JetUP Partner Hub — Data Processing & Privacy Policy

Data Controller: JetUP LLC · Registry No. 402155813 Georgia, Tbilisi, Didube district, Uznadze street, N111, flat N11, Building N2 Email: welcome@jet-up.ai

Effective Date: April 17, 2026 · Last Updated: April 17, 2026

This Policy applies to the current beta release of the Partner Hub and is written to be GDPR-aware, as the Partner Hub serves users in the EU/Germany even though JetUP is registered in Georgia. We may refine the wording as the product evolves; the most recent version, shown by its "Last Updated" date, always applies.

1. Scope of This Policy

This Policy explains how JetUP processes personal data in connection with the Partner Hub — the personal pages partners publish at jet-up.ai/hub/{slug}. It covers two groups of people: the partner who builds and publishes the page, and the visitors who view the page and may leave their contact details.

This Policy complements JetUP's general website Privacy Policy on jet-up.ai. Where the Partner Hub is concerned, this Policy applies.

2. Who We Are (Data Controller)

JetUP LLC is the operator of the Partner Hub and the controller for the processing described here.

JetUP LLC · Registry No. 402155813 Georgia, Tbilisi, Didube district, Uznadze street, N111, flat N11, Building N2 Email / data-protection contact: welcome@jet-up.ai

JetUP does not maintain an EU office. All financial transactions are conducted via the independent, regulated broker (TagMarkets), which is a separate company and a separate controller for the data it processes.

3. What Data We Collect

3.1 Partner data (from the person building the page)

contact details — name and contact information (e.g. Telegram, WhatsApp, email);
photo uploaded for the AI Avatar;
voice recording uploaded for the AI Avatar;
about-text and any other content you enter;
social links and your personal referral link (taken from the IB Portal);
technical and usage data needed to operate the page.

3.2 Visitor / lead data (from people who use a partner's page)

name and contact details a visitor submits through the page (e.g. Telegram, WhatsApp, email);
selected area of interest (e.g. trading, partnership);
messages a visitor sends to the page's AI Assistant;
basic technical data (e.g. session and language).

We do not collect or store payment data, trading-account credentials, or passwords. Those are handled exclusively by the Broker.

4. Why We Process This Data (Purposes)

We process personal data to:

build and publish the partner's Hub page (about-text, links, layout);
generate the AI Avatar — process the partner's photo and voice to create the personalised video greeting;
operate the page's AI Assistant so it can answer visitor questions;
capture leads and pass them to the relevant partner, so the partner can follow up;
operate, secure, support, and promote the ecosystem and the Partner Hub (including the demonstration/showcase use described in the Terms of Use, Section 11).

5. Legal Bases for Processing (GDPR Art. 6)

Performance of a contract — Art. 6(1)(b): building, hosting, and operating the partner's page under the Terms of Use; passing leads to the partner.
Consent — Art. 6(1)(a): processing the partner's photo and voice to create the AI Avatar (see Section 6); and, where applicable, marketing communications to visitors.
Legitimate interests — Art. 6(1)(f): operating, securing, improving, and promoting the Partner Hub, and demonstrating the product, balanced against the rights of the people involved.

6. Photo and Voice for the AI Avatar — Explicit, Separate Consent

Creating the AI Avatar requires processing the partner's photo and voice recording to generate a video likeness. This is a distinct and sensitive type of processing, so it is based on the partner's explicit, separate consent, requested at the point of upload — not bundled into general acceptance of the Terms.

The partner may withdraw this consent at any time by contacting welcome@jet-up.ai. Withdrawal stops future processing and leads to deletion of the source photo/voice and avatar as described in Section 10; it does not affect processing already carried out before withdrawal.

7. Visitor Leads — Roles of JetUP and the Partner

When a visitor submits their contact details on a partner's page:

JetUP processes the lead to operate the page and to deliver it to the relevant partner;
once the lead is delivered, the partner uses it to follow up and becomes responsible, as a controller, for their own further use of that contact.

Each partner must handle the contacts they receive lawfully — including informing those people how their data will be used and honouring their rights.

8. Sharing and Disclosure

We do not sell or rent personal data. We share data only as needed:

with the relevant partner — visitor leads captured on that partner's page;
with service providers (processors) acting on our instructions — for example AI avatar generation, hosting, and messaging infrastructure, under appropriate data-processing terms;
with the independent, regulated broker — where a person chooses to register through a referral link, to enable that registration;
with communication platforms (e.g. Telegram, WhatsApp, Instagram, YouTube) where a person chooses to contact through those channels;
where required by law or to protect rights, safety, and the integrity of the platform.

9. International Data Transfers

JetUP is established in Georgia, which is outside the European Economic Area, while the Partner Hub serves users in the EU/Germany. Personal data may therefore be transferred to and processed in Georgia and in the locations of our service providers. Where required, we put in place appropriate safeguards for such transfers (for example, Standard Contractual Clauses with our processors).

10. How Long We Keep Data (Retention)

Visitor / lead and contact-form data: kept for a maximum of 24 months from the last contact, or until deletion is requested, consistent with JetUP's general retention practice.
Partner page content (about-text, links): kept for as long as the page is published and the partner relationship is active, then deleted within 30 days of takedown.
Photo, voice, and AI Avatar: kept for as long as needed to operate the avatar; deleted within 30 days after the partner withdraws consent, removes the avatar, or the page is taken down — unless retention is required by law.

11. Your Rights

Subject to applicable law, partners and visitors have the right to:

access the personal data we hold about them;
rectify inaccurate or incomplete data;
erase their data ("right to be forgotten");
restrict or object to processing;
data portability;
withdraw consent at any time (including consent for the AI Avatar), without affecting prior lawful processing;
lodge a complaint with a competent data-protection supervisory authority.

To exercise any right, contact welcome@jet-up.ai. We will respond within the timeframe required by applicable law.

12. Security

We apply reasonable technical and organisational measures to protect personal data against unauthorised access, loss, or misuse. No system is perfectly secure, but we work to keep your data protected and to limit access to what is necessary.

13. Cookies and Analytics

The Partner Hub uses minimal cookies for technical purposes only (such as sessions and language selection). No third-party tracking or analytics is used unless the user has explicitly consented.

14. Children

The Partner Hub is intended for adults (18+). We do not knowingly process the data of minors. If you believe a minor's data has been provided, contact welcome@jet-up.ai and we will delete it.

15. Changes to This Policy

We may update this Policy. The current version, with its "Last Updated" date, will be published in the partner cabinet and/or on the website.

16. Contact

For any privacy-related request or question: welcome@jet-up.ai

JetUP LLC · Registry No. 402155813 · Georgia, Tbilisi, Didube district, Uznadze street, N111, flat N11, Building N2

Appendix A — Consent Wording for the Registration Form

The registration form uses two separate consents. General acceptance of the Terms and Privacy Policy is one consent; explicit consent to process your photo and voice for the AI Avatar is a separate one, given on its own and never pre-ticked.

☐ Terms & Privacy (required). I have read and agree to the JetUP Partner Hub Terms of Use and Privacy Policy. I understand the Partner Hub is owned by JetUP and that I receive a right to use it, not ownership. I confirm I hold all rights to the materials I publish, and I agree that JetUP may use and publish my page and its content for demonstration and promotional purposes.

☐ AI Avatar — explicit consent (required). I explicitly consent to JetUP processing the photo and voice I upload to generate my personalised AI video greeting. I confirm this is my own likeness and voice (or that I have the person's explicit permission), and I understand I can withdraw this consent at any time at welcome@jet-up.ai.