This Privacy Policy explains which personal data are processed when you use Upstream.life, the purposes for which they are needed, who they may be shared with, how long they are retained, and which rights you may exercise.
Please read this Policy together with the Terms of Use and the Cookie Policy.
Privacy Policy
Privacy Policy
1. Who Is Responsible for Data Processing
The operator of Upstream.life and the controller of users’ personal data is Oleh Anatoliiovych Bokov, a sole proprietor registered under the laws of Ukraine, email: biblecourse@upstream.life (“Upstream,” “we,” “us,” or “our”).
The technical infrastructure of the Portal operates on the Clevio educational platform. LLC “DV Digital Media” provides technical access, maintenance, and support services for Clevio on behalf of Upstream and within the scope of Upstream’s documented instructions, unless applicable law requires otherwise.If you use the Portal through a church, school, employer, ministry, or another organisation, that organisation may also determine the purposes of learning and access certain learning-related data. In such cases, that organisation may act as an independent or joint controller in relation to its users.2. What Data We May Process
The scope of data depends on how you use the Portal and which features are enabled. We may process the following categories of data:
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Account data: first name, last name, email address, phone number, password in protected form, and user identifier.
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Learning data: enrolled courses, progress, test results, assignments, certificates, attendance, and activity time.
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Communications: support messages, comments, discussion responses, and feedback.
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Technical data: IP address, browser and device type, operating system version, event logs, session identifiers, and crash information.
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Integration data: data from CRM systems, SMS providers, video communication services, or other connected tools — only where the relevant integration is enabled.
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Payment data: payment status, order history, and payment identifier. Upstream does not store full bank card details where payment processing is carried out by a payment provider.
We do not ask you to upload special categories of personal data, such as information about health, political views, religious beliefs, or biometric data, unless this is required for a specific programme and is covered by a separate notice or lawful basis.
3. Why We Use Data
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Account creation and maintenance (account data): to provide access to the Portal and fulfil our agreement with the user.
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Organisation of learning (progress, results, assignments, certificates): to provide educational services, administer the programme, and follow lawful instructions from the organisation that provided access.
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Support and security (contact details, logs, IP address, messages): to resolve technical issues, protect against misuse, prevent fraud, and ensure stable operation.
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Payments (order data, payment status): to process purchases, maintain accounting and tax records, handle refunds, and provide support.
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Improvement of the Portal (aggregated or technical usage data): to analyse errors and improve the interface and features. Where possible, aggregated or anonymised data are used.
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Communications and newsletters (email address, preferences): to provide course-related information and service notices. Marketing communications may be sent where the required consent or another lawful basis is available.
4. Legal Bases for Processing
We process data where this is necessary to provide the Portal and fulfil our arrangements with you, comply with legal requirements, protect security and the legitimate interests of Upstream or third parties, or on the basis of your consent where consent is required.
For users in the European Economic Area and the United Kingdom, where the GDPR or similar legislation applies, we identify the relevant legal basis separately: performance of a contract, compliance with a legal obligation, legitimate interests, or consent. You may withdraw your consent for the future without affecting the lawfulness of processing carried out before its withdrawal.5. Who May Receive Data
We do not sell personal data. Access to personal data may be provided only to persons and organisations that reasonably need it for the operation of the Portal or to comply with the law:
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LLC “DV Digital Media” as the technical provider of Clevio, support, and maintenance services;
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hosting, cloud, and backup services used for the operation of the Portal;
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email, SMS, notification, video communication, CRM, and analytics providers — only where they are actually connected;
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payment providers, where a user pays for services;
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the organisation through which you received access to learning — to the extent necessary for learning administration;
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public authorities, auditors, accountants, or professional advisers, where required by law or necessary to protect Upstream’s rights.
6. International Data Transfers
Data may be stored or processed in Ukraine and in other countries where this is necessary for the operation of cloud infrastructure, backup services, technical support, or connected services. In the event of such transfers, we take reasonable safeguards required by applicable law and use contractual, organisational, and technical protections where necessary.
7. Retention Periods
We retain data no longer than necessary for the purposes described in this Policy, unless a different period is required by law, contract, the organisation that provided access, or the need to protect rights in the event of a dispute.
This also applies to any persons with whom we share your information and to those who provide services on our behalf. When we no longer need to use or retain your information in accordance with our legal or regulatory obligations, we will either delete it from our systems or remove personal identifiers so that you can no longer be identified.8. Your Rights
Depending on applicable law, you may request access to your data, correction, deletion, restriction of processing, data portability, object to certain types of processing, or withdraw your consent.
To exercise your rights, please contact us at biblecourse@upstream.life. We may ask you to verify your identity where necessary to protect your data. We respond to requests within the time limits established by applicable law.If you received access through an organisation, some requests — for example, those concerning learning progress, access to a programme, or the retention period for learning records — may require the involvement of that organisation. Where necessary, we will advise you where to direct your request.You may also lodge a complaint with the competent data protection authority if you believe that your rights have been violated.9. Our Policy Regarding Children’s Information
The Portal is not intended for independent use by children who have not reached the age at which they may lawfully consent to data processing in their country without the involvement of a parent, legal representative, or authorised organisation.
If you believe that a child has provided us with data without the required permission, please contact us at biblecourse@upstream.life.10. How We Make Changes to This Policy
We may amend this Policy from time to time. In that case, we will publish the changes on this page. If you continue to use the Portal after the changes take effect, this will mean that you agree to the updated Policy.
If the changes are material, we may send you a separate notice or ask for your consent where required by law.Effective Date: June 25, 2026.Last Updated: June 25, 2026.- Privacy Policy
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