Upsello

Privacy Policy

Published and Updated: March 13, 2026

Introduction & Upsello's Privacy Commitment

This Privacy Policy statement is formulated by Zhongju (Fujian) Intelligent Technology Co., Ltd. (hereinafter referred to as "Upsello"). Since our inception, Upsello has been deeply committed to protecting the privacy of our customers and users, even before privacy concerns attracted the heightened attention and legal safeguards they receive today. We only collect the minimum amount of necessary information required to operate our business or complete the specific transaction at hand. We inform customers about what information we gather and enable them to opt out of specific processing activities. Most importantly, our utmost commitment is that we never insert third-party advertisements into our products to monetize user data—never have, never will—even within our free tier offerings. This approach eliminates the fundamental conflict of interest between harvesting customer data and maximizing advertising revenue, thereby preventing inevitable compromises on user privacy. The purpose of this Privacy Policy is to clearly explain what information we collect, how we use it, and how we will not use it. Although this document is comprehensive in covering potential scenarios, we strive to keep the language as concise, straightforward, and transparent as possible.

Scope of this Privacy Policy

This Privacy Policy applies to all Upsello websites linking to this policy, as well as the products, services, and mobile applications provided by Upsello through these websites. It also covers applications published by Upsello on our online marketplace or third-party app stores, Software Development Kits (SDKs) provided for third-party platforms, and Application Programming Interfaces (APIs). This policy does not apply to external websites, products, or services governed by separate privacy policies. This Privacy Policy is structured into three parts: • Part I – Information Upsello Collects and Controls • Part II – Information Upsello Processes on Your Behalf • Part III – General Provisions

Part I: Overview of Information Collected and Controlled by Upsello

This section addresses how Upsello collects and uses information regarding website visitors, prospective customers, users of Upsello products and services, and individuals who communicate with Upsello via forms or email addresses posted on or linked to our websites. We only collect information when we have a lawful basis and legitimate purpose to do so. Upsello obtains information through three primary channels: 1. Information you provide directly; 2. Information automatically collected by Upsello; 3. Information obtained from third parties. Below, we describe these scenarios and the specific types of information collected under each.

Information You Provide Directly

• Account Registration: When you register for an Upsello account to access one or more of our services, we request details such as your name, contact phone number, email address, company name, and country to complete account creation. You will also create a unique username and password. You may optionally provide additional details, such as your profile photograph, time zone, and language preference. You may also configure security questions and answers, which are strictly utilized only during password recovery. • Event Signups and Form Submissions: We record information submitted when you: (i) register for online webinars or offline seminars, (ii) subscribe to our newsletters or mailing lists, (iii) submit forms to download whitepapers, product documentation, or materials, (iv) participate in surveys or contests, or (v) request customer support, quotations, or general inquiries. • Payment Processing: When purchasing products or services from us, we request your name, contact details, and payment account information. For credit card payments, we store the cardholder's name and billing address, card expiration date, and the last four digits of the card number. We do not store full credit card numbers. To facilitate future transactions with your consent, encrypted payment tokens may be securely retained within our PCI-compliant payment gateway service providers. • Testimonials: When you authorize us to publish testimonials regarding our products and services, we may include your name and title alongside the testimonial. You can request modification or removal of your testimonial at any time by contacting us at [email protected]. • Interactions with Upsello: We may record, analyze, and retain records of your interactions with our team, including emails, telephone calls, and live chat sessions with our sales and technical support personnel, to enhance customer experience and service quality. • Mobile Application Permissions: When using Upsello mobile applications, you may be prompted to grant permissions such as microphone access (for voice recordings and voice input), storage read/write access (to save recorded audio or access photos, media, and files locally), and media access to provide a comprehensive mobile experience.

Information Automatically Collected by Upsello

• Browser, Device, and Server Data: When you access our websites, we automatically collect information transmitted by your web browser, mobile device, and server requests, including IP address, browser type, language preferences, referring URLs, access timestamps, operating system, Android ID, hardware manufacturer, and network carriers. This data is recorded in log files to evaluate visitor demographics and system performance. • First-Party Cookies and Tracking Technologies: We use session and persistent cookies to identify authenticated users and improve browsing experience. We embed unique product identifiers in downloadable applications to track usage. We also utilize tags, scripts, and local storage objects (such as HTML5 LSOs) to analyze navigation patterns, assess email campaign efficacy, and evaluate feature adoption. Upsello relies solely on first-party cookies and does not deploy third-party advertising tracking technologies on our marketing pages. • Application Logs and Usage Analytics: We collect diagnostic data and telemetry through application logs and proprietary analytics tools to evaluate how our products and services are utilized. Metrics include click events, page scroll depth, features accessed, session frequency, error logs, resource consumption, and device configurations.

Information Obtained from Third Parties & SDK Safeguards

• Federated Authentication Logins: You may register or sign in to Upsello services using federated identity providers (such as WeChat, QQ, Weibo, or Baidu). These providers authenticate your identity and share authorized profile details with us, such as your verified name and email address. • Referral Programs: If someone refers our services to you via an official referral program, they may provide your contact information. You may request removal of your contact details from our database at any time by writing to [email protected]. • Channel Partners and Resellers: If you interact with our authorized resellers or express interest in our solutions through partners, they may share your name, corporate email, and organization details with Upsello. Event co-hosts and rating/review platforms may also provide feedback and contact information. • Public and Social Media Sources: When you submit public reviews, participate in forum discussions, or interact with our social channels, we may gather publicly visible feedback to improve our product features. • Third-Party SDK & API Auditing: To ensure stable client performance and deliver extended features, our applications may embed partner SDKs or API integrations. We enforce rigorous security assessments on all integrated SDKs and require partners to uphold confidentiality and data protection standards matching this policy.

Purposes for Processing Personal Information

We process collected information strictly for the following purposes: 1. Communicating regarding purchased services, technical alerts, security advisories, policy updates, and critical operational notices; 2. Processing device identifiers (such as Android ID and storage access) solely to bind devices, ensure account authentication security, and maintain audit log integrity; 3. Provisioning, maintaining, and supporting user accounts, backup infrastructure, and collaborative workspace features; 4. Monitoring system stability, troubleshooting operational defects, and optimizing product workflows; 5. Delivering responsive customer care and assessing customer satisfaction; 6. Detecting, preventing, and mitigating fraudulent transactions, unauthorized access, spam distributions, and security threats; 7. Conducting aggregated, anonymized usage research to refine feature offerings (without serving third-party behavioral advertisements); 8. Analyzing system navigation trends to enhance website information architecture; 9. Evaluating the performance of our marketing initiatives and delivering pertinent service announcements.

Legal Bases for Processing & Right to Withdraw Consent

• Lawful Grounds: In accordance with the Personal Information Protection Law of the PRC (PIPL) and applicable international standards, our processing relies on: (i) performance of contracts with you, (ii) compliance with statutory obligations, (iii) protection of vital interests and public health emergencies, (iv) legitimate operational requirements, and (v) your explicit prior consent where applicable. • Withdrawal of Consent: Where processing relies on your consent, you maintain the right to revoke that consent at any time. Revocation will not impact the lawfulness of processing carried out prior to withdrawal.

Your Choices Regarding Information Processing

• Opting Out of Non-Essential Communications: You may unsubscribe from newsletters, marketing bulletins, and promotional announcements by utilizing the "Unsubscribe" link located in the footer of such emails. Essential administrative notices (password resets, billing invoices, security incident alerts) cannot be opted out of while maintaining an active account. • Cookie Preferences: You may disable cookies through your browser settings. Please note that disabling essential session cookies may impair the functionality of authenticated portals. • Optional Information: You are not obligated to submit optional profile attributes (such as photographs or social handles) and may remove or update them at your discretion.

Parties with Whom We Share Information

Upsello does not sell personal information to any third party. Information described in Part I is accessible strictly on a need-to-know basis to: • Affiliated Entities and Personnel: Authorized employees and contractors bound by strict confidentiality covenants; • Vetted Third-Party Service Providers: Infrastructure hosts, payment gateways, analytics providers, and email delivery vendors operating under rigorous contractual data protection agreements; • Authorized Channel Partners: Regional distribution partners solely to assist in localized onboarding when requested; • Legal and Regulatory Disclosures: Government authorities or judicial bodies in compliance with binding statutory mandates or legal processes, as detailed in Part III.

Your Rights as a Data Subject

Regardless of your jurisdiction, Upsello accords you comprehensive data subject rights: • Right to Withdraw Consent: Revoke previously granted processing authorizations at any time; • Right to Service Availability: We will not deny services or degrade features if you decline non-essential processing consents; • Right of Access: Request disclosure of the categories, sources, processing purposes, retention periods, and recipients of your personal data; • Right to Rectification: Correct inaccurate or incomplete personal records; • Right to Erasure: Demand deletion of personal information when it is no longer necessary for original collection purposes or upon account termination; • Right to Restrict Processing: Request limitations on specific data processing activities under statutory conditions; • Right to Data Portability: Receive your personal information in a structured, commonly used, and machine-readable format; • Right to Object: Challenge processing conducted for direct marketing or specific legitimate interest grounds; • Right to Lodge Complaints: Submit grievances to competent supervisory authorities if you believe our data handling infringes statutory rights; • Rights Regarding Deceased Individuals' Data: Close relatives may exercise rights of access, copying, correction, and deletion regarding a deceased user's personal information, subject to applicable law and any contrary instructions left by the deceased; • Protection Against Automated Discrimination: We refrain from applying discriminatory transactional pricing or service terms based solely on automated profiling.

Data Retention Periods

We retain personal data strictly for as long as necessary to fulfill the purposes articulated in this policy. Certain data may be archived for longer intervals where required by tax, accounting, anti-fraud, or legal dispute defense mandates. Once the retention rationale expires, data is securely erased or irreversible anonymized within our active production systems.

Part II: Information Upsello Processes on Your Behalf

• Entrusted Service Data: When using our cloud services or requesting technical support, you may entrust business records, customer details, or employee data to Upsello. In such circumstances, you act as the Data Controller (or primary Entrusted Party), and Upsello acts as the Data Processor (or sub-processor). We store and process this data strictly within the boundaries of our service agreement and your explicit technical instructions. • Mobile Device Integrations: When granted permission, mobile apps may interface with camera modules, contacts, local photo galleries, or geolocation sensors to deliver specific features (such as scanning or location tagging). Location information shared with mapping APIs is processed strictly for rendering coordinates and is never retained for behavioral profiling. You may revoke these device permissions at any time in your operating system settings.

Ownership, Control, and Utilization of Service Data

• Customer Ownership: All service data submitted into Upsello applications remains your exclusive property. You retain complete authority to: (i) query and view your service data, (ii) share data via supported external integrations, and (iii) request full export or permanent purge of your records. • Processing Scope: We process service data exclusively to execute technical workflows directed by you (e.g., generating billing records or dispatching campaign notifications to designated contact lists). • Push Notifications: When push notifications are enabled, notices are relayed via platform gateways (such as Apple APNs, Google FCM, WeChat notifications, or SMS gateways). Preferences can be toggled in your client settings.

Sharing, Archival Cycles, and Data Subject Inquiries for Service Data

• Access Boundaries: Access to service data by Upsello engineering staff is restricted to exceptional troubleshooting, spam-detection verification, or OCR quality validation under monitored audit logging. • Retention and Deletion Lifecycles: Service data is maintained during your active subscription. Upon account closure, active database entries are purged during the subsequent scheduled maintenance cycle (conducted every 6 months). Residual disaster recovery backups are permanently overwritten within 3 months thereafter. • Data Subject Requests: If an individual whose personal data is managed by your organization contacts Upsello directly to exercise their rights, we will redirect them to contact your organization and provide technical assistance to fulfill valid requests.

Part III: Children's Privacy and Data Security Framework

• Children's Privacy: Upsello products and platforms are not marketed to or intended for individuals under 14 years of age. We do not knowingly harvest personal information from children under 14. If we discover inadvertent receipt of such data without verified parental consent, we will promptly delete it. If you suspect an unauthorized minor submission, notify us at [email protected]. Organizations utilizing Upsello tools to handle minor data assume full responsibility for statutory compliance. • Information Security Measures: Upsello deploys comprehensive administrative, technical, and physical safeguards—including role-based access control, encryption in transit (TLS) and at rest, vulnerability management, and perimeter firewalls—to protect data against unauthorized access, loss, or alteration. Inquiries may be directed to [email protected].

Data Protection Officer (DPO) & Contact Information

We have designated an official Data Protection Officer to supervise privacy governance and compliance across all Upsello business operations. For privacy-related questions, inquiries, or statutory rights requests, please contact: • Email: [email protected] • Written Postal Address: Attn: Data Protection Officer Room F03, 29th Floor, Huakai Fugui Building, Dongda Road, Gulou District, Fuzhou City, Fujian Province, China

Cross-Border Transfers & Data Processing Addendum (DPA)

• Cross-Border Data Transfers: To support international operations, your personal data and service information may be processed or stored in infrastructure located in the United States, the European Economic Area (EEA), or other jurisdictions where Upsello operates. International transfers adhere to compliant legal mechanisms, such as Standard Contractual Clauses (SCCs) and regulatory frameworks under the PIPL. Inquiries regarding transfer documentation may be directed to [email protected]. • Data Processing Addendum (DPA): To assist enterprise clients in demonstrating statutory regulatory compliance, Upsello provides a standard Data Processing Addendum (DPA). You can request an executable DPA by emailing [email protected].

Automation, Artificial Intelligence, and Do Not Track Signals

• Automation and Machine Learning: Upsello utilizes modern technologies, including regex parsers, template matchers, and machine learning models, to deliver predictive insights and operational automation. In honoring our privacy commitments, service data is processed only to: (i) evaluate anonymized model accuracy, and (ii) build customized organizational models tailored specifically to your enterprise. Core model development is fueled by our own operational training data, internal benchmarks, and licensed resources. • "Do Not Track" (DNT) Browser Signals: Certain web browsers transmit DNT headers to visited sites. Because the technology sector lacks a harmonized standard governing response protocols, our websites do not modify automated data collection practices upon encountering DNT signals.

External Hyperlinks, Public Forums, and Social Widgets

• Third-Party Links: Our websites may contain links to external sites beyond Upsello's operational control. Transmissions to external destinations are governed by their respective privacy disclosures. • Public Blogs and Discussion Boards: Information posted on our public blog comments and community forums is visible to the public and may be indexed. To request removal of your forum submissions, contact [email protected]. • Social Media Widgets: Embedded social icons (such as Twitter or Facebook share buttons) may log your IP address and set operational cookies governed by the issuing networks' respective privacy policies.

Statutory Disclosures, Business Transfers, and Policy Amendments

• Statutory Disclosures & Rights Enforcement: We may preserve or disclose records when required by applicable laws, legal subpoenas, or national security warrants, or when necessary to detect cyber fraud, enforce contractual terms, or protect public safety. • Business Succession: In the event of a merger, acquisition, or asset transfer, the acquiring entity will remain legally bound to fulfill our privacy commitments. Affected users will receive prompt notification via email or prominent website notices. • Policy Audit and Governance: We conduct regular compliance assessments to enforce this policy. Inquiries can be forwarded to [email protected]. • Amendment Notifications: We reserve the right to revise this policy. In the event of material revisions impacting user rights, we will provide at least 30 days' advance notice via primary registered emails. Continued utilization of our services following the effective date signifies acceptance of the amended policy. Minor non-substantive adjustments are published directly on our portal without individual mailings.