Privacy Policy

    Thanks for visiting The privacy policy explains the What, How and Why of the Personally Identifiable Information we collect when you visit the website located at (the “Site”) and includes Personal Information collected via online forms, email, telephone or other means. It also explains the specific ways we use and disclose that information. By using or accessing the Site you are accepting the practices described in this Privacy Policy and you are consenting to our processing of your information as described below.


    Getting a few definitions out of the way should help you better understand this policy. When we say “we”, “us”, “our” or Upswing, we’re referring to Bunt Studio SRL, a Romanian company.

    Personal Information refers to any information which may identify an individual personally, such as the first and last name, home address, billing address, or other physical address, email address, telephone number, etc.

    Visitor refers to anyone accessing the Upswing Site.

    Information Collected

    Upswing collects information on your usage of our Site through 3rd party services, such as pages visited, links clicked, non-sensitive text entered and mouse movements, as well as information more commonly collected, such as the referring URL, browser, operating system, cookie information and Internet Service Provider (“Usage Data”). Upswing’s purpose in collecting Usage Information is to better understand how Upswing’s Visitors use the Site. Upswing does not use the Usage Information to identify its Visitors and does not disclose the Usage Information other than under the circumstances described in this Privacy Policy.

    As a Visitor, Upswing collects potentially personally identifying information like Internet Protocol (“IP”) addresses (“Potential PII”). You may also choose to interact with the Site and that results in you providing Personal Information to Upswing, such as giving us your name and email address, when signing up for a free report at

    We only collect Personal Information that is reasonable or necessary to accomplish the purpose of your interaction with Upswing as a Visitor. You may choose not to provide this information, but you need to understand that, as a result, you may not be able to engage in certain activities on the Site. Any Personal Information provided by you as a Visitor to the Site will be used only as described in this Privacy Policy.

    Location of Your Information

    Any servers or services that contain Personally Identifiable Information are located within the European Union. At times, Upswing may process or transfer some of your personal data (such as name and email address) to our affiliate companies outside of the EU. Any such transfer will be made in accordance with the applicable laws on data protection and this Privacy Policy. By submitting any personal information or by using the Website, you consent to such transfer and processing of your personal data outside the EU.

    Use of Your Personal Information

    We will never sell your data to third parties. However, in the course of business, we may hire third party individuals and organizations to help us make the Upswing Services better. These third parties include our web host provider, other SaaS providers, such as an email hosting service, payment processors or outside contractors hired to perform maintenance or assist us in securing our website. We may also hire third parties to operate, maintain, repair or otherwise improve or preserve our website or its underlying files or systems.

    Upswing may disclose Personal Information and Potential PII only to those of its employees and third party organizations that (1) need to know such information, in order to process it on Upswing’s behalf or to provide services as described above and (2) have agreed not to disclose it to any other parties without Upswing’s consent. Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using the Site and/or the Service, you consent to the transfer of information to such individuals and organizations in order to accomplish these purposes.

    Before using or sharing your information with non-agent third parties in ways not discussed here or previously authorized by you, we will provide you with Notice and an opportunity to control the further use or disclosure of your personal information.

    If you have downloaded the Industry Report and have supplied your email address, Upswing may occasionally send you an email to tell you about new features, solicit your feedback or just keep you up to date with what’s going on with Upswing. If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it, in order to help us clarify or respond to your request or to help us support other users. Upswing takes all reasonably necessary measures to protect against the unauthorized access, use, alteration or destruction of Personal Information and Potential PII.

    In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. If we or, substantially, all of our assets were to be acquired or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur and that any acquirer of us or of our assets may continue to use your Personal Information and Potential PII as set forth in this policy. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your Personal Information and Potential PII, as well as any choices you may have regarding your Personal Information and Potential PII.

    Rights of the subject person

    Within the context of the processing of your personal data, you have the following rights:

    1.  The right of access to the processed personal data: you have the right to obtain a confirmation whether or not your personal data are being processed, and, if affirmative, to have access to the type of personal data and to the conditions of processing, by addressing a request in this respect to the data controller;
    2.  The right to request the rectification or erasure of personal data: you have the possibility to request,  by sending a request in this respect to the data controller, the rectification of inaccurate personal data, the supplementation of incomplete data or the erasure of your personal data in case (i) the data are no longer needed for their original purpose (and no new lawful purpose exists), (ii) the lawful basis for the processing is the data subject’s consent, the data subject withdraws that consent, and no other lawful ground exists, (iii) the data subject exercises the right to object and the controller has no overriding grounds for continuing the processing, (iv) the data have been processed unlawfully, (v) erasure is necessary for compliance with EU law or Romanian law, or (vi) the data were collected in connection with the informational society services offered to children (if the case), where specific requirements regarding consent are applicable;
    3.  The right to request the restriction of processing: you have the right to obtain the restriction of processing in cases where: (i) you consider that the processed personal data are inaccurate, for a period enabling the controller to verify the accuracy of the personal data; (ii) the processing is unlawful, however you don’t want us to erase your personal data, but to restrict the use of data; (iii) in case the data controller no longer needs your personal data for the above-mentioned purposes, but you are requiring the data for establishing, exercising or defending a legal claim or (iv) you have objected to processing pending the verification whether the legitimate grounds of the data controller override those of the data subject;
    4.  The right to withdraw your consent for processing, when the processing is based on consent, without affecting the lawfulness of processing undertaken until that moment;
    5.  The right to object to the data processing on grounds relating to your particular situation, when the processing is based on legitimate interest and to object at any moment to the data processing for direct marketing purposes, including profiling;
    6.   The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the data subject or similarly affects the data subject in a significant manner;
    7.  The right to data portability, meaning the right to receive your personal data, which you provided to the data controller in a structured, commonly used and machine-readable format and the right to transfer those data to another controller, if the processing is based on your consent or the performance of a contract and is undertaken by using automatic means;
    8.  The right to file a complaint with the Data Protection Authority (ANSPDCP) and the right to address to the competent courts of law.

    The exercising of the above rights may be performed at any time. Also, in case you wish to withdraw your consent given for direct marketing purposes you have the possibility to use the “unsubscribe” option provided to you in every marketing communication.

    Right to Access, Edit and Remove Your Information

    You have the right to access personal information we hold on you. Whenever you use our Site, we strive to make sure that the Personal Information is correct. If that information is wrong, we give you ways to update it or to delete it by contacting us at  – unless we have to keep that information for legitimate business or legal purposes. When updating your Personal Information, we may ask you to verify your identity before making any changes. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup systems). Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort.

    To request the removal of your Personal Information from our Site, blog or social media, contact us at In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.

    Security Measures

    We take measures to enhance the security of our Site. These measures include using SSL Certificates. It is important for you to protect against unauthorized access to your password and to your computer. No security measures are perfect and we cannot promise that the information about you will remain secure in all circumstances.

    Do Not Track Signal

    We treat the data of everyone who comes to our site in accordance with this Privacy Policy, whatever their Do Not Track setting is.


    Our site is intended for a general audience and we do not knowingly collect Personal Information from anyone under the age of 13.

    How Upswing Collects Information

    Cookies are small data files placed on your computer by the websites you visit and the emails you read and can be used to help recognize you when you return to a website or when you visit other sites. We or our third party service providers may use cookies to, among other things, measure activity, personalize your experience, remember your viewing preferences or track your status or progress when accessing our site. For some of these purposes, our cookies may be tied to Personal Information and/or Potential PII. These cookies do not track the same user across unrelated domains and, as described above, attempts to infer identity across domains are strictly prohibited.

    Upswing does not and will not ever attempt to identify the same person across disparate, unrelated domains.

    Blocking Cookies

    If you choose to do so, you can set your browser to reject the cookies or you can manually delete individual or all of the cookies on your computer, by following your browser’s instructions. Additionally, we installed Cookiebot, to give you more transparency and an easier way of controlling which cookies you want to block. Note that turning off cookies may disable functions of our website.

    Useful information about cookies can be found at:


    We may amend this Privacy Policy from time to time. When there are changes to this Privacy Policy, we will update this page. The date on the bottom will always indicate when we last made changes. If you are a visitor to this Site and disagree with the Privacy Policy, you should leave the Site and/or cancel your agreement with Upswing.

    What If I Have Questions or Concerns?

    If you have any questions or concerns regarding privacy when using Upswing, please send us a detailed message to

    We will make every effort to address your concerns.

    Effective Date

    This Privacy Policy became effective on: May 25, 2018.