Your privacy,
protected.

UpSpiral.Life LLC

Last Revised: 08/12/2026

Applies to users in the United States, Canada, European Union/EEA, and United Kingdom

NOTE: This document contains placeholders marked [IN BRACKETS] that must be completed before publishing. Please have a qualified legal professional review this policy before it is made public.

1. INTRODUCTION

UpSpiral.Life LLC (“Company,” “We,” or “Us”) respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit upspiral.life and upspirallife.net (our “Website”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On this Website.
• In email, text, and other electronic messages between you and this Website.
• Through mobile and desktop applications you download from this Website.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

This policy does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by the Company or any third party.
• Any third party, including through any application or content (including advertising) that may link to or be accessible from the Website.

Please read this policy carefully. If you do not agree with our practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Section 16: Changes to Our Privacy Policy). Your continued use of this Website after we make changes constitutes acceptance of those changes.

2. CHILDREN UNDER THE AGE OF 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 18. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at support@upspiral.life.

3. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We collect several types of information from and about users of our Website, including:

• Identifiers such as name, postal address, email address, and any other identifier by which you may be contacted online or offline (“personal information”).
• Demographic information that does not individually identify you, such as gender or survey responses.
• Commercial information, including records of products or services purchased or considered.
• Internet or electronic network activity, including browsing history on our Website and search queries.
• Geolocation data (approximate location based on IP address).
• Inferences drawn from the above to create a profile about your preferences and interests.
• Information about your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the site, including usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From third parties, such as our Mighty Network app and affiliate business partners.

The information we collect may include:

• Information you provide by filling in forms on our Website, including at registration, subscription, or when requesting services.
• Records and copies of your correspondence, including email addresses, if you contact us.
• Your responses to surveys we may ask you to complete.
• Details of transactions you carry out through our Website and fulfillment of your orders, including financial information where required.
• Your search queries on the Website.

4. AUTOMATIC DATA COLLECTION AND TRACKING TECHNOLOGIES

As you navigate through and interact with our Website, we may use automatic data collection technologies, including:

• Browser Cookies: Small files placed on your device. You may refuse cookies by adjusting browser settings, though some parts of the Website may then be inaccessible.
• Flash Cookies: Local stored objects used to collect information about your preferences and navigation. These are not managed by the same browser settings as browser cookies.
• Web Beacons: Small electronic files embedded in pages or emails that allow us to count users who have visited pages or opened emails and collect related statistics.

We do not collect personal information automatically, but we may associate this information with personal information we collect from other sources.

5. COOKIES AND TRACKING TECHNOLOGIES — YOUR CHOICES

Types of Cookies We Use

• Strictly Necessary Cookies: Required for the Website to function. They cannot be switched off as they are set in response to your actions, such as logging in or filling out forms.
• Performance/Analytics Cookies: Allow us to count visits and traffic sources to measure and improve Website performance. All information collected is aggregated and anonymous.
• Functional Cookies: Enable enhanced functionality and personalization, such as remembering your preferences.
• Targeting/Advertising Cookies: May be set by our advertising partners to build a profile of your interests and show you relevant advertising on other sites.

Cookie Consent

When you first visit our Website, you will be presented with a cookie consent banner giving you the ability to accept or decline non-essential cookies. You may update your preferences at any time by clicking the “Cookie Settings” link in the footer of our Website. Continued browsing without adjusting settings does not constitute consent to non-essential cookies under applicable law.

Do Not Track (DNT) Signals

Some browsers include a “Do Not Track” (DNT) feature. Our Website currently [DOES / DOES NOT] respond to DNT signals. Regardless of your DNT setting, you may control tracking by adjusting your cookie preferences as described above.

Third-Party Cookies

Some content or applications on the Website are served by third parties, including advertisers and analytics providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. We do not control these technologies. If you have questions about an advertisement or targeted content, please contact the responsible provider directly.

For more information about cookies and how to manage them, visit www.allaboutcookies.org.

6. HOW WE USE YOUR INFORMATION

We use information we collect about you, including personal information, to:

• Present our Website and its contents to you.
• Provide you with information, products, or services that you request from us.
• Fulfill any other purpose for which you provide it.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you about changes to our Website or any products or services we offer.
• Personalize your experience on our Website.
• Conduct research, analytics, and improve our services.
• Send marketing and promotional communications where you have consented or where we have a legitimate interest in doing so.
• Comply with applicable legal obligations.
• For any other purpose with your consent.

7. LAWFUL BASIS FOR PROCESSING (EU/EEA AND UK USERS — GDPR)

If you are located in the European Union, European Economic Area, or United Kingdom, we process your personal data only where we have a lawful basis to do so under Article 6 of the GDPR. The lawful bases we rely on include:

• Contractual Necessity: We process your data where it is necessary to perform a contract with you, such as processing a purchase or providing access to our services.
• Legitimate Interests: We process your data where it is in our legitimate business interests to do so, such as improving our Website, preventing fraud, and ensuring network security, provided those interests are not overridden by your rights.
• Legal Obligation: We may process your data where necessary to comply with a legal obligation, such as responding to a court order or regulatory request.
• Consent: Where we rely on your consent (such as for non-essential cookies or marketing communications), you have the right to withdraw consent at any time by contacting us at support@upspiral.life or using the opt-out mechanism provided at the point of collection. Withdrawal of consent does not affect the lawfulness of prior processing.

Where we process special categories of sensitive personal data, we rely on explicit consent or another applicable legal basis under Article 9 of the GDPR.

8. DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated, non-identifying information about our users without restriction.

We may disclose personal information that we collect or you provide:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business, who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. Categories of third-party recipients include: payment processors, email service providers, web hosting and analytics providers, and marketing platforms.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of UpSpiral.Life LLC’s assets.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of UpSpiral.Life LLC, our customers, or others.

9. DATA RETENTION

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, and applicable legal requirements.

As a general guide:

• Account information: Retained for as long as your account is active, and for up to [3 years / INSERT PERIOD] after account closure to comply with legal obligations and resolve disputes.
• Transaction records: Retained for [7 years] to comply with tax and financial reporting obligations.
• Marketing preferences and correspondence: Retained until you opt out or request deletion, plus a reasonable period thereafter to honor your preferences.
• Website usage and analytics data: Retained for [2 years] from the date of collection.

When personal data is no longer needed, we securely delete or anonymize it. If immediate deletion is not possible (e.g., because data is stored in backup archives), we will isolate the data from further processing until deletion is possible.

10. DATA SECURITY

We have implemented appropriate technical and organizational measures designed to protect your personal information from accidental loss, unauthorized access, use, alteration, or disclosure. These measures include:

• Encryption of personal data in transit using SSL/TLS technology.
• Access controls limiting personal data access to employees, contractors, and agents who have a business need to access it.
• Regular review of our information collection, storage, and processing practices.
• Physical, electronic, and procedural safeguards for systems where we store personal data.

While we strive to protect your personal information, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

In the event of a data breach that is likely to result in risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours of becoming aware of the breach, as required under GDPR Article 33. Where required by applicable law, we will also notify affected individuals without undue delay.

11. INTERNATIONAL DATA TRANSFERS

UpSpiral.Life LLC is based in the United States. If you are accessing our Website from the European Union, European Economic Area, United Kingdom, Canada, or other regions with data protection laws that may differ from those in the United States, please be aware that your information may be transferred to, stored, and processed in the United States.

Where we transfer personal data from the EU/EEA or UK to the United States or other countries not deemed to provide an adequate level of data protection, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs): We use European Commission-approved Standard Contractual Clauses with our data processors and third-party partners where required.
• Adequacy Decisions: Where transfers are to countries that have received an adequacy decision from the European Commission, we rely on that decision.

You may request a copy of the safeguards we have in place for international transfers by contacting us at support@upspiral.life.

12. AUTOMATED DECISION-MAKING AND PROFILING

We [DO / DO NOT] use automated decision-making processes, including profiling, that produce legal or similarly significant effects on you. [IF APPLICABLE, ADD: We use automated tools to personalize content and recommendations displayed to you based on your browsing behavior and preferences. This profiling does not produce legal effects but is intended to improve your experience.]

EU/EEA and UK residents have the right not to be subject to a decision based solely on automated processing if it produces legal or similarly significant effects. If you have concerns about any automated processing, please contact us at support@upspiral.life and we will provide further information and, where applicable, arrange for human review.

13. YOUR DATA PROTECTION RIGHTS

Rights for All Users

• Right to Access: You may request a copy of the personal information we hold about you.
• Right to Correction: You may request that we correct any inaccurate or incomplete personal information.
• Right to Deletion: You may request that we delete your personal information, subject to certain legal exceptions. Note: We cannot delete your personal information except by also deleting your user account.

Additional Rights for EU/EEA and UK Residents (GDPR)

• Right to Restrict Processing: Request that we limit the way we use your personal data in certain circumstances.
• Right to Data Portability: Request a copy of your data in a structured, commonly used, machine-readable format, and have it transferred to another controller where technically feasible.
• Right to Object: Object to our processing of your personal data where we rely on legitimate interests as our lawful basis, or where data is used for direct marketing.
• Right to Withdraw Consent: Where processing is based on consent, withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right Regarding Automated Decisions: Not be subject to a decision based solely on automated processing that produces legal or similarly significant effects.
• Right to Lodge a Complaint: Lodge a complaint with your local data protection authority. A list of EU data protection authorities is available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en. UK residents may contact the Information Commissioner’s Office (ICO) at https://ico.org.uk.

To exercise any of these rights, please contact us at support@upspiral.life. We will respond to all legitimate requests within 30 days. In complex cases, we may extend this period by a further two months and will notify you. We will not charge a fee unless your request is manifestly unfounded or excessive.

14. YOUR CALIFORNIA PRIVACY RIGHTS (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) provides you with specific rights regarding your personal information.

Categories of Personal Information Collected in the Past 12 Months

• Identifiers (name, email address, IP address, account username)
• Commercial information (purchase history, products or services obtained)
• Internet or electronic network activity (browsing history on our Website, search queries)
• Geolocation data (approximate location based on IP address)
• Inferences drawn from the above to create a profile about your preferences

Do We Sell or Share Personal Information?

We [DO / DO NOT] sell your personal information. We [DO / DO NOT] share your personal information with third parties for cross-context behavioral advertising purposes. If we do sell or share your information, you have the right to opt out by clicking the “Do Not Sell or Share My Personal Information” link in the footer of our Website or by contacting us at support@upspiral.life.

Your Rights Under CCPA/CPRA

• Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected about you, the sources, purposes for collecting it, and categories of third parties with whom it is shared.
• Right to Delete: Request deletion of personal information we have collected from you, subject to certain exceptions.
• Right to Correct: Request correction of inaccurate personal information.
• Right to Opt Out of Sale/Sharing: Opt out of the sale or sharing of your personal information for cross-context behavioral advertising.
• Right to Limit Use of Sensitive Personal Information: Direct us to limit the use of your sensitive personal information to what is necessary to perform the services you requested.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights. We will not deny goods or services, charge different prices, or provide a different quality of service because you exercised your rights.

How to Submit a Request

To exercise your California privacy rights, please submit a verifiable consumer request by:

• Emailing us at support@upspiral.life
  We will respond within 45 days of receiving a verifiable request. We may extend this period by an additional 45 days when reasonably necessary and will notify you of the extension.

Authorized Agents

You may designate an authorized agent to submit requests on your behalf. We may require written proof of the agent’s authorization and may verify your identity directly.

California’s “Shine the Light” law (Civil Code § 1798.83) also permits California residents to request information about disclosure of personal information to third parties for their direct marketing purposes. To make such a request, contact us at support@upspiral.life.

15. OTHER U.S. STATE PRIVACY RIGHTS

Several U.S. states have enacted privacy laws that provide residents with rights similar to those described in this policy. If you are a resident of Colorado, Virginia, Connecticut, Texas, Oregon, Montana, or another state with applicable privacy legislation, you may have the following rights, subject to certain exceptions:

• Right to Know/Access: Request confirmation of whether we process your personal data and access to that data.
• Right to Correct: Request correction of inaccurate personal data.
• Right to Delete: Request deletion of personal data you have provided or that we have collected about you.
• Right to Data Portability: Obtain a copy of your personal data in a portable, usable format.
• Right to Opt Out: Opt out of the processing of your personal data for purposes of targeted advertising, sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights, please contact us at support@upspiral.life. We will respond within the timeframe required by your state’s applicable law (typically 45–60 days). We will not discriminate against you for exercising these rights.

If we deny your request, you may appeal our decision by contacting us at support@upspiral.life with the subject line “Privacy Rights Appeal.” If you are unsatisfied with our response to your appeal, you may have the right to contact your state’s attorney general.

16. CANADIAN PRIVACY RIGHTS (PIPEDA)

If you are a resident of Canada, your personal information is collected, used, and disclosed in accordance with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws.

Accountability

UpSpiral.Life LLC is responsible for personal information under its control. We have designated a Privacy Officer who is accountable for our compliance with PIPEDA. You may contact our Privacy Officer at: support@upspiral.life.

Consent

We collect, use, and disclose your personal information with your knowledge and consent, except where permitted or required by law. You may withdraw consent at any time, subject to legal and contractual restrictions, by contacting us at support@upspiral.life. Please note that withdrawal of consent may affect our ability to provide certain services to you.

Your Rights Under PIPEDA

• Right to Access: Request access to your personal information and information about how it has been used or disclosed.
• Right to Correction: Request correction of any inaccuracies in your personal information.
• Right to Complain: If you believe we have not complied with PIPEDA, you may file a complaint with the Office of the Privacy Commissioner of Canada at www.priv.gc.ca.

We will respond to access and correction requests within 30 days, as required by PIPEDA.

17. EMAIL COMMUNICATIONS (CAN-SPAM AND CASL)

For All Users

If you have provided us with your email address, we may send you marketing or promotional communications. Every marketing email we send will:

• Clearly identify UpSpiral.Life LLC as the sender.
• Include our physical mailing address: [INSERT COMPANY PHYSICAL MAILING ADDRESS].
• Include a clear and conspicuous unsubscribe mechanism.
• Honor opt-out requests within 10 business days of receipt, as required by the CAN-SPAM Act.

Please note that even if you opt out of marketing emails, we may still send you transactional or administrative emails related to your account or services you have requested.

For Canadian Users (CASL)

We send commercial electronic messages (CEMs) to Canadian residents only with express or implied consent, as required by Canada’s Anti-Spam Legislation (CASL).

• Express Consent: We obtain your express consent where required before sending marketing messages, which includes a clear description of the message content and sender identity.
• Implied Consent: We may rely on implied consent where you have an existing business relationship with us as defined by CASL.

We maintain records of consent and the basis on which we rely to send commercial messages. You may withdraw consent at any time by clicking “unsubscribe” in any commercial email or by contacting us at support@upspiral.life.

18. EU/UK REPRESENTATIVE

As UpSpiral.Life LLC is based in the United States and processes data of individuals in the EU/EEA and UK, we have designated a representative as required by GDPR Article 27 (and UK GDPR where applicable).

Our EU Representative is: Will be updated…

Our UK Representative is: Will be updated…

Please note that these representatives serve as a point of contact only and do not limit your ability to contact UpSpiral.Life LLC directly or to exercise your rights against us.

19. ACCESSING AND CORRECTING YOUR INFORMATION

You may send us an email at support@upspiral.life to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Use.

20. CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page with a notice that the policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account. The date the privacy policy was last revised is identified at the top of this page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

21. CONTACT INFORMATION

To ask questions or comment about this privacy policy and our privacy practices, or to exercise any of your rights described in this policy, please contact us at:

UpSpiral.Life LLC

Email: support@upspiral.life

Website: upspiral.life

Mailing Address: 65 Merrimon Ave, #1241 Asheville NC 28801

If you are an EU/EEA or UK resident and wish to exercise your GDPR rights or make a complaint, you may also contact your local data protection authority.