Our Policy

This privacy policy (“Privacy Policy”) describes the data collection and handling practices that Upwave, Inc. (“Upwave”) follows for Personal Data (described below) about individuals (“respondent”) who engage with a survey across the websites, mobile applications or other services run by a network of publishers powered by the Upwave “Network”). We collect survey responses and other information from respondents that interact with the Network as described in this Privacy Policy on behalf of our customers (“Customers”).

Information We Collect

When you respond to surveys hosted by the Network, we may collect information from you (“Response Data”), as further described below:

Survey Responses

When you engage with a survey on the Network, you are granting Upwave permission to transfer and store your survey responses. These responses may be provided and/or sold to 3rd parties, such as the Upwave’s Customers.

Survey Response Metadata

You also grant Company permission to transfer and store the “metadata” of your survey, including but not limited to: your operating system, your web browser, the time you completed each question of the survey, the amount of time it took you to complete each question of the survey, and the geographic location from which you engaged with the survey. All of the Survey Response Metadata, with the exception of your IP address (covered below), may be provided and/or sold to 3rd parties, such as the Company’s customers.

Personal Data

We do not collect any Personally Identifiable Information from you. Your IP address is used to determine approximate geographic location and to ensure survey accuracy (avoiding bot attacks and for antifraud purposes). We do not store your IP address in raw form after your session completes, and it is never shared with 3rd parties. We do not run surveys across our Network that ask for any Personally Identifiable Information via a survey question. Company is not responsible for any special handling of Personally Identifiable Information that you submit unsolicited via a “free response” survey question on the Network.

By voluntarily providing us with the Response Data described above, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Response Data, you acknowledge and agree that such Response Data may be transferred from your current location to the offices and servers of Company and the authorized third parties referred to herein located in the United States.

Our Disclosure Of Your Response Data And Other Information

Below are some circumstances in which we may share your Response Data with certain third parties who are not our customers, without further notice to you.

Business Transfers

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Response Data may be part of the transferred assets.

Agents, Consultants, And Related Third Parties

Company, like many businesses, sometimes hires other companies to perform certain business-related functions. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

Business Partners

Company may provide Response Data to our business partners in connection with the use and operation of the Company Services and other aspects of the Company business.


This Privacy Policy does not apply to any information collected by Company other than Response Data collected through the Network. This Privacy Policy does not apply to any unsolicited information you provide to Company through the Network or through any other means (“Unsolicited Information”). This includes, but is not limited to, information posted to any public areas of Company’s website (www.Upwave.com). All Unsolicited Information shall be deemed to be non-confidential and Company shall be free to reproduce, use, disclose, distribute and exploit such Unsolicited Information without limitation or attribution.


Company does not knowingly collect Response Data from children under the age of 13. If you are under the age of 13, please do not engage with any surveys across our Network or provide any other information to Company. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Response Data on the Network. If you have reason to believe that a child under the age of 13 has provided Response Data to Company through the Network, please contact us, and we will endeavor to delete that information from our databases.

Relationships With Other Websites

This Privacy Policy applies only to the Network. This Privacy Policy does not apply to your relationship with the 3rd party websites that comprise our Network. Please contact the 3rd party sites that comprise our Network (i.e, the site in which you engaged with the survey) for information about their privacy policies.

We may receive information about consumers from 3rd party sites to enable targeted surveys on our Network. The collection and use of that data are governed by the privacy policy and legal terms of the data collector and the website using the data; it is not governed by Upwave.


Company takes reasonable steps to protect the Response Data provided to us from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission or form of electronic storage is ever fully secure or error free. Please keep this in mind when disclosing any Response Data to Company.

Changes To Company’s Privacy Policy

The Network and our business may change from time to time. As a result, at times it may be necessary for Company to make changes to this Privacy Policy. Company reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Response Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Network after any changes or revisions to this Privacy Policy will indicate your agreement with the terms of such revised Privacy Policy.

Scope: This Policy applies to Personal Data that is transferred to Upwave in the U.S. from the EU.

Our Services: We provide a platform and tools (“Services”) that allow customers (“Customers”) to, among other things, follow standard industry practices to create consumer surveys. We power a network of publishers, including blogs, online magazines or video sites (“Network”) where consumers (“Survey Respondents”) can take surveys in exchange for access to premium content on the Network (for example, e-books, videos, downloads). We conduct consumer surveys on behalf of our Customers, who write the surveys and determine how the survey responses and any other data about Survey Respondents are used.

Types of Personal Data Collected: Personal Data means any information that can be used to identify an individual that is received from the EU and is recorded in any form.

When Survey Respondents engage with a survey on the Network, we collect certain data about Survey Respondents on behalf of our Customers, including:

  • Survey responses: We collect and store the survey responses provided by Survey Respondents.
  • Demographic Data: We collect demographics about Survey Respondents, such as gender and age range.
  • Usage data: We collect data about how Survey Respondents and Survey Respondents’ device interact with the Network, including but not limited to: Survey Respondents’ operating system, web browser, device type, the time Survey Respondents completed each question of the survey, the amount of time it took Survey Respondents to complete each question of the survey, the IP address and the geographic location from which Survey Respondents engaged with the survey.

We also collect Personal Data that Customers provide to us when they register for an account on our website www.Upwave.com (“Site”). The information we may collect includes Customers’ name, company name, location, email address, phone number, and account password (“Customer Data”).


For Survey Respondents:

In operating the Network, we may use a technology called “cookies.” A cookie is a piece of information that the computers that hosts the Network gives to your browser when you access the Network. Our cookies help provide additional functionality to the Network and help us analyze Network usage more accurately. For instance, the Network may set a cookie on your browser that allows you to bypass engaging with a survey due to your previous completion of a survey. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Network’s features.

For all visitors of our Site:

We use cookies on our Site to improve the functionality and quality of the Site, including to store your preferences and settings, measure web traffic and usage activity to analyze how the Site and the Services are performing, provide interest-based advertising, look for possible fraudulent activity.

Purposes of Data Processing: We process information, including Personal Data, about Survey Respondents that we collect for the purpose of providing the Services to Customers. We use Customer Data for the purpose of creating and maintaining Customers’ account; providing the Services to Customers; responding to and communicating with customers about Customers’ inquiries and requests; notifying Customers about offers, new services or other promotions.


Access To Information; Contacting Company

To keep your Response Data accurate, current, and complete, please contact us as specified below. Please also feel free to contact us if you have any questions about Company’s Privacy Policy or the information practices of the Network.

You may contact us as follows:

Telephone+1 (415) 745–8833
Postal Mail: Upwave, 642 Harrison Street, Suite 300, San Francisco, CA 94107

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To learn about your rights under the California Consumer Privacy Act (CCPA), click here.