please contact us or consult guidance from the UK Information Commissioner’s Office (ICO).
If you would like to exercise any of these rights, please:
- complete a data subject request form (available by emailing data@upperechelon.com); or
- email, call, or write to us (see “How to contact us” below);
- provide sufficient information to identify yourself (your full name, address, customer or matter reference number) and any additional identity verification information we request;
- inform us which right you want to exercise and the information it relates to.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being lost accidentally, used unlawfully, or accessed without authorisation.
We limit access to your personal data to individuals who have a genuine business need to access it. Those processing your information are subject to confidentiality obligations.
We also maintain procedures to deal with suspected data security breaches. We will notify you and any applicable regulator of a suspected breach where legally required.
For guidance on protecting your personal data from fraud, identity theft, viruses, and online threats, please visit www.getsafeonline.org.
How to complain
Please contact us if you have any concerns about our use of your personal data (see “How to contact us” below). We hope to resolve any issues.
You may also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO).
Changes to this privacy policy
This privacy notice was published on 5 November 2025 and last updated on 5 November 2025.
We may change this privacy notice from time to time—when we do, we will notify you via email or other appropriate methods.
Updating your personal data
We take reasonable steps to ensure your personal data remains accurate and up to date. Please let us know if any of your information changes (e.g., name, address).
You may also update your information through your account settings where applicable.
How to contact us
Individuals in the UK may contact us via:
Email: data@upperechelon.com
If you have questions about this policy, wish to exercise your data protection rights, or wish to make a complaint, please contact us.
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