Privacy Policy

Last Modified: October 24, 2026

Scope of This Policy

This privacy policy describes the treatment of information provided or collected on the sites and applications where this privacy policy is posted, whether on our digital properties or on applications we make available on third-party sites or platforms. We follow this privacy policy in accordance with applicable law in the places where we operate. In some cases, we may provide additional data privacy notices specific to certain products, practices, or regions. Those terms are to be read in conjunction with this policy.

Website, marketing, and account administration. This policy describes how we handle information for our websites, marketing activities, dealings with prospective customers, and administration of customer accounts and billing. The collection, use, advertising, sharing, and retention provisions below apply to that information, subject to applicable law and any governing customer agreement. They do not authorize us to use customer-submitted Cloud Service content for advertising or independent third-party marketing.

Customer-submitted Cloud Service content. Business data submitted to our hosted software — including drawings, job records, pricing, customer lists, and similar material (“Customer Content”) — is governed by the applicable customer agreement and any applicable data processing agreement (“DPA”). The section “Customer Content, Usage Data, and Derived Data” below explains that distinction. This policy does not grant new rights in Customer Content or amend a customer’s accepted agreement. See our Terms of Use for website use.

Website Preview Tools and subscribed Cloud Services are different. Free demonstration, trial, and evaluation tools made available under our Preview Tool Terms are governed by those terms. A subscribed Cloud Service does not become a website Preview Tool merely because it is designated “Preview” or offered with “Preview Pricing.” Its customer agreement continues to govern Customer Content, confidentiality, and data use.

When you provide information directly to an independent third-party site or platform, that third party may collect it under its own privacy practices. Our sites and applications may also link to independently operated sites. Review their policies when you choose to provide information to them. This distinction does not remove our obligations for service providers processing information on our behalf or our obligations under applicable law, a customer agreement, or a DPA.

Who We Are

This website is owned and operated by WeProgram, LLC (d/b/a Upleveled Industries), a Puerto Rico limited liability company.

For information we process for our websites, marketing, dealings with prospective customers, and our own account and billing administration purposes, WeProgram, LLC acts as a data controller to the extent determined by applicable law.

For personal data in Customer Content that we process on a customer’s behalf, our responsibilities and the customer’s responsibilities are governed by applicable law and the applicable customer agreement and DPA. Where we act as a processor, we process that data in accordance with those obligations and the customer’s lawful instructions. Our role for other processing, including uses authorized by the governing agreement, depends on the processing and applicable law; this policy does not classify every activity as processing solely on the customer’s behalf.

Customer Content, Usage Data, and Derived Data

The customer retains ownership of Customer Content. Our rights to process Customer Content and data about the provision, use, and performance of the Cloud Services (“Usage Data”) come from the applicable customer agreement, subject to applicable law and any applicable DPA. A separately negotiated agreement may provide different rights or restrictions. The following description applies only to the extent the governing agreement authorizes it; it does not change an existing agreement or supply a permission that agreement does not grant.

Where our Cloud Services Terms govern, we may process Customer Content to provide the Cloud Services and create, retain, and use Derived Data — data, statistics, and artifacts derived from Customer Content and Usage Data — to improve our products and services, including development, testing, evaluation, model training, and fine-tuning. Before reuse, we remove identifying information and take reasonable measures to prevent identification of the customer, individuals, or the customer’s customers, suppliers, and projects. Derived Data will not reproduce the customer’s specific confidential workflows; general patterns and learnings may inform our products and services. We use commercially reasonable efforts to prevent trained models from reproducing or making available the customer’s Confidential Information.

Those Derived Data permissions and safeguards survive termination as provided in the governing Cloud Services Terms and do not themselves authorize publication. Under those Terms, we may publish anonymized and non-attributable performance results, but identifying the customer by name or logo, or publishing anything that identifies the customer, requires a separate written agreement granting that right. Where the incorporated Standard Terms permit disclosure of Usage Data, that data must be aggregated and must not identify the customer or users. Applicable confidentiality obligations continue to apply, subject to the uses authorized by the governing agreement.

Removing identifiers does not mean all Derived Data is legally anonymous. Applicable data protection laws continue to apply wherever the information remains personal data. Any required DPA must be executed before the relevant processing, and its terms govern personal-data handling to the extent provided by the governing agreement, including its conflict rules. Nothing in this policy or a customer agreement displaces rights or obligations that applicable law does not permit the parties to waive.

Types of Information We Collect

For the website, marketing, and account administration purposes described above, we collect three basic types of information – personal information (as defined in this policy), organizational information (as defined in this policy) and anonymous information (as defined in this policy) – and we may use personal and anonymous information to create a third type of information, aggregate information (also defined in this policy). For example, we may collect:

• Usage, viewing, technical, and device data when you visit our sites, use our applications on third-party sites or platforms, or open emails we send, including your browser or device type, unique device identifier, and IP address.
• Registration information you provide when you create an account, enter a promotion, or link your profile on a third-party site or platform with your registration account, such as your first name and surname, country of residence, gender, date of birth, email address, username, and password;
• Transaction information you provide when you request information, contact Client Services, or purchase a product or service from us, such as your postal address, telephone number, and payment information;
• Information you provide in public forums on our sites and applications, such as your public posts;
• Information sent either one-to-one or within a limited group using message, chat, post, or similar functionality, where we are permitted by applicable law to collect this information;
• Information we obtain from a third party, such as a site or platform provider, about use of our applications on third-party platforms or devices;
• Location information, including location information provided by a mobile or other device interacting with one of our sites or applications (including through beacon technologies), or associated with your IP address, where we are permitted by law to process this information;
• Activity information about your use, and the use by any person(s) you authorize through your account, of our sites and applications, such as the content you view or post, how often you use our services, and your preferences; and

How We Collect Your Information

The following describes collection for website, marketing, and account administration purposes. Customer Content and related Usage Data remain subject to the separate agreement-based treatment described above.

• We collect information you provide to us when you request or purchase products, services, or information from us, register with us (including when you link your profile on a third-party site or platform with your registration account), participate in public forums or other activities on our sites and applications, respond to client surveys, or otherwise interact with us using one or more devices. You may provide information in a variety of ways, including by typing or using voice commands.
• We collect information through a variety of technologies, such as cookies, Flash cookies, pixels, tags, software development kits, application program interfaces, and Web beacons, including when you visit our sites and applications or use our applications on third-party sites or platforms using one or more devices, whether or not you are logged in or registered.
• We collect information using analytics tools, including when you visit our sites and applications or use our applications on third-party sites or platforms.
• We acquire information from other trusted sources to update or supplement the information you provided or we collected automatically, such as when we validate postal address information using third party services. Applicable law may require that you authorize the third party to share your information with us before we can acquire it.

Use of Your Information

For website, marketing, and account administration information, consistent with applicable law, the governing customer agreement, and choices and controls that may be available to you, we may use information collected from you, or from devices associated with you, to:

• Provide you with the experiences, products, and services you request, view, engage with, or purchase;
• Communicate with you about your account or transactions with us and send you information or request feedback about features on our sites and applications or changes to our policies;
• Send you offers and promotions for our products and services or third-party products and services;
• Personalize content and experiences;
• Provide you with targeted advertising based on your activity on our sites and applications and on third-party sites and applications;
• Operate, understand, optimize, develop, or improve our sites, applications, products, services and operations, including by using client survey research and analytics tools; and
• Detect, investigate and prevent activities that may violate our policies or be illegal.

Sharing Your Information with Other Entities

For website, marketing, and account administration information, we share personal or organizational information only in limited circumstances, subject to applicable law and any governing customer agreement, including:

• When you allow us to share your personal information or organizational information with carefully selected companies so that they can send you offers and promotions about their products and services;
• When you direct us to share your personal information with another company to fulfill your request, such as:
  • When you engage WeProgram to deliver services that include work performed by third-party partners, such as CNC programming contractors, equipment manufacturers, or software integration providers; and
  • When you request consultations, audits, or other engagements that involve coordination with third-party business systems or service partners.
• When companies perform services on our behalf, like package delivery, marketing and advertising, and customer service; however, these companies are prohibited from using your personal information for purposes other than those requested by us or required by law; and
• When we share your personal information with third parties in connection with the sale of a business, to enforce our Terms of Use or rules, to ensure the safety and security of our clients and third parties, to protect our rights and property and the rights and property of our clients and third parties, to comply with legal process, or in other cases if we believe in good faith that disclosure is required by law.

Service providers processing information on our behalf are distinct from independent third parties. They remain subject to the applicable contractual, confidentiality, and data-protection obligations; disclosure to a service provider does not remove our obligations. An independent recipient may process information under its own privacy policy where the disclosure and processing are authorized. Customer Content, related Usage Data, and Derived Data are shared only as permitted by the governing customer agreement, any applicable DPA, and applicable law, rather than under the general marketing-sharing provisions above.

Your Controls and Choices

For website, marketing, and account administration information, we provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. In accordance with applicable law, your controls and choices may include:

• Correcting, updating, and deleting account information;
• Choosing or changing your choices for subscriptions, newsletters, and alerts;
• Choosing whether to receive from us offers and promotions for our products and services, or products and services that we think may be of interest to you;
• Choosing whether we share your personal information or organizational information with other companies so they can send you offers and promotions about their products and services;
• Choosing to control targeted advertising you receive within applications by using the settings and choices made available to you through your device(s), for example, by re-setting your device’s advertising identifier and/or opting out of interest based ads;
• Change or withdraw your consent for cookie use from the Cookie Declaration on our website;
• Requesting removal of your personal information from a public forum on one of our sites or application; and
• Requesting access to the personal information we hold about you and that we amend or delete it.

You may exercise these controls and choices in various ways, contacting ClientSolutions@UpleveledIndustries.com following instructions provided in communications sent to you, or by using your device or other available settings (for example, by re-setting your device’s advertising identifier and/or opting out of interest based ads).

Please be aware that if you do not allow us to collect personal information from you, we may not be able to deliver certain experiences, products, and services to you, and some of our services may not be able to take account of your interests and preferences. If collection of personal information is mandatory, we will make that clear at the point of collection so that you can make an informed decision whether to participate. If you have questions about the specific personal information about you that we process or retain, and your rights regarding that personal information, please contact ClientSolutions@UpleveledIndustries.com.

Requests concerning personal data we process on behalf of a customer are handled according to applicable law and the governing customer agreement and DPA, including the customer’s role in responding to those requests. The choices described here do not limit statutory privacy rights.

Data Security, Integrity, and Retention

The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, administrative, and physical security measures that are designed to protect client information from unauthorized access, disclosure, use, and modification. We regularly review our security procedures to consider appropriate new technology and methods. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable. We retain website, marketing, and account administration information for the length of time needed to fulfill the applicable purposes outlined in this policy unless a longer retention period is required or permitted by law, subject to any governing customer agreement.

Customer Content retention, return, and deletion are governed by the applicable customer agreement and DPA, including obligations following termination and any permitted backup or ordinary-course record retention. Confidentiality and applicable data-protection obligations continue for retained information as required by those agreements and law. The general retention statement above does not override those obligations or the agreement-specific survival of authorized Derived Data permissions and safeguards.

Data Transfers, Storage, and Processing Globally

We operate globally and may transfer your personal information and organizational information to locations around the world for the purposes described in this privacy policy. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. Transfers involving Customer Content are also subject to applicable data protection laws, the governing customer agreement, and any applicable DPA.

Changes to This Privacy Policy

From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on our sites and applications, or by other means, consistent with applicable law.

Changes to this policy do not amend an accepted customer agreement, expand our Customer Content or Derived Data rights, or replace contractual notice and change procedures. Changes to customer agreements follow their own governing provisions.

Comments and Questions

If you have a comment or question about this privacy policy, please contact ClientSolutions@UpleveledIndustries.com.