Privacy Policy

Last Updated: August 14, 2025

Welcome to Upper Inc.’s Privacy Policy. Your privacy is important to us, and we are committed to protecting your personal data in compliance with applicable data protection laws, including the U.S. CAN-SPAM Act and the General Data Protection Regulation (GDPR) This policy explains how we collect, use, store, and share your information.

1. Data Collection

We may collect and process the following types of personal data if supplied by you:

Personal Identification Information: Name, email address, phone number, mailing address.

Technical Information: IP address, browser type, operating system, and cookies.

Other Information: Any information you voluntarily provide via forms, emails, or calls.

2. Data Usage

We use your personal data for the following purposes:

To provide and manage our investment services.

To comply with legal and regulatory requirements.

To improve our website, products, and services.

To send marketing communications (with your consent, where required).

To respond to your inquiries and provide customer support.

3. Data Sharing

We do not sell or rent your personal data. However, we may share your information with:

Trusted third-party service providers for business operations (e.g., IT services, payment processing).

Regulatory authorities, when required by law.

Business partners, with your explicit consent.

4. Cookie Policy

We use cookies and similar tracking technologies to enhance your browsing experience. Cookies are small files stored on your device that help us analyze website traffic and improve functionality. You can manage your cookie preferences through your browser settings.

5. Email Communication and Opt-Out

In compliance with the CAN-SPAM Act, which governs commercial emails in the United States We will clearly identify all commercial emails as advertisements.

We will provide our valid physical postal address in every email.

We will include a clear and conspicuous, easy-to-use opt-out link in all marketing emails, allowing you to unsubscribe from future communications .

If you wish to stop receiving marketing emails from us, click the "Unsubscribe" link in the footer of any such communication or contact us directly. Opt-out requests will be honored promptly.

6. Your Rights Under GDPR

The GDPR regulates the collection and use of personal data for individuals within the European Union As a user in the EU, you have the following rights regarding your personal data:

Right to Access: Request a copy of the personal data we hold about you.

Right to Rectification: Request the correction of inaccurate or incomplete data.

Right to Erasure (Right to Be Forgotten): Request the deletion of your personal data, under certain conditions.

Right to Restrict Processing: Request that we restrict how we process your data in specific circumstances.

Right to Data Portability: Request your data in a structured, commonly used, and machine-readable format.

Right to Object: Object to the processing of your data for direct marketing or other legitimate interests.

To exercise any of these rights, please contact us at the email address provided below.

7. Data Security

We use industry-standard administrative, technical, and physical security measures to protect your data from unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet is entirely secure, and we cannot guarantee absolute security.

8. Legal Basis for Processing

We process your personal data based on one or more of the following legal grounds as established under GDPR:

Consent: You have given us clear consent to process your personal data for a specific purpose (e.g., for marketing communications) Contract: The processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.

Legal Obligation: The processing is necessary for us to comply with the law (not including contractual obligations).

Legitimate Interests: The processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests.

9. International Data Transfers

If you are located outside the United States, your data may be transferred to, stored, and processed in the United States or other countries with different data protection laws than your country of residence. We use appropriate safeguards, such as Standard Contractual Clauses, to ensure your data is protected during such transfers.

10. Updates to This Policy

We may update this privacy policy periodically to reflect changes in our practices or for other operational, legal, or regulatory reasons. The latest version will always be available on this page with the "Last Updated" date revised accordingly. Please check back regularly for updates.

11. Contact Information

If you have questions or concerns about this Privacy Policy or wish to exercise your rights, you can contact us at:

Upper Inc.
310.623.7551
16129 Hawthorne Blvd ste D-125

Lawndale, CA 90260