Privacy Policy

Gain.Energy, Inc. (Upstrima) - Effective: October 29, 2024 | Last Updated: August 3, 2025

Gain.Energy, Inc. ("Gain.Energy," "we," "us") operates the Upstrima platform (the "Platform"), an AI-enabled workspace for oil & gas engineers and related professionals. This Privacy Policy explains how we collect, use, share, and protect personal data, and what rights you have.

1. Who We Are (Controller)

For personal data processed under this Policy, the data controller is:

Gain.Energy, Inc.

8 the Green, Suite A

Dover, DE 19901, USA

Email: upstrima@gain.energy (privacy & support)

We offer services to users in the EEA/UK. If you have questions, contact us at upstrima@gain.energy.

2. Scope

This Policy applies to personal data we process when you create or use an Upstrima account, visit our websites or apps, or contact us. If you use Upstrima through an organization (enterprise/workspace model), your organization may act as controller for workspace content; we would act as processor under a separate DPA.

3. Personal Data We Collect

A. Data You Provide:

  • Name, email, password (stored as a secure hash)
  • Company (if provided), role/title (if provided)
  • Profile settings and preferences
  • Support communications

B. Data Collected Automatically:

  • Device and browser type, OS, language
  • IP address and approximate location (city/country)
  • Logs of Platform activity (feature usage, timestamps, errors)
  • Cookie/SDK identifiers

We do not intentionally collect special-category data (e.g., health, biometric, political or religious data). Please avoid uploading such data.

4. How We Use Personal Data

We use personal data to:

  1. Provide the Platform
  2. Secure and prevent fraud/abuse
  3. Improve the Platform
  4. Support you
  5. Billing and administration (if applicable)
  6. Marketing (opt-in only in EEA/UK)
  7. Legal compliance
  8. Develop and maintain AI functionality using your content only to deliver features to you

5. Legal Bases for Processing (EEA/UK)

We process personal data on the following bases:

  • Contract (Art. 6(1)(b))
  • Legitimate interests (Art. 6(1)(f))
  • Consent (Art. 6(1)(a))
  • Legal obligation (Art. 6(1)(c))

6. AI and Model Training

Upstrima uses AI features to help you work more effectively. We process your content and prompts to provide AI features.

We do not train generalized AI models on your content.

When we use third-party LLM providers for inference, we send prompts/content to them with "no training / zero retention" settings enabled where available.

7. How We Share Personal Data

We share personal data only as needed to operate Upstrima, including with:

  • Infrastructure/hosting providers (servers located in the USA)
  • Authentication providers (if enabled)
  • Analytics and telemetry providers
  • Customer support tooling
  • Payment processors (if applicable)

We do not sell personal information.

We may disclose data if required by law or to protect rights, safety, and security.

8. International Data Transfers

Your data may be processed in the United States and other countries where our vendors operate. When transferring personal data from the EEA/UK to countries without an adequacy decision, we rely on appropriate safeguards such as the EU Standard Contractual Clauses (SCCs) and the UK Addendum, and we take supplementary measures where required.

9. Data Retention

Account data:Retained while your account is active; deleted or anonymized within 30 days after termination unless legally required longer.
User content:Deleted files move to Trash, where you can restore them for 30 days; after that they are permanently deleted. "Delete now" in Trash deletes a file at once. Deleted content is removed from backups within 60 days.
Agent files:Files uploaded to an agent and files it generates are deleted when you remove the agent or clear its chat.
Logs:Retained for 90 days, then deleted.
Billing records:Retained for 7 years.

10. Security

We use reasonable technical and organizational measures including:

  • Encryption in transit and at rest
  • MFA for admins
  • Role-based access controls
  • Audit logging
  • Least privilege access reviews

11. Your Rights (EEA/UK)

You may:

  • Access, correct, or delete your data
  • Restrict or object to processing
  • Request portability
  • Withdraw consent
  • Lodge a complaint with your supervisory authority

To exercise your rights, email upstrima@gain.energy or visit our Data Rights Portal.

12. California Privacy Rights (CCPA/CPRA)

California residents may:

  • Know, access, delete, and correct their data
  • Opt out of sale/sharing (we do not sell or share for cross-context behavioral advertising)
  • Not be discriminated against for exercising rights

Categories collected include identifiers, internet/activity data, and professional info you choose to provide.

13. Children

Upstrima is not intended for users under 16. We do not knowingly collect children's data.

14. Changes to This Policy

We may update this Policy. If changes are material, we will notify you via the Platform or email.

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