Legal Document
Privacy, Sub-Processors,
& Data Safety Policy
Child Safety Standards
Global Upper Prayer Rooms GUPR maintains a zero-tolerance policy toward Child Sexual Abuse and Exploitation (CSAE). Our dedicated standards cover age verification, in-app reporting, CSAM handling, and law enforcement cooperation.
Read Child Safety Standards →The Core Compliance Statement
Compliance: UK GDPR / Data Protection Act 2018
GUPR Ltd acts as your primary Data Controller. We operate a cloud-native digital sanctuary structured on data minimization principles. GUPR Ltd does not sell user data, does not compile advertising user tracking dossiers, and does not monetize user metadata. All data processing maps directly to core application utility or legal security compliance.
Sub-Processor Matrix & Data Safety Map
Compliance: UK GDPR Article 13 / Apple Guideline 5.1.1 / Google Play Data Safety
To operate our decentralized application, we utilize exactly three enterprise-grade, GDPR-compliant sub-processors under explicit Data Processing Agreements (DPAs) in accordance with UK GDPR Article 28. We do not sell your data. This matrix mirrors the exact fields required for your Google Play Console Data Safety Form submission:
Real-Time Media Infrastructure Provider
Exact data types collected: ephemeral IP addresses and unique device identifiers. Processing type & scope: Transient/Ephemeral only — data is processed purely in RAM on a temporary, peer-to-peer packet routing basis to optimize connection matrices. Absolutely zero live video feeds, audio recordings, or voice streams are ever captured, saved, or stored on any server. Required vs. Optional: Required — only when participating inside a live Sanctuary room. Purpose:Core App Functionality & Network Quality Optimization.
Cloud Database Processor
Exact data types collected: user email addresses, user date of birth (DOB), chosen custom handles, encrypted auth credentials, and user-generated text (Prayer Wall entries). Processing type & scope: Secured & encrypted retention — saved within a hardened PostgreSQL infrastructure layer utilizing SSL encryption in transit and AES-256 at rest. Required vs. Optional: Required — to establish and maintain an authentic account profile. Purpose: Account Management, Security Enforcement, and App Functionality.
Subscription Management Layer
Exact data types collected: anonymous App User IDs, platform purchase codes, and package entitlement statuses. Processing type & scope: Abstracted ledger system — coordinates transaction eligibility tags directly with native Google Play / Apple billing APIs. Zero banking, credit card, or financial account parameters ever enter GUPR infrastructure. Required vs. Optional: Required — only when performing digital consumable purchases. Purpose: App Functionality, Entitlement Verification, and Purchase Management.
Data Minimization Boundaries
Compliance: UK GDPR Article 5(1)(c) — Data Minimization Principle
We aggressively eliminate tracking code vectors. GUPR does not capture, harvest, or log device IP addresses for marketing metrics. Account registration states and legal policy acceptances are written via localized Unix timestamps linked to an anonymous UUID string. We do not inject commercial tracking cookies, third-party advertising SDK layers, or marketing analytics trackers (such as Facebook or Firebase), keeping your data footprints perfectly restricted.
Right to Erasure (Account Deletion Mandates)
Compliance: UK GDPR Article 17 / Apple Account Deletion Directive / Google Play Data Deletion Policy
Under international data privacy statutes, you possess an unyielding, permanent “Right to be Forgotten.” GUPR provides two absolute self-service pathways to completely destroy all personal records instantly:
Two Absolute Self-Service Pathways
1. In-App Self-Service Purge — Users can navigate to Settings → Account → Delete Account. Triggering this command immediately executes a cascading delete routine that removes your authentication record from our Cloud Database Processor, obliterates your profile schema rows, strips your custom display handle, and wipes all text entries.
2. Web-Based Self-Service Portal — In compliance with modern app store data accessibility rules, you do not need the app installed to delete your profile. Users can navigate directly to our official web route at www.globalupperprayerrooms.com/delete-account from any browser. Authenticating through this link fires the exact same backend purge command, instantly clearing your data footprints from our server infrastructure.
Both pathways are permanent and irreversible.
For administrative data-safety audits, requests can also be filed directly to our data privacy team at info@globalupperprayerrooms.com.
Data Preservation & Law Enforcement Compliance
Compliance: UK Online Safety Act 2023 / NCA Cooperation / NCMEC CyberTipline / UK GDPR Article 6(1)(c)
Global Upper Prayer Rooms (GUPR) utilizes an ephemeral WebRTC architecture for live prayer rooms; live audio and video streams are strictly not recorded or stored by our servers. However, in cases of suspected Child Sexual Abuse and Exploitation (CSAE), severe Terms of Service violations, or formal law enforcement requests, all persistent data — including account information, session metadata (timestamps), text-based chat logs, and any uploaded files or media up to 5MB — are preserved in a secure, access-controlled environment for a minimum of 90 days to support legal investigations. GUPR does not capture, log, or retain IP addresses for this or any other purpose.
Child Safety & Law Enforcement
For CSAE-related reports or law enforcement cooperation requests, contact our dedicated safety team at info@globalupperprayerrooms.com. Full child safety standards are published at globalupperprayerrooms.com/child-safety.
Legal Links Matrix
Data Safety Form Inputs — GUPR Terms of Service & EULA
Submit Data Inquiries — info@globalupperprayerrooms.com
Regulatory Appeals — Information Commissioner's Office (ICO), United Kingdom
App Support & Assistance
Compliance: Apple App Store Review Guideline 1.5
Need help with your account, a live prayer room, or a purchase inside GUPR? Our support team is on hand to help. Contact us at info@globalupperprayerrooms.com - we aim to respond to genuine support enquiries within 24-48 hours.
Account or sign-in issues
Include your registered email and, if possible, your GUPR handle, so we can locate your account quickly.
Spark Minutes or Glory Glow purchase issues
Include your order or transaction reference where available.
Reporting a user or a room
Use the in-app Report function for the fastest response - it reaches our moderation queue directly.
Deleting your account
See Section 4 above, or visit www.globalupperprayerrooms.com/delete-account.
Safeguarding & Law Enforcement
For safeguarding concerns, child safety reports, or law enforcement enquiries, please see our Child Safety Standards page rather than general support.
This support channel is provided for genuine account, technical, and safety enquiries. GUPR reserves the right to decline correspondence unrelated to these purposes.
Privacy Enquiries & ICO Complaints
Contact info@globalupperprayerrooms.com. You may also file a complaint with the Information Commissioner's Office (ICO). Also read our Terms of Service.