Privacy Policy

Effective date: June 3, 2026

Please read this privacy policy carefully.

Your privacy is important to Up Capital Management, Inc. (“UCM,” “we,” “us,” or “our”). This Privacy Policy explains what information we collect about you when you visit upcapitalmgmt.com, how we use that information, the choices you have, and the steps we take to protect it. By using this website, you agree to the practices described here. If you do not agree, please do not use the site.

This policy applies to information collected through our website. It does not apply to the separate terms that govern your relationship with us once you become a client. Your client relationship is governed by your advisory agreement and the disclosures in our Form ADV.

Summary

We value your privacy and we limit what we collect to what we need. We do not sell your personal information. We use the information you give us, and the information we gather automatically, to operate the site, respond to your requests, send you communications you have asked for, and improve what we offer. You can opt out of analytics and advertising tracking, and you can ask us to access, correct, or delete the personal information we hold about you. California residents have additional rights, described in the California Privacy Disclosure below.

The information we collect

Information you give us directly

When you fill out a form on our site, subscribe to a newsletter, request a meeting, or otherwise contact us, you may provide:

  • Your name, email address, and phone number
  • Your city, state, or other location details
  • Information about your financial situation or goals that you choose to share in a message or form
  • Any other information you include when you write to us

We collect this information through Gravity Forms, the form software we use on the site. We use it to respond to you, to schedule conversations, and to send you the communications you request.

Information we collect automatically

When you visit the site, we and our service providers collect certain information automatically through cookies and similar technology:

  • Your IP address and general location
  • Your browser type, device type, and operating system
  • The pages you view, the links you click, and the time and date of your visit
  • The website or source that referred you to us

We use Google Analytics to understand how visitors use the site so we can improve it. Google Analytics sets cookies and collects usage information on our behalf. You can learn how Google uses this data at policies.google.com/technologies/partner-sites, and you can opt out using the Google Analytics opt-out browser add-on at tools.google.com/dlpage/gaoptout.

Advertising and remarketing

We work with third-party advertising platforms, including Meta (Facebook and Instagram), LinkedIn, and Google Ads, to reach people who may be interested in our services. These platforms place pixels or tags on our site that allow them to recognize your browser and show you our ads on their platforms and elsewhere on the internet. This is sometimes called remarketing.

These platforms may combine the information collected on our site with information they already hold about you. We do not control how these platforms use that information. You can manage your advertising preferences directly:

  • Meta: facebook.com/ads/preferences
  • LinkedIn: linkedin.com/psettings/advertising
  • Google: adssettings.google.com

You can also opt out of interest-based advertising from many companies at optout.aboutads.info and optout.networkadvertising.org.

Email communications

When you subscribe to a newsletter or update, we manage that subscription through Constant Contact, our email service provider. Constant Contact stores your email address and tracks whether emails are opened and which links are clicked, so we can understand engagement and improve our communications. Every email we send includes an unsubscribe link, and you can opt out at any time.

How we use the information we collect

We use the information we collect to:

  • Operate, maintain, and improve the website
  • Respond to your questions and requests
  • Schedule and prepare for conversations you request
  • Send you newsletters, updates, and other communications you have asked to receive
  • Understand how visitors use the site so we can make it better
  • Show relevant advertising to people who may be interested in our services
  • Comply with our legal and regulatory obligations as a registered investment adviser
  • Protect the security and integrity of the site

How we share information

We do not sell your personal information. We share it only in the limited circumstances described here:

  • Service providers. We share information with companies that perform services for us, such as our website host, our form software (Gravity Forms), our analytics provider (Google), our email provider (Constant Contact), and our advertising partners (Meta, LinkedIn, Google). These providers may use the information only to perform services for us.
  • Legal and regulatory. We may disclose information when required by law, regulation, subpoena, court order, or government request, including to financial regulators with authority over our business.
  • Protection of rights. We may share information when we believe it is necessary to protect our rights, your safety, or the safety of others, or to investigate fraud or respond to a legal claim.
  • Business transfer. If we are involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will take reasonable steps to ensure it remains protected.

How we protect your information

We use reasonable administrative, technical, and physical safeguards designed to protect the personal information we hold from unauthorized access, use, or disclosure. No method of transmission over the internet or method of storage is completely secure, so we cannot guarantee absolute security. You share information with us at your own risk.

How long we keep your information

We keep personal information for as long as needed to fulfill the purposes described in this policy, to maintain our business records, and to comply with our legal and regulatory obligations. As a registered investment adviser, we are subject to recordkeeping rules that require us to retain certain records for set periods. When information is no longer needed, we take reasonable steps to delete or de-identify it.

Third-party websites

Our site may contain links to other websites operated by third parties. We are not responsible for the privacy practices or content of those sites. This policy applies only to information collected through our website. We encourage you to review the privacy policy of any website you visit.

Your choices

You have choices about how your information is collected and used:

  • Analytics. Opt out of Google Analytics using the browser add-on at tools.google.com/dlpage/gaoptout.
  • Advertising. Manage advertising preferences through the platform links above, or opt out of interest-based advertising at optout.aboutads.info.
  • Email. Unsubscribe from any newsletter using the link at the bottom of the email.
  • Cookies. Most browsers let you refuse or delete cookies through your browser settings. Some features of the site may not work properly if you disable cookies.

Children

Our site is intended for adults. We do not knowingly collect personal information from anyone under the age of 18. If you believe a child has provided us with personal information, please contact us at the address below and we will delete it.

Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will change the effective date at the top of this page. We encourage you to review this policy periodically. Your continued use of the site after a change takes effect means you accept the updated policy.

Contacting us

If you have questions about this Privacy Policy or how we handle your information, please contact us at:

Up Capital Management, Inc. 341 Lincoln Street Roseville, CA 95768
(916) 520-6420 
[email protected]


California Privacy Disclosure

Effective date: June 6, 2026

This California Privacy Disclosure supplements our Privacy Policy and applies only to California residents. It is provided under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”). Terms used here have the meaning given to them in the CCPA.

Categories of personal information we collect

In the past twelve months, we may have collected the following categories of personal information:

  • Identifiers, such as your name, email address, phone number, and IP address.
  • Personal information under California Civil Code Section 1798.80, such as your name and contact information.
  • Internet or other electronic network activity, such as your browsing activity on our site, the pages you view, and how you interact with our content and advertising.
  • Geolocation data, such as the general location derived from your IP address.
  • Inferences, such as conclusions drawn about your interests based on your activity, used for advertising.

We collect these categories from the sources described in our Privacy Policy: directly from you when you fill out a form or contact us, and automatically through cookies and tracking technology when you use the site.

We do not collect sensitive personal information for the purpose of inferring characteristics about you, and we do not use it beyond the purposes permitted under the CCPA.

How we use this information

We use the categories of personal information listed above for the business purposes described in our Privacy Policy, including operating the site, responding to your requests, sending communications you request, analyzing site usage, providing advertising, and meeting our legal and regulatory obligations.

How we share this information

In the past twelve months, we may have disclosed the categories of personal information listed above to our service providers, our advertising partners, and others as described in the “How we share information” section of our Privacy Policy.

“Sale” and “sharing” of personal information

We do not sell your personal information for money.

However, under the CCPA’s broad definitions, the use of advertising cookies and pixels to show you ads on other platforms (such as Meta, LinkedIn, and Google) may be considered “sharing” personal information for cross-context behavioral advertising. We do not knowingly share the personal information of anyone under 16.

You have the right to opt out of this sharing. To opt out, you can:

  • Use the advertising platform controls and opt-out links listed in our Privacy Policy.
  • Adjust your browser settings to limit or block cookies.
  • Contact us using the information below and we will honor your request.

Your California privacy rights

If you are a California resident, you have the following rights:

  • The right to know. You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes for collecting it, and the categories of third parties with whom we share it.
  • The right to delete. You may request that we delete the personal information we have collected from you, subject to certain exceptions, including our recordkeeping obligations as a registered investment adviser.
  • The right to correct. You may request that we correct inaccurate personal information we hold about you.
  • The right to opt out of sharing. You may opt out of the sharing of your personal information for cross-context behavioral advertising, as described above.
  • The right to non-discrimination. We will not discriminate against you for exercising any of these rights.

How to exercise your rights

To exercise your right to know, delete, or correct, you may contact us at:

Up Capital Management, Inc. 341 Lincoln Street Roseville, CA 95768 (916) 520-6420 [email protected]

We will verify your request by confirming details we already hold about you, such as your email address. We will respond within the timeframes required by the CCPA. You may use an authorized agent to make a request on your behalf, provided you give the agent written permission and we can verify their authority.