Privacy Policy

At Pullup App Ltd., respect for privacy and protection of our users' personal data (the "data") are part of our fundamental values. Our friends and family use Pullup every day, so we can guarantee that you will be treated the same way.

We are aware that others before us have given apps a bad reputation in terms of data management, that's why we want to clarify some key points right from the start:

You will find in this privacy policy (the "Policy") all the useful information to understand and be reassured about what we do with your data when you use the Pullup application ("the app", "the application", "Pullup"). We tried to make it as simple as possible.

Age Verification

Upon opening Pullup for the first time, we ask you to manually enter your age to verify that you have the digital majority in your country.

If we discover that we have inadvertently collected data from minors under the required age, we will delete them without delay!

Minimum age required by country

For all countries not listed below, the minimum age required is 13 years old.

Asia	South Korea	14
	Vietnam	15
Caribbean	Aruba	16
	Caribbean Netherlands	16
	Curacao	16
	Sint Maarten	16
Europe	Austria	14
	Bulgaria	16
	Croatia	16
	Cyprus	14
	Czech Republic	15
	Denmark	15
	France	15
	Germany	16
	Greece	15
	Hungary	16
	Ireland	16
	Italy	14
	Lithuania	14
	Luxembourg	16
	The Netherlands	16
	Poland	16
	Romania	16
	San Marino	16
	Serbia	15
	Slovakia	16
	Slovenia	16
	Spain	14
South America	Chile	14
	Colombia	14
	Peru	14
	Venezuela	14

How does Pullup collect your data?

When you decide to join Pullup, we collect certain information that personally concerns you and could allow to identify you (they are listed in Section 3).

We collect them directly from you:

if you choose to create a Pullup account; and
when you contact us via the Pullup app, by email or mail.

We receive them indirectly:

from Apple, Google or TikTok if you choose to connect to your Apple, Google or TikTok account to access the Pullup app; and
when we use analytics tools.

In all cases, we process your data under the conditions provided in this Policy.

Who controls the processing of your data?

Pullup App Ltd. ("We" or "Pullup") a private limited company, registered in the Companies House of England and Wales under number 167 429 28, whose head office is located at 6th Floor/37 Lombard Street, London, United Kingdom, EC3V 9BQ.

Pullup is responsible for processing and protecting your data in the Pullup app.

For any question, any request related to your data, or to exercise your rights detailed in section 5, you can contact our certified data protection officer:

From the app: By clicking on the "send feedback" section from the app settings
By email: At the following address: info@pullup.app. Clearly indicate the subject of your request for a quick and efficient treatment!
By mail: To: Pullup App Ltd., 6th Floor/37 Lombard Street, London, United Kingdom, EC3V 9BQ.

How does Pullup process your data?

The purpose of these tables is to clearly answer the following questions:

What data do we process when you use the Pullup app?
Why do we process your data?
On what basis do we process your data?
How long do we keep your data?

In all cases, we only process the necessary data and for a limited duration.

Account Creation

What data?	Why?	On what basis?	How long?
Your age (not your date of birth - we only keep the year of birth calculated on the age you entered)	To check that you have the numerical majority of the country you're in, and give you access to Pullup if that's the case!	Necessary to meet our legal obligations to protect minors and verify their digital majority.	As long as you have a Pullup account or max 3 years after our last contact.
A Name (you can change it at any time, we only keep the name you really use)	To display your name to your friends, it's pretty useful!	Necessary to use the app according to our terms and conditions.	As long as you have a Pullup account or max 3 years after our last contact.
A profile picture (which you choose and can change at any time - we don't have access to your photos)	Because it’s better with a pic!	Necessary to use the app according to our terms and conditions.	As long as you have a Pullup account or max 3 years after our last contact.
Your unique Pullup ID and device ID	To differentiate yourself from the others and make sure it's really you!	Necessary to use the app according to our terms and conditions.	As long as you have a Pullup account or max 3 years after our last contact.

Connection

If Connected with Apple	E-mail (your e-mail or the one generated by Apple); First and last name	So you can log in quickly without needing a password!	Necessary to use the app according to our terms and conditions.	As long as you have a Pullup account or max 3 years after our last contact.
If Connected with Google	E-mail, first name and last name (linked to your Google account or the one you choose for Pullup)	So you can log in quickly without needing a password!	Necessary to use the app according to our terms and conditions.	As long as you have a Pullup account or max 3 years after our last contact.
If Connected with TikTok	Your TikTok ID	So you can log in quickly without needing a password!	Necessary to use the app according to our terms and conditions.	As long as you have a Ten Ten account or max 3 years after our last contact.
If Connected with e-mail	Your e-mail address and the unique temporary login code you receive by e-mail	So you can log in quickly!	Necessary to use the app according to our terms and conditions.	As long as you have a Pullup account or max 3 years after our last contact.

Using Pullup

Data	What data?	Why?	On what basis?	How long?
Notifications	Settings of your phone (e.g. model, OS version, language preferences)	To let you know when a user wants to talk to you, poke you or is talking to you!	Necessary to use the app according to our terms and conditions.	We don't keep any notification history!
Usage settings	Information on the settings of your phone, “do not disturb” status if you have activated it on your phone.	To avoid Pullup launching at the wrong time (in class, for example )!	Necessary to use the app according to our terms and conditions.	We don't keep information on your status.
Friend management	The Pullup identifier of the user who makes the friend request.	So you can accept or decline friend requests, 'mute' or 'ghost' them!	Necessary to use the app according to our terms and conditions.	As long as you have a Pullup account or max 3 years after our last contact.
Communication with friends	Your voice (which we do not store and to which we do not have access.	So you can communicate with your friends.	Necessary to use the app according to our terms and conditions.	We don't have access to your voice so we don't store it!

Internal analyses

Data	What data?	Why?	On what basis?	How long?
Statistical analyses	Your unique Pullup identifier, your usage data (phone type, number of friends, IP address, battery level, etc.)	To be able to analyze the +s and -s of Ten Ten and improve its functionalities.	Our legitimate interest in continually improving the app and your user experience.	As long as the information is necessary for the evaluation of Pullup's performance.
Analyses de sécurité	Your usage data (bugs reported by you, connection history, etc.)	The purpose of the processing is to guarantee the proper functioning, availability and security of the Ten Ten app.	Our legitimate interest in continually improving the app and your user experience.	As long as the information is necessary for fixing a bug or assessing the security level.

Request management

Title	What data?	Why?	On what basis?	How long?
Management of requests to exercise rights	Your unique Pullup identifier, name, email address, information on the right(s) exercised, our exchanges.	To process and monitor your requests to exercise your rights over your data.	Necessary to meet our obligations under the GDPR.	During the period necessary to process your request.
Management of requests from competent authorities	Your unique Pullup identifier, last name, first name, email address if imposed by the authority.	To respond to an official and mandatory request from a competent authority.	Necessary to respond to legal requests imposed by competent authorities.	During the period necessary to process the request from the competent authority.
Management of user reports	The unique Pullup identifier of the reporting user and the one being reported, and the reason for the report.	To maintain a caring environment and avoid inappropriate behavior!	Our legitimate interest in protecting users in the event of inappropriate behavior or illegal content.	During the period necessary to process the report.

Who does Pullup share your data with?

To make your user experience as simple and pleasant as possible, we need external technical and IT providers (e.g. server providers, statistical software providers, secure data hosts, temporary unique connection validation code sending provider, etc...).

In all cases, we ensure to impose strict obligations and we only work with providers recognized for their security guarantees.

Transfers outside European Union

To maximize the security of your data and that of other users around the world, we use our trusted provider Amazon Web Services ("AWS") which hosts our users' data on servers based in the United States.

Don't worry, your data benefits from a level of protection recognized as equivalent to what we assure you within the European Union. AWS is of course on the list of organizations that have committed to respecting the data protection framework between the EU and the United States.

In any case and if necessary to achieve the objectives described in this Policy, we will not transfer your data outside the European Union before having framed and secured said transfer under the conditions of the GDPR.

For more details on the terms of transfer of your data outside the European Union, do not hesitate to contact us (see section 1 or 6).

What are your rights?

Get and check your data
You can ask us : whether Pullup holds any data about you; and obtain a copy of this data in a readable and comprehensible format.

Rectify your data
You can ask us to correct your data in case of error or change. For example, if you change your e-mail address.

Delete your data
In some cases, you can ask us to delete your data. For example, if your data is no longer required. You can also delete your Pullup account, but we'll give you 30 days to think it over before permanently deleting your account!

Block the use of your data
You can ask us to stop using your data if you have asked us to rectify your data or if you have objected to the processing of your data.

Take your data with you
You can ask to take a copy of your data with you, or pass it on to others for future use.

Define guidelines for the fate of your post-mortem data
This right isn't very cheerful, but it allows you to tell us what you want to do with your data after your death. For example, you can decide right now that all your data should be deleted at that time.

How to exercise your rights?

You can exercise your rights at any time:

From the app: By clicking on the "send feedback" section from the app settings
By email: At the following address: info@pullup.app. Clearly indicate the subject of your request for a quick and efficient treatment!
By mail: To: Pullup App Ltd., 6th Floor/37 Lombard Street, London, United Kingdom, EC3V 9BQ.

What if Pullup changes the policy?

We can update our Privacy Policy if this is necessary or if the law requires it.

Last update September 4, 2025