Upturn Privacy Policy

Last Updated: August 26, 2026

This Privacy Policy explains how information about you is collected, used, disclosed, retained, and protected by Upturn Corporation ("Upturn," "we," "our," or "us"). This Privacy Policy applies to information we collect when you use our websites, mobile applications, investment-advisory features, artificial-intelligence features, APIs, and other online products and services (collectively, the "Services"), or when you otherwise interact with us.

Upturn Corporation is a Delaware corporation and an investment adviser registered with the U.S. Securities and Exchange Commission. This Privacy Policy should be read together with Upturn's Terms of Use, applicable investment-adviser disclosures, and any financial privacy notice Upturn provides under Regulation S-P, the Gramm-Leach-Bliley Act, or other applicable law.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, may provide additional notice, such as adding a statement to our homepage, sending an email, or providing an in-app notification. We encourage you to review this Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

Collection of Information

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information when you create or maintain an account, subscribe to the Services, create a watchlist or simulated Robo-Portfolio, use search or AI-assisted features, select preferences, request customer support, request account deletion, exercise a privacy right, or otherwise communicate with us.

The types of information we may collect include your name, email address, account identifier, Google or Apple authentication identifier, watchlist contents, simulated portfolio selections, stocks or ETFs viewed or saved, search queries, investment themes, preferences, notification settings, subscription and transaction records, support correspondence, and any other information you choose to provide.

Authentication Information

Upturn accounts are created and accessed through Google or Apple sign-in. Upturn does not offer a separate username-and-password registration method and does not collect or store the password associated with your Google or Apple account.

Google or Apple may provide Upturn with information authorized through the sign-in process, such as your name, email address, authentication identifier, and other limited account information permitted by the applicable provider and your settings. The provider's privacy policy and account settings govern its separate processing of your information.

Payment and Subscription Information

Upturn subscriptions are purchased directly from Upturn and payments are processed by Stripe. Payment-card information is provided directly to Stripe. Upturn does not collect, receive, or store complete payment-card numbers or card security codes.

Stripe may provide Upturn with transaction identifiers, payment status, subscription status, renewal and cancellation dates, invoice information, and limited billing details needed to administer your subscription. Stripe processes payment information under its own privacy policy, contractual terms, and legal obligations. Google and Apple are used for authentication and are not payment processors for Upturn subscriptions.

Information We Collect Automatically When You Use the Services

When you access or use our Services, we and our service providers automatically collect certain information about you, including:

• Log Information: We collect log information about your use of the Services, including the type of browser you use, access times, pages or screens viewed, your IP address, the approximate city or region from which you accessed the Services, the page you visited before navigating to our Services, session duration, and the frequency of your interactions with particular features.
• Preferences or Options Selected in the Application: We collect information such as stocks or ETFs added to or removed from watchlists, simulated Robo-Portfolio selections, saved searches, notification settings, and other preferences or options selected in the application.
• Device Information: We collect information about the computer or mobile device you use to access our Services, including hardware model, operating system and version, browser type, unique or technical device identifiers, application version, and mobile-network information.
• Approximate Location Information: We may collect approximate geographic location based on an IP address. This typically identifies a country, region, or city and may be inaccurate because of VPN use, mobile networks, or internet-service-provider routing. Upturn does not collect precise device location unless a feature expressly requests it and you grant permission.
• Information Collected by Cookies and Other Tracking Technologies: We use cookies, software development kits, pixels, local storage, web beacons, and similar technologies. These technologies help operate and secure the Services, remember preferences, enforce usage limits, understand which areas and features are popular, count visits, measure campaign effectiveness, and improve user experience. More information appears in the Cookies Policy section below.

Information Collected Through Third-Party Services

Data Collection and Usage

We use Google Analytics, Firebase Analytics, Firebase Crashlytics, and Microsoft Clarity to understand how users interact with our website and application. These services help us improve performance and functionality, optimize user experience, diagnose errors, understand engagement, and protect the Services from misuse.

Microsoft Clarity may capture behavioral metrics, heatmaps, clicks, scrolling, mouse movements, navigation, and session-replay information to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement. We do not use Microsoft Advertising. Advertising displayed by Upturn is provided through Google AdSense.

Information Collected

Personal and Authentication Data

• User Authentication: Google, Apple, or Firebase authentication may provide an email address, authentication identifier, name, or other limited information authorized by the user and the applicable provider.
• User Identifiers: Firebase and other providers may generate identifiers for authentication, analytics, crash reporting, security, or service operation.

Usage and Device Data

• Crash Data: Firebase Crashlytics may collect crash logs, device information, application status, and diagnostic information to help identify and correct stability problems.
• Analytics Data: Google Analytics, Firebase Analytics, Microsoft Clarity, and similar providers may collect usage patterns, application interactions, engagement metrics, pages viewed, links selected, and time spent using the Services.
• Device Information: These services may collect IP addresses, device type, operating system, browser type, application version, and technical identifiers.

Demographic Data

Google Analytics or advertising services may make aggregated or inferred demographic information available, such as approximate age range, gender, or general interests, depending on the user's Google settings, cookies, device configuration, and the service configuration used by Upturn.

Microsoft Clarity focuses primarily on behavioral and interaction analytics rather than providing Upturn with identified demographic profiles. Demographic reporting available to Upturn is generally aggregated or subject to minimum reporting thresholds and is not used by Upturn to identify a particular individual.

Location Data

• Collection Method: Google Analytics, Firebase Analytics, and similar services may infer approximate location from an IP address, typically at the country, region, or city level.
• Purpose: We use approximate location to understand the geographic distribution of users, operate and secure the Services, evaluate regional usage, and improve user experience.
• Accuracy: Approximate location may be inaccurate because of VPNs, proxies, mobile networks, or internet-service-provider routing.
• User Controls: Users may adjust device, browser, cookie, and advertising settings. VPNs or proxies may also affect the location inferred from an IP address.

How We Use Analytics and Technical Data

• Improve website and application performance, usability, and reliability;
• Identify technical issues, crashes, and errors and optimize content;
• Analyze user engagement, feature usage, navigation, and behavior;
• Enforce plan or free-tier usage limits;
• Measure advertising and campaign performance; and
• Detect, investigate, and prevent security threats, fraud, and abuse.

Third-Party Processing and Privacy Policies

Analytics, authentication, payment, AI, and advertising providers process information to provide services to Upturn and may also process information under their own applicable terms, settings, privacy policies, and legal obligations. Upturn discloses personal information to these providers as described in this Privacy Policy;

• Google Privacy Policy: https://policies.google.com/privacy
• Firebase Privacy and Security: https://firebase.google.com/support/privacy
• Microsoft Privacy Statement: https://www.microsoft.com/privacy/privacystatement
• Microsoft Clarity information: https://learn.microsoft.com/clarity/
• Stripe Privacy Policy: https://stripe.com/privacy

User Controls and Opt-Out Options

Depending on the technology and your location, you may manage or limit analytics and advertising through available cookie controls, browser settings, device settings, Google advertising settings, provider opt-out tools, or other legally required mechanisms.

• Google Analytics Opt-Out Browser Add-on: https://tools.google.com/dlpage/gaoptout
• Microsoft Clarity privacy information and controls: https://learn.microsoft.com/clarity/faq
• Google advertising settings: https://adssettings.google.com
• Browser settings to view, remove, or block cookies; and
• Mobile-device settings to limit ad personalization, analytics, tracking, or push notifications where those controls are available.

Disabling cookies or other technologies may affect authentication, plan-limit enforcement, availability, functionality, personalization, or reliability of the Services.

Information We Collect From Other Sources

We may obtain information from other sources and combine it with information we collect through the Services. In particular, we may receive information from Google or Apple when you sign in, from Stripe when you purchase or manage a subscription, and from analytics, security, advertising, cloud, and service providers that support the Services.

If you create or access your account through Google or Apple, we may receive information such as your name, email address, authentication identifier, and other limited account information in accordance with the provider's authorization procedures and your settings.

Upturn does not represent that it routinely obtains consumer information from credit bureaus, mailing-list providers, social-media friend lists, or identity-verification services. If Upturn later implements such a service, it will update this Privacy Policy or provide any additional notice required by law.

Watchlists, Robo-Portfolios, and Investment-Related Activity

Upturn may collect information concerning securities, ETFs, investment themes, and companies that you view, search for, add to a watchlist, or include in a simulated Robo-Portfolio. This information may reveal or suggest your investment interests.

We use this information to provide requested features, save account preferences, deliver relevant alerts, support AI-assisted search, personalize the Services, and improve product functionality.

Unless Upturn expressly identifies and separately offers a brokerage, custody, or account-integration service, Upturn does not have access to your complete brokerage holdings, brokerage credentials, actual securities transactions, or externally maintained account balances. If Upturn later offers such an integration, it will provide additional disclosures describing the account information received and how it is used.

AI-Assisted Search and AI-Generated Features

Upturn uses artificial intelligence to help generate company descriptions, company details, SWOT analyses, similar-company information, investor-fit assessments, risk profiles, and other supporting investment information. These features provide informational context and do not, by themselves, generate or change Upturn's proprietary BUY, SELL, or PASS advisory outputs unless expressly disclosed.

When you use an AI-assisted search feature, such as searching for stocks that match a theme, characteristic, or investment idea, Upturn may process the search query and related information needed to return relevant results. Upturn may transmit the query, relevant company or security information, and limited technical or contextual information to Google Gemini or another AI, search, grounding, cloud-hosting, or data-processing provider.

These providers may process submitted information under their applicable contractual terms, privacy policies, product settings, and legal obligations. Upturn does not make a blanket representation that every third-party AI provider is prohibited from using submitted search queries for service improvement or model training because the provider's treatment of information depends on the specific service, configuration, terms, and privacy policy applicable to the request.

Do not include Social Security numbers, brokerage credentials, complete financial-account numbers, payment-card information, health information, confidential information, material nonpublic information, or other highly sensitive information in search queries or AI-related submissions.

Use of Information

We may use information about you for various purposes, including to:

• Provide, maintain, secure, and improve our Services;
• Create and authenticate accounts through Google or Apple;
• Provide investment advisories, company information, AI-generated analysis, search, watchlist, notification, and simulated Robo-Portfolio features;
• Process and administer trials, subscriptions, Stripe transactions, cancellations, and account deletion;
• Send confirmations, invoices, technical notices, updates, security alerts, regulatory disclosures, and support or administrative messages;
• Respond to comments, questions, privacy requests, and customer-support inquiries;
• Communicate about products, services, offers, promotions, and information we believe may be of interest, where permitted;
• Monitor and analyze trends, usage, engagement, and activities in connection with our Services;
• Personalize and improve the Services and provide content, features, or advertisements consistent with user settings and applicable law;
• Detect, investigate, and prevent fraudulent transactions, misuse, security incidents, and other illegal activities;
• Comply with investment-adviser recordkeeping, tax, accounting, audit, regulatory, and legal obligations;
• Establish, exercise, or defend legal claims;
• Evaluate or complete a merger, financing, acquisition, restructuring, or other corporate transaction;
• Link or combine information obtained from service providers to operate and improve the Services; and
• Carry out another purpose disclosed when information is collected.

Sharing of Information

We may disclose information about you as follows or as otherwise described in this Privacy Policy:

• With vendors, consultants, and service providers that need access to information to perform work for Upturn, including providers of hosting, Google or Apple authentication, Stripe payment processing, analytics, crash reporting, advertising delivery, AI-assisted search, email delivery, customer support, and security services;
• With Google Gemini or another AI, search, grounding, or cloud provider when reasonably necessary to process a search or AI-supported company-information feature;
• In response to a request for information when disclosure is required or permitted by applicable law, regulation, legal process, or regulatory obligation;
• When we reasonably believe your actions are inconsistent with our Terms of Use or policies, or when disclosure is reasonably necessary to protect the rights, property, security, or safety of Upturn, our users, or others;
• With attorneys, accountants, auditors, compliance consultants, and other professional advisers assisting Upturn;
• In connection with, or during negotiations concerning, a merger, financing, reorganization, sale of assets, acquisition, or similar corporate transaction;
• Between Upturn and its current or future parents, affiliates, subsidiaries, or companies under common control, subject to applicable law; and
• With your consent or at your direction.

We may also use or disclose aggregated or de-identified information that cannot reasonably be used to identify an individual. We do not sell personal information for money.

Advertising and Analytics Services Provided by Others

We allow third parties to provide analytics services and Google AdSense to serve advertisements on our behalf. These entities may use cookies, web beacons, software development kits, pixels, device identifiers, and similar technologies to collect information about your use of the Services and, depending on the provider and configuration, other websites and applications. Information may include your IP address, browser type, mobile-network information, pages viewed, time spent on pages or in applications, links selected, device identifiers, and conversion information.

This information may be used by Upturn and the applicable providers to analyze and track data, determine the popularity of content, measure advertising, understand online activity, prevent fraud, and deliver advertisements under the provider's settings, consent choices, and privacy policies.

Upturn does not independently operate a targeted-advertising program or create its own advertising audience profiles from user-created investment activity. However, Google AdSense or its advertising partners may personalize advertisements depending on Google's service configuration, the user's Google and device settings, consent choices, browser settings, and applicable law. Certain advertising disclosures may be characterized as "sharing" or targeted advertising under some state privacy laws even when personal information is not sold for money.

Upturn may display banner or click-through advertising on its website or application and may receive compensation for such advertising. Certain advertisements may concern financial products. Upturn does not endorse, verify, or guarantee any financial product or other product or service promoted by an advertiser and generally does not select every company that advertises through Google AdSense.

Where applicable law requires consent, an opt-out mechanism, or recognition of a supported privacy-preference signal, Upturn will make the legally required choice available. You may also manage available choices through cookie controls, browser settings, device settings, Google advertising settings, or other provider tools.

Security

Upturn takes reasonable administrative, technical, and organizational measures designed to help protect information about you from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction.

No website, application, cloud service, or method of electronic storage is completely secure. Upturn cannot guarantee that unauthorized parties will never defeat applicable safeguards. If Upturn determines that a security incident requires notification under applicable law, Upturn will notify affected individuals, regulators, or other parties as required.

Transfer of Information to the U.S. and Other Countries

Upturn is based in the United States, and information may be processed, transferred, and stored in the United States and other countries where Upturn or its service providers operate. Privacy laws in those countries may differ from the laws applicable where you reside.

Where applicable law requires a lawful transfer mechanism, additional safeguards, or another authorized basis for an international transfer, Upturn will use the mechanism or safeguards required under the circumstances.

Data Retention and Compliance Records

We retain information for as long as reasonably necessary to provide the Services, maintain security, administer subscriptions, satisfy legal and regulatory requirements, prevent fraud, resolve disputes, and enforce agreements. Retention periods depend on the type of information, why it was collected, applicable legal obligations, and whether it remains reasonably necessary for an authorized business purpose.

Information that may be retained after subscription cancellation or account deletion, when required or permitted by law, includes:

• Account-identification information reasonably necessary to maintain required records;
• Advisory communications, advisory-client records, and investment-adviser books and records;
• Subscription records, Stripe transaction identifiers, invoices, payment confirmations, refunds, and billing history;
• Records showing acceptance of the Terms of Use, privacy notices, disclosure acknowledgements, and account-consent events;
• Tax, accounting, audit, regulatory, legal-hold, and dispute-resolution records;
• Security logs and fraud-prevention records reasonably necessary to investigate, prevent, or document incidents; and
• Search queries, AI-related records, analytics data, or technical information when retention is reasonably necessary for compliance, security, troubleshooting, service improvement, or applicable recordkeeping obligations.

When information must be retained after account deletion, Upturn will restrict its use to the lawful purposes supporting retention and maintain it according to applicable security and recordkeeping requirements. Stripe, Google, Apple, analytics providers, AI providers, advertising providers, and other independent third parties may separately retain information under their own legal obligations, privacy policies, settings, and applicable terms.

Your Choices

Account Information

You may update or correct certain account information by using available website or mobile-application settings or by emailing info@upturn.io. You may request account deletion through available account-management features or by emailing info@upturn.io. Upturn may take reasonable steps to verify your identity before completing a request.

Subscription Cancellation

Cancelling a subscription stops future renewal but does not delete your Upturn account or immediately terminate paid access. After cancellation, you will continue to have access to paid subscription features, watchlists, simulated Robo-Portfolios, and other available account information until the end of the subscription period for which you have already paid.

After the paid subscription period ends, your account may move to a free plan. Account information, watchlists, and simulated Robo-Portfolios may remain associated with your account, although access or functionality may be limited under the free plan or other applicable product restrictions. Subscription cancellation does not, by itself, delete account data.

Account Deletion

When an account-deletion request is processed, Upturn will terminate account access, cancel any active subscription processed through Stripe to prevent future renewals or charges, and delete or de-identify personal information and product data that Upturn is not required or permitted to retain.

Information removed or de-identified may include watchlists, saved securities, simulated Robo-Portfolios, portfolio configurations, saved searches, investment themes, preferences, notification settings, eligible search history, and other user-created account information.

Account deletion may immediately end access to paid features, including access that would otherwise have continued through the end of the paid subscription period. Account deletion does not automatically entitle a user to a refund, except where required by applicable law or expressly provided by Upturn.

Deleting the Upturn mobile application from a device does not delete an Upturn account or cancel a subscription. You must use Upturn's account-deletion process or contact info@upturn.io. Upturn may retain information required or permitted for investment-adviser compliance, tax, accounting, security, fraud prevention, dispute resolution, and other lawful purposes, as described in the Data Retention and Compliance Records section.

Privacy Rights

Depending on where you reside, the nature of your relationship with Upturn, and applicable exceptions, you may have the right to request access, correction, deletion, or portability of certain personal information; receive information about collection, use, disclosure, or retention; withdraw consent where processing depends on consent; exercise available choices concerning targeted advertising or sharing; or appeal the denial of a privacy request where applicable law provides that right.

To submit a privacy request, email info@upturn.io. Upturn may verify your identity and request information reasonably necessary to authenticate the request. An authorized agent may submit a request where permitted by law, subject to verification of identity and authority. Upturn will respond within the period required by applicable law and will not unlawfully discriminate against a person for exercising an available privacy right.

Cookies Policy

Upturn.io uses cookies and similar technologies to operate the website, provide Services, analyze usage, display advertising, enforce service limits, and enhance user experience. Cookies are small text files stored on your device when you visit a website. Most web browsers accept cookies by default. You may usually configure a browser to remove or reject cookies, but doing so may affect the availability and functionality of the Services.

Types of Cookies We Use

Strictly Necessary Cookies

These cookies and similar technologies are essential to website operation. They support authentication, account access, security protections, fraud prevention, system stability, session management, and core functionality.

Upturn.io may also use these technologies to enforce service-usage limits associated with free-tier or subscription accounts, such as limiting the number of detailed stock or ETF pages accessed within a specified period. Strictly necessary technologies cannot be disabled through optional cookie settings.

Performance and Analytics Cookies

Performance and analytics technologies help us understand how visitors interact with the Services so we can improve performance, usability, and reliability. They may collect website traffic, page usage, feature interactions, error messages, crash information, engagement metrics, approximate location, and technical performance information.

Some analytics information may be aggregated or de-identified. Other technical identifiers may still constitute personal information under applicable law even when they do not directly identify a user by name.

Functional Cookies

Functional technologies enable enhanced features and personalization, such as remembering preferences, account settings, and selected options. Disabling them may reduce functionality or personalization.

Advertising Cookies

Google AdSense and its advertising partners may use cookies or similar technologies to display and measure advertisements, limit repetitive advertisements, prevent fraud, and, depending on settings and consent choices, personalize advertising. Upturn does not use Microsoft Advertising.

Managing Cookies

Users may manage available cookie choices through the cookie consent tool on Upturn.io, browser settings, device settings, Google advertising settings, and other provider controls. Most browsers permit users to view stored cookies, delete cookies, block cookies from specified websites, or block all cookies. Disabling certain cookies may affect authentication, security, plan-limit enforcement, or other website functionality.

Promotional Communications

You may opt out of receiving promotional emails from Upturn by following the instructions in those emails or by emailing info@upturn.io. If you opt out, Upturn may still send non-promotional communications concerning your account, subscription, payments, security, investment-adviser disclosures, regulatory matters, or requested Services.

Mobile Push Notifications and Alerts

With your permission, we may send promotional and non-promotional push notifications or alerts to your mobile device concerning investment advisories, watchlists, portfolios, account activity, product updates, or promotions. You may deactivate these messages through available application preferences or your mobile-device settings. Notification availability may depend on your subscription plan and device permissions.

Financial Privacy and Regulation S-P

As an SEC-registered investment adviser, Upturn maintains policies and procedures designed to protect customer information and respond to unauthorized access or use, consistent with applicable financial-privacy, safeguards, and incident-response requirements.

Depending on the circumstances, those procedures may address incident identification and assessment, containment, recovery, service-provider oversight, documentation, and notification to affected individuals or regulatory authorities. This Privacy Policy does not replace any separate customer financial privacy notice Upturn is required to provide under Regulation S-P, the Gramm-Leach-Bliley Act, or other applicable law.

Children and Account Eligibility

The Services are not directed to children under 13, and Upturn does not knowingly collect personal information from children under 13. Individuals must be at least 18 years old and legally capable of entering into a binding agreement to create an Upturn advisory account unless Upturn expressly offers a different service permitted by law.

If Upturn learns that it collected a child's personal information in violation of applicable law, it will take reasonable steps to delete the information or otherwise address the issue as required.

Contact Us

If you have questions about this Privacy Policy, want to submit a privacy request, or want to request account deletion, contact Upturn Corporation at info@upturn.io.