Privacy Policy

Last updated: January 15, 2026

1. Introduction

Upturn Marketing Group, Inc. ("Upturn," "we," "us," or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website (upturnmarketinggroup.com), use our platform, or interact with our services.

By using our services, you agree to the collection and use of information in accordance with this policy. If you do not agree with the terms of this policy, please do not access our services.

2. Information We Collect

2.1 Information You Provide

We collect information you voluntarily provide when you register for an account, subscribe to our newsletter, request a demo, fill out a form, make a purchase, or contact us. This may include your name, email address, phone number, company name, job title, billing information, and any other information you choose to provide.

2.2 Information Collected Automatically

When you visit our website or use our platform, we automatically collect certain information including your IP address, browser type and version, operating system, referring URLs, pages viewed, time spent on pages, click patterns, device identifiers, and approximate geographic location based on IP address.

2.3 Information from Third Parties

We may receive information about you from third-party sources, including integration partners (e.g., Shopify, Salesforce), analytics providers, advertising networks, and public databases. We combine this information with data we collect directly to improve our services.

2.4 Customer Data

As a marketing platform, our customers upload and manage their own contact lists and customer data through our service. Upturn processes this data on behalf of our customers as a data processor. Our customers are the data controllers for their subscriber data and are responsible for obtaining appropriate consent.

3. How We Use Your Information

We use the information we collect for the following purposes:

4. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

5. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption in transit (TLS 1.3) and at rest (AES-256), access controls and authentication, regular security audits and penetration testing, employee security training, and incident response procedures. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

6. Data Retention

We retain your personal data only as long as necessary for the purposes outlined in this policy, unless a longer retention period is required or permitted by law. When data is no longer needed, we securely delete or anonymize it. Customer account data is retained for the duration of the subscription and for 90 days following account closure.

7. Your Rights

Depending on your location, you may have the following rights regarding your personal data:

To exercise any of these rights, contact us at privacy@upturnmarketinggroup.com. We will respond within 30 days.

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect information about your browsing activities. You can control cookies through your browser settings. We use essential cookies (required for site functionality), analytics cookies (to understand usage patterns), and marketing cookies (to deliver relevant advertising). You may opt out of non-essential cookies through the cookie settings on our website.

9. International Data Transfers

If you are located outside the United States, your information may be transferred to and processed in the United States. We implement appropriate safeguards, including Standard Contractual Clauses, to ensure your data is protected in accordance with applicable data protection laws.

10. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including the right to know what personal information we collect, the right to delete your personal information, the right to opt out of the sale or sharing of your personal information (we do not sell personal information), and the right to non-discrimination for exercising your privacy rights.

11. Children's Privacy

Our services are not directed to individuals under the age of 16. We do not knowingly collect personal information from children under 16. If we become aware that we have collected personal data from a child under 16, we will take steps to delete that information.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last updated" date. We encourage you to review this policy periodically.

13. Contact Us

If you have questions about this Privacy Policy or our data practices, contact us at:

Upturn Marketing Group, Inc.
123 Marketing Ave, Suite 400
New York, NY 10013
Email: privacy@upturnmarketinggroup.com
Phone: +1 (212) 555-0147