Summary of Material Changes to our Policies

​​Dear UpScrollers,

We wanted to let you know that we've made some updates to our Terms of Service, Community Guidelines, and Privacy Policy. Here’s a summary of what’s changed across each.

Why are we updating our policies?

UpScrolled is growing, and as we introduce new features, expand into new regions, and adapt to evolving laws and regulations, we want to make sure the rules that govern our platform are clear, fair, and easy to understand.

Below is a summary of changes to our Terms of Service:

We updated the operating entity to UpScrolled B.V. and revised the governing law to the Netherlands, with disputes to be resolved in the courts of Amsterdam. This move reflects our commitment to operating under one of the world's most robust privacy and digital rights frameworks - the EU's General Data Protection Regulation (GDPR) and the Digital Services Act (DSA) - giving our global community stronger protections, greater transparency, and meaningful rights over their data and experience on UpScrolled.

We expanded the section on user content to better explain how content may be hosted and licensed to UpScrolled, while confirming that users retain ownership of their content.

We added a dedicated EU Digital Services Act (DSA) compliance section for users in the European Union, covering illegal content reporting, transparency in moderation decisions, appeals procedures, and cooperation with trusted flaggers.

We introduced a new Platform Liability and Hosting Status section, clarifying UpScrolled's role as a hosting provider consistent with intermediary protections under applicable laws.

We strengthened and expanded rules on platform abuse and manipulation and unauthorised automated access, including a prohibition on using platform data to train AI systems.

We introduced a formal Appeals process, including a requirement for EU users to submit appeals within six months of notification.

We revised the dispute resolution section to include an Out-of-Court Dispute Settlement (OCDS) mechanism for EU users under DSA Article 21, alongside an updated arbitration clause applicable to U.S. and Canadian users.

We revised legal provisions, including limitation of liability, indemnity, and governing law to reflect UpScrolled's move to the Netherlands and compliance with EU legal requirements.

Below is a summary of changes to our Privacy Policy:

We updated the Privacy Policy to reflect UpScrolled's headquarters in the Netherlands and primary data storage in Ireland.

We introduced a dedicated section for users in the European Economic Area (EEA) and United Kingdom, outlining legal bases for processing personal data under the GDPR and UK GDPR, formal data protection rights, and the right to lodge a complaint with a supervisory authority.

We appointed a Data Protection Officer (DPO), contactable at privacy@upscrolled.com, to oversee privacy and data protection compliance.

We added a UK Representative appointment for data protection purposes.

We expanded information on international data transfers, clarifying that transfers are protected through standard contractual clauses and other legally recognised safeguards.

We clarified the types of information collected, including IP-derived approximate location data, content and media uploads, and limited information from third-party sources such as identity verification providers.

We added a dedicated section for certain U.S. states, confirming that UpScrolled does not sell or trade personal information and does not engage in targeted advertising as defined under applicable state privacy laws.

We expanded the "Your Choices" section to cover account information, marketing communications, push notifications, and account deletion requests.

We updated the minimum age requirement to 16 and added clearer language on how we handle data from underage users if discovered.

Below is a summary of changes to our Community Guidelines:

We restructured the Community Guidelines around three core principles: connecting safely, sharing freely, and building community, with a new introductory framework explaining the least-restrictive, transparent enforcement approach (label → removal → suspension → deactivation).

We added more detailed standards for harassment and abusive conduct, including explicit prohibition of coordinated harassment campaigns and attempts to intimidate or silence others.

We expanded hate speech protections to include migration status as a protected characteristic alongside existing categories.

We clarified rules on violence and dangerous activities, explicitly permitting content documenting human rights abuses or war crimes with appropriate warnings, while prohibiting content that coordinates attacks on the platform.

We updated sexual content rules to specify that users who publish prohibited content will face immediate account termination and referral to authorities where applicable.

We strengthened child safety language with a reinforced zero-tolerance policy on child sexual exploitation and abuse (CSAM) content, consistent with DSA priority illegal content requirements.

We updated our misinformation and deceptive practices section to include impersonation of public officials and manipulation of civic or electoral processes.

We added expanded guidance on AI-generated and synthetic media, requiring disclosure of AI-generated content and prohibiting deceptive deepfakes or synthetic media intended to mislead.

We clarified enforcement actions and the appeals process, giving users the right to contest moderation decisions through in-app tools or by contacting safety@upscrolled.com.

We encourage you to review the updated policies in full to stay informed. The revised Terms of Service and Privacy Policy will go into effect for existing users by 30 May 2026. By continuing to use UpScrolled, you agree to the revised Terms of Service and Privacy Policy. If you have any questions, please don’t hesitate to reach out - we’re here to help.

Thank you for being a valued member of our community.