Privacy Policy

Upfrontly, Inc. (“Upfrontly,” “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 personal data when you visit our website, interact with our forms, or otherwise engage with us as a prospective platform partner, promoter, app developer, capital partner, or service provider.

This Policy is designed to comply with the EU General Data Protection Regulation (GDPR), the UK GDPR, the California Consumer Privacy Act as amended by the CPRA (collectively, “CCPA”), and other applicable data protection laws. Where specific laws grant additional rights, those rights are described in the relevant sections below.

1. Data controller

The data controller responsible for your personal data is Upfrontly, Inc.

For privacy inquiries, use the contact form on our About page.

2. Personal data we collect

We collect the following categories of personal data:

• Contact and business information you provide when submitting a pilot request, promoter or app developer waitlist form, capital partner inquiry, or general contact form: name, work email, company or platform name, role, phone (if provided), and free-text notes.
• Communications between you and our team, including emails, scheduled calls, and meeting notes.
• Technical and usage data when you visit the website: IP address, device and browser information, referring URL, pages visited, time spent, and interaction events — collected via cookies and similar technologies, subject to your consent (see Section 9).
• Marketing preferences, including opt-ins and opt-outs for email communications.

We do not knowingly collect sensitive personal data (racial or ethnic origin, political opinions, religious beliefs, health data, biometric data, sexual orientation, or genetic data) through this website. If you provide such information in a free-text field, we will delete it at the earliest opportunity.

3. Why we use your personal data and our lawful basis

Under GDPR Article 6, we process personal data only when we have a lawful basis. We rely on the following:

Purpose	Lawful basis
Respond to your inquiry; evaluate pilot or partnership opportunities	Legitimate interest (pursuing commercial opportunities you initiated) / pre-contractual steps at your request
Send marketing communications	Consent (you may withdraw at any time)
Operate, secure, and analyze the website	Legitimate interest, subject to cookie consent
Comply with legal, regulatory, and audit obligations	Legal obligation
Detect and prevent fraud or misuse	Legitimate interest

4. Who we share personal data with

We share personal data only with:

• Service providers acting on our instructions under written data-processing agreements — including hosting, email delivery, analytics, and customer-relationship-management providers.
• Professional advisors (legal, accounting, audit) where required for a specific engagement.
• Regulators, law enforcement, or courts where required by applicable law.
• Corporate transaction counterparties in connection with a merger, acquisition, financing, or similar event, subject to confidentiality.

We do not sell personal data, and we do not “share” personal data for cross-context behavioral advertising as those terms are defined under the CCPA.

5. International transfers

Upfrontly is based in the United States. If you are located in the European Economic Area, the United Kingdom, or Switzerland, your personal data may be transferred to and processed in the United States, which may not offer the same level of data protection as your jurisdiction.

Where we transfer personal data outside the EEA, UK, or Switzerland, we rely on the European Commission’s Standard Contractual Clauses (and the UK International Data Transfer Addendum, where applicable), or on adequacy decisions. Copies of the relevant safeguards are available on request via the contact form on our About page.

6. How long we keep personal data

We retain personal data only for as long as necessary for the purposes set out above:

• Inquiry and pilot form submissions: 24 months after last contact, or longer if a contractual relationship is established.
• Marketing contacts: until you unsubscribe, and up to 12 months thereafter for suppression-list purposes.
• Website analytics and cookie data: as described in Section 9 below.
• Records required for legal, regulatory, tax, or audit compliance: for the period required by applicable law.

After the applicable retention period, we delete, anonymize, or archive personal data in a secure manner.

7. Your rights

Depending on where you live, you have the following rights with respect to your personal data. We respond to valid requests within the time limits required by law (typically 30 days under GDPR, 45 days under CCPA).

If you are in the EEA, UK, or Switzerland (GDPR / UK GDPR)

• Access — ask whether we process your personal data and receive a copy.
• Rectification — ask us to correct inaccurate or incomplete data.
• Erasure — ask us to delete personal data (“right to be forgotten”), subject to legal retention obligations.
• Restriction — ask us to limit how we process your data.
• Portability — receive your data in a structured, commonly used, machine-readable format and transmit it to another controller.
• Objection — object to processing based on legitimate interests or for direct marketing.
• Withdraw consent — where processing is based on your consent, withdraw it at any time without affecting prior lawful processing.
• Complain — lodge a complaint with your local supervisory authority (in the UK, the ICO; elsewhere, see edpb.europa.eu).

If you are a California resident (CCPA / CPRA)

• Right to know the categories and specific pieces of personal information we collect, use, disclose, and sell or share.
• Right to delete personal information we collected from you, subject to exceptions.
• Right to correct inaccurate personal information.
• Right to opt out of the sale or sharing of personal information. We do not sell or share personal information as those terms are defined under the CCPA.
• Right to limit the use or disclosure of sensitive personal information. We do not use sensitive personal information for any purpose that would require a limit right.
• Right to non-discrimination for exercising your privacy rights.
• Authorized agent — you may designate an authorized agent to submit requests on your behalf.

How to exercise your rights

Submit your request via the contact form on our About page. We may need to verify your identity before acting on the request. We will not charge a fee unless your request is manifestly unfounded or excessive, as permitted by applicable law.

8. Security

We maintain administrative, technical, and physical safeguards designed to protect personal data against unauthorized access, disclosure, alteration, or destruction. These measures include encryption in transit and at rest, role-based access controls, audit logging, and vendor due diligence. No system is perfectly secure; we will notify affected individuals and regulators of any personal data breach as required by applicable law.

9. Cookies and similar technologies

We use cookies and similar technologies to operate the website, understand usage, and — only with your consent — measure and improve performance. You can manage your cookie preferences at any time by clicking Cookie preferences in the footer.

Essential cookies (required for the site to function, including your cookie-consent preference) are retained for up to 12 months. Analytics and marketing cookies are set only with your explicit consent and are retained for up to 12 months from your last visit. You can review and change your choices at any time via the Cookie preferences link in the footer.

10. Children

Our website and services are directed to business users and are not intended for individuals under the age of 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.

11. Changes to this Policy

We may update this Policy from time to time. The “Last updated” date at the top reflects the most recent changes. For material changes, we will provide additional notice (for example, via email or a banner on the website) before the changes take effect.

12. Contact

All inquiries: use the contact form on our About page.