Most Up - Privacy Policy

Last Updated: February 3rd, 2025

INTRODUCTION

Most Up ("we," "our," or "us"), operated by Hmmm Ltd, is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, and protect your personal information when you use our mobile application ("Most Up" or the "App").

WHO WE ARE

Data Controller: HMMM Ltd - Office 1, Technology House, 9 Newton Place, Glasgow, Scotland, G3 7PR.

Email: anas@hmmm.team

KEY INFORMATION

The App provides financial transparency through leaderboards while maintaining user privacy options. We collect and process your data to:

• Connect with your bank account through GoCardless
• Display anonymizable financial rankings
• Show city-based leaderboards
• Provide usage analytics to improve our service

LAWFUL BASIS

We process your personal data on the following legal grounds:

• Contract: To provide our services as per our Terms and Conditions
• Consent: For connecting to your bank account via GoCardless
• Legitimate Interests: For analytics and service improvement
• Legal Obligation: To comply with financial regulations and data protection laws

INFORMATION WE COLLECT

5.1 Information You Provide

• Account information (age, gender, city)
• Profile pictures and display preferences
• Bank connection authorization through GoCardless
• City selection for leaderboard participation

5.2 Information Collected Automatically

• Bank balance information via GoCardless
• Usage data through Mixpanel analytics including:
• App interactions and feature usage
• Session duration and frequency
• App performance data
• Device information (operating system, device type, app version)

5.3 Location Data

• One-time city selection for leaderboard placement
• We do not track your ongoing location
• City information is stored to maintain leaderboard organization

HOW WE USE YOUR INFORMATION

6.1 Core Functionality

• Display your position on financial leaderboards
• Enable anonymous mode when requested
• Maintain city-specific rankings
• Process and display balance updates

6.2 Service Improvement

• Analyze app usage patterns through Mixpanel
• Identify and fix technical issues
• Improve user experience and features
• Generate anonymous statistical data

DATA STORAGE AND SECURITY

7.1 Storage

• Data is stored securely on Google Firebase infrastructure
• Primary servers located in London/Europe2 region
• Some processing may occur outside the UK/EEA within Google's secure infrastructure

7.2 Security Measures

• Industry-standard encryption for data in transit and at rest
• Regular security audits and updates
• Strict access controls and authentication
• Secure Firebase Authentication for user management

DATA SHARING

8.1 Third-Party Service Providers

• GoCardless: For secure open banking connections
• Google Firebase: For secure data storage and authentication
• Mixpanel: For anonymous usage analytics

We ensure these providers comply with data protection laws and maintain appropriate security measures.

8.2 Leaderboard Display

• Balance information is displayed to other users
• Age, gender, and city are shown on leaderboards
• You can control visibility through anonymous mode
• We never share your full banking details or transaction history

8.3 Other Disclosures

We may disclose your information:

• If required by law or regulation
• To protect the rights, property, or safety of our users
• In connection with a business transfer or reorganization
• With your explicit consent

YOUR RIGHTS AND CONTROLS

9.1 Your Rights

You have the right to:

• Access your personal data
• Correct inaccurate data
• Request data deletion
• Object to data processing
• Request data portability
• Withdraw consent at any time

9.2 How to Exercise Your Rights

• Anonymous Mode: Toggle in-app for immediate privacy
• Account Deletion: Available through app settings
• Data Access: Contact anas@hmmm.team
• Other Requests: Email us with your specific request

We'll respond to all requests within one month.

DATA RETENTION

10.1 Active Accounts

• Account information: Maintained while account is active
• Balance history: Stored for leaderboard functionality
• City data: Kept for leaderboard organization
• Analytics data: Retained for 12 months

10.2 Account Deletion

When you delete your account:

• All personal data is immediately deleted
• Bank connections are severed
• Profile and balance information is removed
• Anonymized analytics data may be retained

INTERNATIONAL DATA TRANSFERS

11.1 Data Location

• Primary data storage: UK/EEA (Google Firebase London/Europe2)
• Some processing may occur outside the UK/EEA
• All transfers comply with UK GDPR requirements
• Appropriate safeguards are in place through standard contractual clauses

11.2 Service Providers

We ensure all service providers:

• Maintain adequate data protection measures
• Process data in accordance with UK privacy laws
• Have appropriate data transfer mechanisms in place

COOKIES AND TRACKING

12.1 Mobile App Analytics

• We use Mixpanel for analytics
• No traditional browser cookies are used
• Device identifiers may be used for app functionality

12.2 Essential App Data

• Local storage for app functionality
• Authentication tokens
• User preferences
• Anonymous mode settings

CHANGES TO THIS PRIVACY POLICY

13.1 Updates

• We may update this policy periodically
• Significant changes will be notified in-app
• Continued use indicates acceptance of changes
• Previous versions available upon request

13.2 Notification

We will notify you of material changes through:

• In-app notifications
• Email notifications
• App store update notes

CONTACT & COMPLAINTS

14.1 Contact Us

For privacy-related queries:

Email: anas@hmmm.team

Address: Office 1, Technology House, 9 Newton Place, Glasgow, Scotland, G3 7PR

Response time: Within 5 working days

14.2 Official Complaints

You have the right to:

• File a complaint with the ICO (www.ico.org.uk)
• Contact your local data protection authority
• Seek judicial remedy

ADDITIONAL INFORMATION

15.1 Children's Privacy

• Minimum age requirement: 16 years
• We do not knowingly collect data from under-16s
• Contact us if you believe we have such data

15.2 Financial Information Notice

• Balance information is displayed for comparison only
• Not financial advice or recommendation
• Users should verify accuracy through their bank
• We are not responsible for financial decisions made based on leaderboard data

SUBSCRIPTION SERVICES

16.1 Subscription Overview

• Most Up offers auto-renewable subscriptions to access the app
• Subscription payments are processed through Apple's App Store
• Payment will be charged to your Apple ID account at confirmation of purchase
• Subscription automatically renews unless cancelled at least 24 hours before the end of the current period

16.2 Subscription Data Collection

We collect and process the following subscription-related data:

• Subscription status and type
• Purchase dates and renewal dates
• Transaction identifiers
• Payment status (through Apple's payment system)

16.3 Subscription Management

• Subscriptions automatically renew unless auto-renewal is turned off at least 24 hours before the current period ends
• You can manage and cancel your subscription through:
• iPhone/iPad: Settings → Apple ID → Subscriptions

16.4 Subscription Privacy

• Subscription status is stored securely with your account information
• Payment processing is handled entirely by Apple's App Store
• We do not store credit card or direct payment information
• Subscription status may be used to determine feature access

16.5 Billing and Renewals

• Account will be charged for renewal within 24-hours prior to the end of the current period
• Cost of renewal depends on your subscription plan
• Price changes will be notified in advance according to Apple's policies
• Refunds are handled through Apple's App Store support

16.6 Subscription Data Retention

• Active subscription data: Maintained while subscription is active
• Cancelled subscription data: Retained for 6 months after cancellation
• Historical subscription data: May be retained for legal and accounting purposes