Privacy Policy

Last updated September 3, 2026

Thank you for choosing to be part of our community at Upwards Care, Inc. or any subsidiaries or services “Powered by Upwards” (collectively referred to in this policy as “Upwards,” “we,” “us,” or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at support@upwards.com .

When you visit our website https://upwards.com ("Website"), use our mobile applications (“Apps”), attend sales, marketing or other events, or otherwise access our online or offline offerings, including Subsidy Connect and optional guided application-support tools for child care subsidies and other public-benefit programs (our Apps and other offerings referred to collectively as the "Services"), you trust us with your personal information. We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Services.

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
7. DO WE COLLECT INFORMATION FROM MINORS?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. DO WE MAKE UPDATES TO THIS POLICY?
10. STATE PRIVACY RIGHTS
11. PRIVACY INFORMATION FOR NEVADA RESIDENTS
12. CALIFORNIA PRIVACY AND COMMUNICATIONS NOTICE
13. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

1. WHAT INFORMATION DO WE COLLECT?

In Short: The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use.

The personal information we collect is described below.

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when registering on the Services or Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or Apps (such as posting messages in our online forums or entering competitions, contests or giveaways) or otherwise contacting us. This information includes the following:

• Account Creation. We collect information such as your name, email address, phone number, zip code, username, password, or other relevant information when you create an account through any of our Services.
  • Provider profiles. If you are a Provider, in addition to your basic profile information, we may collect details regarding the care you offer, including for example the types of care services you provide, your availability, your location, your level of education, languages you speak, your ability to drive, any pictures of yourself you choose to post, your phone numbers, optional references, and any other information you choose to post in your public-facing profile.
• Child’s Information. When you create an Upwards account so that we may match your child with a Provider on our Upwards platform, we collect information such as your name, email address, phone number, child’s first name, age, and zip code.
• Subsidy Connect and Guided Application Support Information. If you use Subsidy Connect or our optional guided application-support tools for child care subsidies or other public-benefit programs (“Application Support Services”), we may collect, receive, or process information associated with your use of those Services. Depending on the program application, the information you choose to provide, and whether you choose to enable optional saved-progress features, this information may include:
  • Eligibility and household information, such as household income, number of children or dependents, household composition, employment or school schedules, and factors that may affect program eligibility, including homelessness, food insecurity, or receipt of public assistance;
  • Application-progress information, such as the pages or stages you reached, the date and time of activity, and information about where you paused or stopped using the guided experience;
  • Information entered into application fields that we are permitted to retain, such as your name, address, email address, phone number, date of birth, household-member information, children’s names and dates of birth, income, employment information, school schedules, and other information requested by an applicable program;
  • Information that may be considered sensitive personal information or otherwise sensitive under applicable law, where requested by an application and where you choose to provide it, such as gender, marital status, citizenship or immigration-related information, disability or special-needs information, foster-care or child-welfare involvement, homelessness, food insecurity, cash-assistance receipt, and other eligibility-related information;
  • Messages and other communications you submit through an automated chat feature;
  • A text-based description of content visible in the guided browser experience, which may include information displayed on an application page or a review-your-answers page; and
  • Technical and session information associated with the guided browser experience, including information needed to operate, secure, troubleshoot, and improve the Application Support Services.
  We use technical controls designed to prevent the collection or retention of certain highly sensitive information, including Social Security numbers, individual taxpayer identification numbers, tax-identification numbers, bank-account and routing numbers, driver’s-license numbers, passport numbers, passwords, and one-time authentication codes. For certain detected fields, we may record only that a field was completed and not the value entered.
  
  However, no filtering or suppression control is perfect. Third-party forms may use inconsistent labels, display information in unexpected ways, or include sensitive information in visible page content. As a result, highly sensitive information may occasionally be transmitted to or received by our systems despite these controls. If we identify such information, we will take steps designed to restrict access, prevent further use or disclosure, investigate the event, and delete or redact the information in accordance with our security and retention practices, unless retention is required by applicable law.
  
  You should not provide passwords, one-time passcodes, authentication codes, or other account-security credentials to us or through the automated chat feature. You are responsible for entering those credentials directly into the applicable third-party website.
  
  You may use the guided application experience without enabling optional storage of application answers. If you decline optional storage, we may retain limited application-progress information needed to operate, secure, troubleshoot, and improve the guided experience, but we will not retain application-field values for future reuse except as otherwise described in this Privacy Policy or required by law.
• Payment and Financial Data. We collect data necessary to process your payment if you make purchases or receive payment for services (e.g., daycare providers), such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument; purchase history; bank account information, such as routing number and account number; last four digits of your social security number; and invoices. All payment data is stored by Stripe and Plaid. You may find their privacy policy link(s) here: https://stripe.com/privacy and https://plaid.com/overview-privacy/.
• Your Communications with Us. We collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, request customer or technical support, apply for a job or otherwise communicate with us.
• Social Media Content. We may offer forums, blogs, or social media pages. Any content you provide on these channels will be considered “public” and is not subject to privacy protections.

Information automatically collected

In Short: Some information — such as IP address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information may include device identifiers and usage information, such as your IP address, cookie identifiers, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. See Section 4 for more information.

Information collected through our Apps

In Short: We may collect information regarding your geolocation, mobile device, and push notifications, when you use our Apps.

If you use our Apps, we may also collect the following information:

• Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services (such as ride pickups). If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's camera, microphone, storage, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
• Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.

Information from Website Visitors

In Short: We may collect information regarding your geolocation, and Website interactions, when you visit our Website.

When you visit our Website, we also use third party software to collect Internet or other electronic network activity information that may, alone or in combination with other information, constitute Personal Information, such as: your domain, your browser and operating system, your IP address, an imprecise geolocation; the date, time, and duration you visited the Website (timestamp); the pages you browsed on the Website; the source page URL used to visit the Website; any search terms used to navigate the Website; a browsing session ID; and whether you are a first time visitor to the Website. We may also collect information you choose to enter into search bars, help pages, or similar tools on the Website in order to respond to your requests, improve our Services, and for security and analytics purposes.

For additional information about cookies used on the Website, please review the section on DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES? below, and for information about how we handle communications under California law, please see California Invasion of Privacy Act (CIPA) Notice below.

Information from Other Sources

In Short: We may collect information about you from other sources to supplement the information that you have provided us.

We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through these services may include your name, your username, location, gender, birth date, email, profile picture, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.

1. By third parties to verify your information and representations
   In order to promote the safety and integrity of the Services, we may utilize third-party service providers to check your information on an ongoing basis against a variety of sources, which may include, but are not limited to, national criminal databases, sex offender registries, certain media streams, terrorist watch lists, criminal and fugitive watch lists, fraud watch lists, law enforcement reports, and other data to assist us in verifying the information you provide us and the representations and warranties you make in the Terms of Use and on the Website . The results of any Preliminary Membership Screens will be made available to Upwards.
2. By third parties that perform background checks
   As provided in the Terms of Use, we may provide some or all Registered Users and Website Visitors with the ability to request from a third-party consumer reporting agency that a background check be run on themselves or on Providers they are considering hiring using information that they and any subject Providers may provide. Any such background checks will be subject to the terms we establish for such checks on the Website pages where they are requested or authorized, the terms of this Privacy Policy, and our Terms of Use. Upwards may receive a copy of, or otherwise have access to, any such background check, unless otherwise specified in this Privacy Policy or the Terms of Use.

2. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

• Account Creation and Logon. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the information you allow us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
• Marketing and Promotional Communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see Section 9 below).
• Order Fulfillment and Management. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
• Protection of Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity).
• User-to-User Communications. We may use your information in order to enable user-to-user communications with each user's consent.
• Business Purposes, Legal Reasons and Contractual Purposes. We may use your information in order to enforce our terms, conditions, and policies for our legitimate business purposes.
• Legal Requests and Harm Prevention. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• User Account Management. We may use your information for the purposes of managing your account and keeping it in working order.
• Service Delivery. We may use your information to provide you with the requested service.
• Subsidy Connect and Application Support Services. We may use information collected through Subsidy Connect and the Application Support Services to:
  • provide eligibility-matching, guided-browser, and automated chat features;
  • help you navigate an application and understand general program or application information;
  • identify programs whose published eligibility criteria may be relevant to information you provide;
  • save and restore your progress, where you have chosen to enable that feature;
  • reuse information you have chosen to save to make future applications easier to complete;
  • provide support when you request help or resume a previously started application;
  • maintain, troubleshoot, secure, evaluate, and improve the Application Support Services;
  • identify, prevent, investigate, and remediate security incidents, including the inadvertent collection of highly sensitive information;
  • respond to your requests, comply with applicable law, enforce our agreements, and protect the rights, safety, and security of Upwards, our users, and others.
  We do not submit applications on your behalf. You remain responsible for reviewing information entered into an application, completing any login, identity-verification, CAPTCHA, or security steps, and submitting the application directly to the applicable government agency or program administrator.
  
  We do not make decisions about whether you qualify for a government benefit or whether a government agency or program administrator should approve, deny, or award an application. Government agencies and program administrators make those decisions.
  
  We may use de-identified or aggregated information to evaluate and improve Subsidy Connect, including the accuracy and usefulness of program-matching and application-support features. We do not use identifiable information collected through Application Support Services to train generalized artificial-intelligence models for use outside the Services without your separate consent.
• User Inquiries/Support. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
• Referral Program. Our Services may offer various tools and functionalities that allow you to provide information about your friends through our referral service; third parties may also use these services to upload information about you. Our referral services may also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker). More information on this program can be found at https://upwards.com/referrals and at https://upwards.com/referrals/terms.
• Other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience. We may use and store this information in aggregated and de-identified form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

We may process or share data based on the following legal basis:

• Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, for the vital health interests of the public, or as evidence in litigation in which we are involved.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may need to process your data or share your personal information in the following situations:

• Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, background checks or screening services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. Where such tracking technologies are nonessential (for example, for analytics, advertising, or personalization), they will be implemented only after you have provided your consent through our cookie banner or preference center where required by law. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent, or trade any of your information with third parties for their promotional purposes.
• Application Support Service Providers. We may disclose information to service providers that help us operate Subsidy Connect and the Application Support Services, including providers of cloud-browser infrastructure, hosting, security, data storage, communications, and automated chat or artificial-intelligence functionality. These providers may process personal information only as necessary to provide services to us and subject to contractual confidentiality, security, and data-use restrictions. We require these providers to use personal information only on our behalf and for the purposes authorized by us, and not to sell, share, use for independent marketing, or use to train generalized artificial-intelligence models, except as otherwise disclosed to you or permitted by applicable law.
• Business Partners. We may provide personal information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.
• Affiliates. We may share personal information with our affiliated companies.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Third-Party Advertisers. We may use third party advertising companies to serve ads when you use the Services. These companies may use information about your visits to our Website and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you. Where such technologies are nonessential, they will be implemented only after you have provided your consent through our cookie banner or preference center where required by law, and you may opt out or change your preferences as described in the “DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?” section.
• Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
• Third-Party Government and Program Websites. When you use Application Support Services, you may access a third-party government or program website through a guided browser experience. Information you enter directly into that website is subject to that third party’s privacy notice, terms, security practices, and other policies. We do not control those third parties’ handling of information you submit directly to them. The guided browser provider may process information visible during an active session in order to provide the browser service. We configure the service to disable session recording and logging where available, do not maintain a browser profile for the session, and cause the browser session to be destroyed when the session ends, subject to limited security and operational records retained by the provider under its applicable terms and data-processing commitments.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We use essential cookies to operate our Services and may use non-essential cookies and other tracking technologies (such as pixels and analytics tools) to collect and store your information only with your consent where required by law.

Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising technologies. When you first visit our Website, you will be presented with a cookie banner that explains how we use cookies and similar technologies and allows you to accept or reject non-essential cookies (such as advertising, analytics, and personalization cookies). We will not set non-essential cookies or similar tracking technologies until you have provided your consent through the banner or our cookie preference center. You can change your cookie preferences or withdraw your consent at any time by using the “Your Privacy Choices” link in the footer (where available) or by adjusting your browser settings, as described below.

• Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences and support certain functionality. We use essential cookies that are necessary for the Website to function, and, with your consent where required, we may use non-essential cookies for analytics, advertising, and personalization. Most browsers allow you to block and delete cookies. However, if you disable essential cookies, some parts of the Services may not work properly.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We treat pixels and similar technologies as nonessential tracking technologies, and we will only deploy them on our Website after you have provided your consent through our cookie banner or preference center where required by law. You may withdraw your consent or change your preferences at any time as described in this “DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?” section.

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features of our Services. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.

Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

Analytics. We may also use Google Analytics, Segment, Datadog, and other service providers to collect information regarding visitor behavior and visitor demographics on our Services. Where required by law, these analytics tools are implemented only after you have provided your consent through our cookie banner or preference center, and you may withdraw your consent or change your preferences at any time as described above. For more information about Google Analytics, please visit policies.google.com/technologies/partner-sites/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to https://tools.google.com/dlpage/gaoptout. For more information about Segment, please visit https://www.twilio.com/en-us/legal/privacy. For more information about Datadog, please visit https://www.datadoghq.com/legal/privacy/.

APIs/SDKs. We may use third-party application programming interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including analytics and advertising partners to collect your personal information for various purposes including to provide analytics services and content that is more relevant to you. Where these APIs or SDKs are used for nonessential purposes (such as analytics, advertising, or personalization), we will implement them only after you have provided your consent through our cookie banner or preference center where required by law. For more information about our use of APIs and SDKs, please contact us as set forth below.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We retain personal information for the period reasonably necessary to provide the Services, maintain your account, comply with legal obligations, resolve disputes, enforce our agreements, protect against fraud and security incidents, and establish or defend legal claims.

For Subsidy Connect and Application Support Services, we retain application-progress information for one year, saved application information for one year and text-based page descriptions for one year, unless a longer period is required or permitted by law. We maintain and apply a retention schedule for these categories of information.

If you withdraw consent for optional saved-progress features, close your account, or submit a valid deletion request, we will delete or de-identify applicable information, subject to lawful exceptions, including information needed to comply with legal obligations, maintain security, prevent fraud, resolve disputes, enforce our agreements, or preserve records required by law.

When we no longer have a legitimate business need to process your personal information, we will delete, de-identify, aggregate, or securely isolate it. If immediate deletion from backup systems is not feasible, we will securely store the information and isolate it from further active processing until deletion is feasible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We use organizational, administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, and destruction. These safeguards include encryption in transit and encryption at rest for personal information stored in connection with Subsidy Connect and Application Support Services, access controls designed to limit access to authorized personnel, logging and monitoring, and controls designed to detect and reduce the collection or retention of certain highly sensitive information.

No security measure is perfect, and we cannot guarantee that our safeguards will prevent every unauthorized access, disclosure, loss, or misuse of information. If we identify that highly sensitive information was inadvertently collected through Application Support Services, we will take steps designed to contain the information, restrict access, investigate the event, and delete or redact the information where appropriate and consistent with applicable law.

By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an email to you.

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children, except that a parent, guardian, or other authorized adult may provide information about a child or dependent in connection with our childcare-related Services, Subsidy Connect, or Application Support Services.

Although certain features of our Services allow parents to provide information regarding their children, we do not knowingly solicit data from or market to children under 13 years of age. By using the Services, you represent that you are at least 13 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. As part of our Upwards Childcare Services, we will collect your child's information, as defined in “What Information Do We Collect?” section above, only with the consent of the child’s parent or guardian. Such information is strictly used to match parents or guardians with Providers through our Services based on their child’s needs. If we learn that personal information from users less than 13 years of age has been incorrectly collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 13 or would like for us to delete your child’s information that you have provided to us, please contact us at support@upwards.com .

When a parent, guardian, or other authorized adult provides information about a child or dependent in connection with an application for a childcare subsidy or other public-benefit program, we process that information only to provide the requested Services, including eligibility matching, guided application support, saved-progress features where enabled, security, and support. We do not knowingly permit children to independently use the Application Support Services or to provide personal information directly through those Services.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time.

In accordance with applicable law, you may have the right to:

• Access the Personal Data we have about you, consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic Personal Data transferred to another party.
• Request correction of your personal information where it is inaccurate or incomplete.
• Request deletion of your personal information, subject to certain exceptions prescribed by law.
• Request restriction of, or object to, processing of your personal information, including the right to opt in or opt out of the sale of your Personal Data to third parties, if applicable, where such requests are permitted by law.
• Disconnect from your third party account (such as your Google or Facebook account).
• Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

If you have enabled optional saved-progress or future application-assistance features, you may withdraw your consent to future optional storage by using available account controls or contacting us as described below. Withdrawal of consent will not affect processing that occurred before withdrawal. Subject to applicable law and the exceptions described in this Privacy Policy, we will stop future optional storage and delete or de-identify information retained solely for those optional features.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. You may also request deletion of information associated with Subsidy Connect or Application Support Services without closing your account by contacting us as described below. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may access your account settings and update preferences or contact us as set forth below.

“Do Not Track”: Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

9. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

10. STATE PRIVACY RIGHTS

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. Depending on your state of residence and applicable law, you may have additional rights regarding sensitive personal information, including the right to withdraw consent for certain processing, limit certain uses or disclosures, or request deletion of information collected through Subsidy Connect or Application Support Services.

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Correct inaccuracies in their personal information, taking into account the information's nature and processing purpose (excluding Iowa and Utah).
• Data portability.
• Opt-out of personal data processing for:
• targeted advertising (excluding Iowa);
• sales; or
• profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
• Either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary by state. To exercise any of these rights, please email privacy@upwards.com. To appeal a decision regarding a consumer rights request, please email privacy@upwards.com .

11. PRIVACY INFORMATION FOR NEVADA RESIDENTS

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at privacy@upwards.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below.

12. CALIFORNIA PRIVACY AND COMMUNICATIONS NOTICE

If you are a California resident, this section provides additional information about certain California-specific privacy and communications practices. Although Upwards may not be subject to all requirements of the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA/CPRA”), we may voluntarily provide certain privacy rights and choices described in this section. The availability and scope of those rights and choices may depend on applicable law and the nature of your request. We do not record or intercept communications in violation of the California Invasion of Privacy Act (“CIPA”).

Categories of personal information we collect. Throughout this Policy, we discuss in detail the specific pieces of personal information we collect from and about our users. Under the CCPA, we are also required to provide you with the categories of personal information we collect as defined by California law. The categories we collect depending on the types of services you use are:

Category of Personal Information Collected by Upwards	Category of Third Parties Information is Disclosed to for a Business Purpose
Identifiers A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.	Advertising networks Data analytics providers Service providers Other Users/Public (name and postal address shared with Providers)
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) A name, address, telephone number, driver's license or state identification card number, education, employment, employment history, financial information, medical information, health insurance information, date of birth, household and dependent information, income, employment or education schedules, citizenship or immigration-related information, and information submitted in connection with an application for a child care subsidy or other public-benefit program.	Service providers Other Users (name, address, telephone number)
Protected classification characteristics under California or federal law Age (40 years or older), age or date of birth, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), marital status, citizenship or immigration-related information, disability or special-needs information, and other protected or sensitive characteristics that may be requested in connection with a public-benefit application.	Service providers Other Users
Internet or other electronic network activity Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement, including, where a consumer uses Application Support Services, application-progress information, pages or stages reached, interactions with the guided browser, and communications with an automated chat feature.	Advertising networks Data analytics providers
Geolocation data Physical location or movements.	Advertising networks Data analytics providers
Sensory data Audio, electronic, visual, or similar information.	Service providers
Professional or employment-related information Current or past job history or performance evaluations.	Service providers
Sensitive Personal Information Depending on the Services used and the information a consumer chooses to provide, this may include government identifiers; financial account information; health information; disability or special-needs information; citizenship or immigration-related information; foster-care or child-welfare involvement; homelessness; food insecurity; cash-assistance receipt; and other information that may be considered sensitive under applicable law.	Service providers
Inferences drawn from other personal information to create a profile about a consumer Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Advertising networks

We use and disclose sensitive personal information only as reasonably necessary to provide requested Services, perform services on our behalf, maintain security and integrity, detect and respond to security incidents, comply with law, and for other purposes permitted by applicable law. We do not use or disclose sensitive personal information to infer characteristics about you or for purposes unrelated to providing and improving the Services, except as permitted by applicable law or with your consent.

“Sales” or “Sharing” of Personal Information under the CCPA/CPRA. For purposes of the CCPA/CPRA, we do not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age, as the term “sell” is commonly understood. That said, we do share information with third party advertisers and analytics providers for the purpose of promoting our Services. To the extent that such sharing is considered a “sale” or “sharing” under the CCPA/CPRA, you may opt-out of having your information used for these purposes by disabling third party cookies on your device, adjusting your preferences through our cookie banner or preference center, or by contacting us as set forth below.

California Shine the Light. The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA/CPRA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “Contact Us” below and provide written authorization signed by you and your designated agent.

Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

Referral Programs and Similar Incentive Programs. As described above in “How We Use Your Personal Information” (“Referral Programs”), we may offer referral programs or other incentivized data collection programs. For example, we may offer incentives to you such as monetary payments or promotional items in connection with these programs, wherein you provide your personal information in exchange for a reward, or provide personal information regarding your friends or colleagues (such as their name and email address) and receive rewards when they sign up to use our Services. These programs are entirely voluntary and allow us to grow our business and provide additional benefits to you. The value of your data to us depends on how you ultimately use our Services, whereas the value of the referred party’s data to us depends on whether the referred party ultimately becomes a Caregiver or Parent and uses our Services. Said value will be reflected in the incentive offered in connection with each program.

Accessibility. This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.

California Privacy Rights and Choices.
If you are a California resident, you may have certain rights and choices regarding your personal information under applicable California law. In addition, Upwards may voluntarily honor certain requests described below, subject to verification and applicable legal exceptions.

• The right to know the categories and specific pieces of personal information we collect, use, disclose, and (if applicable) sell about you.
• The right to request deletion of your personal information, subject to certain exceptions.
• The right to correct inaccurate personal information.
• The right to opt out of the sale or sharing of your personal information, if applicable.
• The right to limit the use and disclosure of sensitive personal information, if applicable.
• The right to non-discrimination for exercising your privacy rights.

To exercise any of these rights, please contact us at support@upwards.com or by mail at the address listed below. We will verify your request using the information associated with your account, including email address. Government identification may be required. You may also designate an authorized agent to make a request on your behalf.

Notice of Collection and Use of Personal Information.
We collect the categories of personal information identified above for the business and commercial purposes described in this Privacy Policy. We do not use or disclose sensitive personal information for purposes other than those permitted under the CCPA.

If you use Subsidy Connect or Application Support Services, we may collect the categories of information described above to provide eligibility matching, guided application support, optional saved-progress and future application-assistance features, automated chat support, security, troubleshooting, and service improvement. We do not use this information to make decisions about whether you qualify for a government benefit or whether a government agency or program administrator should approve, deny, or award an application.

Right to Opt-Out of Sale or Sharing of Personal Information.
We do not sell your personal information as that term is traditionally understood (for example, we do not exchange lists of customer names for money). However, certain uses of cookies, pixels, and similar technologies with advertising and analytics partners may be considered a “sale” or “sharing” of personal information under the CCPA/CPRA. To the extent our use of these technologies is deemed a sale or sharing, you may opt out as described above. If our practices change, we will update this policy and provide you with a method to opt out of the sale or sharing of your personal information. You may also exercise your right to opt out of targeted advertising by disabling third-party cookies or contacting us as described above.

California Invasion of Privacy Act (CIPA) Notice.
We are committed to complying with the California Invasion of Privacy Act (“CIPA”). In connection with our Website and other online Services, we may collect information about your interactions with our Services, including when you use search bars, help pages, contact forms, chat features, or similar tools to submit information or requests. We use this information to operate, secure, and improve our Services, and to respond to your inquiries.

We may also use cookies, pixels, analytics tools, session-replay technology, and similar technologies to collect information about how you interact with our Website and Services. We implement non-essential cookies and similar tracking technologies only after you have provided your express consent through our cookie banner or preference center, and you may withdraw your consent or change your preferences at any time as described in the “DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?” section.

We do not use these technologies, or any third-party tools, for unauthorized wiretapping or eavesdropping, and we contractually require our service providers to use information collected through these tools only on our behalf and in accordance with applicable law and this Privacy Policy. If you have concerns about your privacy or believe your communications have been intercepted or monitored in violation of CIPA, please contact us immediately.

When you use Application Support Services, the guided browser and automated chat feature may process information about your interactions with a third-party application website, including page content, application progress, and messages you submit through the chat feature. We provide notice of this processing through this Privacy Policy and, where applicable, through a just-in-time notice or consent flow before optional storage of application information. We use service providers to support these features and require them to process information only on our behalf and in accordance with applicable law and contractual restrictions.

13. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may email us at support@upwards.com or mail us at:

Upwards
5521 N University Dr
Suite 104
Coral Springs, FL 33067
United States