Privacy Policy

UPSHOPPERS LTD

Last updated: [2026-04-23]

UPSHOPPERS LTD (“Upshoppers,” “we,” “us,” or “our”) provides user identification, data analytics, and marketing automation technology to e-commerce businesses. We are committed to protecting personal information and processing it in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA/CPRA). This Privacy Policy explains how we collect, use, store, and protect information in connection with our services. Please note that this Privacy Policy does not cover personal data collected and processed by Upshoppers as part of services delivered to our clients. For information on how we handle client data, please refer to our Service Privacy Notice.

1. Our Role

In most circumstances, we act as follows:

Upshoppers

Data Processor

We process data only as directed by our clients and do not independently determine how data is used.

Our Clients (Brands / Merchants)

Data Controllers

They determine the purpose and means of data processing.

We process personal data solely within the scope authorized by our clients and do not independently determine the purposes for which such data is used.

2. Information We Collect

We may collect or process the following categories of information:

Information Provided by Users

When a user actively submits information on a client’s website — such as during account registration, newsletter sign-up, or form submission — we may collect:

Email address
Phone number
Other registration or subscription details

Automatically Collected Information

Through technology deployed on client websites (such as pixels, SDKs, or APIs), we may collect:

Browsing behavior (pages visited, clicks, time spent)
Product interaction behavior (product views, add-to-cart events, purchases)
Session data (navigation path, traffic source, clickstream data)

Device and Technical Information

IP address (which may be anonymized)
Browser type and version
Device type and operating system
Cookies and similar tracking identifiers
Login information where applicable

Visitor Identification and Matching Information

Where permitted by applicable law and authorized by our clients, we may use technical means to identify or match users, including associating anonymous browsing activity with existing user profiles and building behavioral profiles.

3. How We Use Information

We process information for the following purposes:

Service Delivery

Visitor identification and data matching
User behavior analysis
Marketing automation and triggered messaging

Client Marketing Optimization

Supporting email, SMS, and other messaging channels (subject to user consent)
Delivering personalized content and product recommendations
Improving conversion rates and customer retention
Conducting marketing analysis, assessing trends, and measuring the effectiveness of campaigns

System Security and Compliance

Fraud prevention and detection
Maintaining system stability and security
Fulfilling legal obligations
System administration, data analysis, testing, and research purposes

4. Legal Basis for Processing

We only process personal information when there is a lawful basis for doing so. Depending on the purpose of processing, the legal bases we rely on include:

Contractual necessity

Processing necessary to fulfil a contract with you or to take steps prior to entering into a contract.

Consent

Processing based on your freely given, specific, and informed consent, for example when you agree to receive marketing communications.

Legitimate interests

Processing necessary for our legitimate business interests, provided those interests do not override your fundamental rights and freedoms.

Legal obligation

Processing required to comply with applicable legal or regulatory obligations.

5. Cookies and Similar Technologies

We use cookies, pixel tags, and other tracking technologies to:

Recognize and track visitor behavior
Analyze website usage patterns
Enable personalized experiences
Distinguish you from other users and remember your preferences

Users may manage or disable cookies through their browser settings. Please note that disabling certain cookies may affect the availability or functionality of some features.

6. Information Sharing and Disclosure

We do not sell personal information.

We may share information in the following circumstances:

With Clients (Data Controllers)

As a service provider, we process and make relevant data available to our clients in accordance with their instructions.

With Service Providers

We may engage third-party service providers, including:

Cloud computing providers
Data analytics providers
Communication service providers (e.g., email and SMS delivery platforms)
Suppliers, business partners, and providers assisting with marketing, advertising, and service delivery

With Group Companies

We may share information with our group companies, including subsidiaries and our ultimate holding company, where necessary for operational or service purposes.

In Connection with Business Transfers

In the event of a merger, acquisition, sale of assets, or other business transfer, personal information may be shared with prospective or actual buyers as part of that transaction, subject to appropriate confidentiality obligations.

As Required by Law

We may disclose information where required by applicable law, regulation, court order, or at the direction of a competent regulatory or governmental authority, or where necessary to protect our rights, property, or safety, or that of our clients or users.

7. Data Storage, Security, and Passwords

We implement reasonable technical and organizational measures to protect data security, including:

Encryption of data in transit and at rest
Access controls and permission management
Security monitoring and regular auditing

Important: You are responsible for maintaining the confidentiality of any account credentials or authentication information associated with our services. If you suspect unauthorized access to your account, please notify us promptly using the contact details provided below. While we employ technical and organizational controls to protect your personal information, no method of internet transmission can be guaranteed to be completely secure.

8. Data Retention

We retain data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Once the retention period has expired, data will be deleted or anonymized.

Where we have processed data on the basis of consent and no other lawful basis applies, we will delete that data upon withdrawal of consent, subject to any exemptions under applicable data protection legislation. Unsubscribed contact details may be retained solely to prevent future unsolicited communications.

9. Your Rights

Depending on the laws applicable to you, you may have the following rights with respect to your personal data:

Access your personal data
Correct inaccurate data
Request deletion of data
Restrict or object to processing
Data portability
Withdraw consent
Lodge a complaint with a supervisory authority

To exercise any of these rights or to make an inquiry, please contact the relevant brand (Data Controller) or reach out to us directly using the contact information below. You also have the right to lodge a complaint with a data protection authority if you believe we have processed your data unlawfully.

10. International Data Transfers

As our services operate globally, data may be transferred to jurisdictions outside the country in which you are located. We ensure that any such transfers are conducted using appropriate safeguards — such as Standard Contractual Clauses — to maintain a level of data protection consistent with applicable legal requirements.

11. Third-Party Services and Links

Our services may integrate with third-party platforms (such as Shopify, Klaviyo, and others). Our websites and digital properties may also contain links to third-party websites and services.

The data processing practices of these third parties are governed by their own respective privacy policies. We do not accept responsibility or liability for third-party privacy notices or practices. Before submitting personal information to any third-party website or service, we encourage you to review their applicable privacy policy.

12. Updates to This Policy

We may update this Privacy Policy from time to time. Any revised version will be published on this page with an updated effective date. We encourage you to review this Policy periodically to stay informed about how we handle your information.

13. Contact Us

If you have any questions, requests, or complaints regarding this Privacy Policy or our data processing practices, please contact us at:

Company: UPSHOPPERS LTD

Email: [email protected]

Address: 421 Brookhurst St, Suite 1312, Anaheim, CA 92804, United States