Privacy Policy
Last updated November 6, 2026
This policy explains how 5448C8 Software LLC (“Upstep,” “we,” “us”) collects, uses, shares, and protects personal information when you use Upstep: our website at upstep.app, the Upstep web app (including workspaces on upstep.app subdomains and on custom domains that organizations connect), the Upstep iOS and Android apps, and our related services (together, the “Service”).
1. Organizations and their workspaces
Most of Upstep is used inside an organization’s workspace. When a business creates a workspace and invites its people, that business (“your organization”) controls the workspace. It decides which forms and fields exist, what gets recorded, who is a member, what each member can see and do, and which of its own customers get access to a customer portal.
We call the content in a workspace “Workspace Data”: hours and other entries, projects, customer records, form answers, attachments, reports, and similar content. For Workspace Data we act as a service provider (a “processor” under the GDPR) to your organization. We process it to provide the Service under our agreement with the organization, and the organization’s own privacy notice governs how it uses that data.
If you are a member or a customer contact of an organization and have a question or request about Workspace Data, please contact that organization. If you contact us instead, we will refer you to it and help it respond.
For your account, billing, our website, and the data we collect to secure, support, and improve the Service, we decide how the data is used (we are the “controller”), and this policy describes our practices.
2. Information we collect
Information you or your organization give us
- Account details: your name, email address, password, time zone, and profile photo.
- Sign-in and security details: two-factor authentication settings, passkeys (a public key and basic details about the device that holds it), and, if your organization uses single sign-on, the identifier, name, and email address its identity provider sends us.
- Organization details: the organization’s name, workspace address, logo, custom domain, settings, roles, teams, and overtime rules.
- Billing details: card details go directly to our payment processor, Stripe; we never see full card numbers. We give Stripe the organization’s name and the email address of the person who set it up, and we keep the card brand, last four digits, expiration date, and the subscription and payment status.
- Workspace Data: hours entries (dates, start and end times, time zone, and the answers to your organization’s form fields), projects (names, descriptions, statuses, assignees, budgets, and target dates), customer records (names, contact details, addresses, and notes), files attached to entries, and reports, views, and dashboards. Files are stored as uploaded, so a photo can include details its camera added, such as where it was taken.
- Invitations: the email addresses of the teammates and customer contacts you invite.
- Messages and feedback: what you send us, including feedback from inside the app, which reaches us by email with your name, email address, organization, and the page you were on.
Information we collect automatically
- Device and log data: IP address, browser and device type, operating system, app version, the pages and addresses you request, the referring page, and the time of each request. We record the IP address and browser or device for each sign-in. The mobile apps also send a random identifier they create for your device.
- Usage data: the pages and screens you view, the buttons and links you click (including their text), and the features you use.
- Approximate location: our analytics provider estimates your city, region, and country from your IP address, and we use your device’s time zone to show and record times. We don’t collect precise location, and our apps don’t ask for access to your location, contacts, camera, or photo library.
- Diagnostics: error reports, crash reports from the iOS app, and performance data.
- Push notification tokens: if you allow notifications in a mobile app, a token from Apple or Google that lets us send them, along with your notification preferences.
- Cookies and similar technologies: see Cookies and similar technologies.
Information from others
- Your organization can add you as a member, assign your role and teams, log hours on your behalf, and include your name in records and reports.
- Identity providers: if your organization uses single sign-on, its identity provider tells us who you are when you sign in.
- Stripe tells us whether payments succeed and gives us the card summary described above.
- Apple and Google give us crash reports from the mobile apps when your device is set to share diagnostics, and statistics such as how many times the apps have been installed.
3. How we use information
We use personal information to:
- Provide the Service. Create and secure accounts, sign you in, run workspaces, calculate hours and overtime, build reports and exports, and send the notifications and scheduled reports your organization sets up.
- Bill for the Service. Process payments, manage subscriptions, and keep billing records.
- Communicate with you. Send verification, password, and security emails, invitations, billing notices, and notices about changes to the Service, send push notifications you allow, and answer your messages.
- Keep the Service secure. Authenticate users, prevent fraud and abuse, limit repeated requests, keep audit records of changes, and investigate incidents.
- Support you. To answer a support request, fix a problem, or investigate abuse, authorized Upstep staff may look at an account or temporarily sign in as a user. Only staff accounts can do this, and we record when it happens.
- Understand and improve the Service. Product analytics, error reports, and performance data help us fix bugs, keep the Service fast, and decide what to build. Feature flags let us roll out changes gradually.
- Meet legal obligations. Comply with law, respond to lawful requests, and enforce our terms.
We don’t sell Workspace Data, use it for advertising, or use it to train AI models.
4. Legal bases for processing (EEA, UK, and Switzerland)
If you are in the European Economic Area, the United Kingdom, or Switzerland, data protection law requires us to have a legal basis for each way we use personal information as a controller. We rely on:
- Purpose
- Providing the Service, including accounts, workspaces, and support
- Legal basis
- Performance of our contract with you or your organization. For members an organization invites, our legitimate interest in providing the service the organization asked for.
- Purpose
- Billing and subscriptions
- Legal basis
- Performance of a contract; legal obligations for tax and accounting records
- Purpose
- Security, fraud and abuse prevention, audit records
- Legal basis
- Our legitimate interest in protecting the Service and its users; legal obligations where they apply
- Purpose
- Product analytics, error monitoring, and improving the Service
- Legal basis
- Our legitimate interest in understanding how the Service is used and keeping it working well
- Purpose
- Service emails and messages
- Legal basis
- Performance of a contract and our legitimate interest in keeping you informed about your account
- Purpose
- Push notifications
- Legal basis
- The same bases as providing the Service, since notifications are part of it. You can turn them off in the app or in your device settings.
- Purpose
- Complying with law and responding to lawful requests
- Legal basis
- Legal obligation
Where we rely on legitimate interests, we balance them against your rights, and you can object (see Rights in the EEA, UK, and Switzerland). You need to give us account information to use the Service; without it we can’t create an account for you. We don’t make decisions about you based solely on automated processing that produce legal or similarly significant effects.
7. How long we keep information
- Account information is kept while your account exists. When you ask us to delete your account, we delete it within 30 days of confirming the request. Workspace Data you added to an organization’s workspace, such as hours you logged, belongs to that organization and stays with it.
- Workspace Data is kept while the organization’s workspace exists. Items deleted in a workspace disappear from view right away, and we keep a copy until the workspace itself is deleted. Entries a member logged stay with the organization after that member leaves it. When an organization asks us to delete its workspace, we delete its Workspace Data, including files, within 30 days.
- Sign-in records, including the IP address and browser or device for each sign-in, are kept while your account exists.
- Audit records of security events and changes, which can include names, email addresses, and IP addresses, are kept to secure the Service, investigate incidents, and resolve disputes. They can outlast the account or workspace they describe.
- Billing records are kept for as long as tax and accounting laws require, generally up to seven years.
- Analytics and diagnostic data are kept only as long as they are useful for the purposes in this policy, within the limits our analytics and error-monitoring providers set.
- Messages and feedback are kept as long as we need them to respond to you and improve the Service.
Deleted information can remain in backups until those backups expire. We may keep information longer when the law requires it, or to resolve disputes and enforce our agreements.
8. How we protect information
We use safeguards designed to protect personal information, including:
- encryption in transit (HTTPS) for the website, the web app, and the mobile apps;
- encryption at rest for our main database and stored files;
- passwords stored only as one-way hashes, and organizations’ single sign-on credentials stored encrypted;
- two-factor authentication, passkeys, and single sign-on for organizations that want them;
- file links that expire, so attachments can’t be opened with an old link;
- roles and permissions that limit what each member can see, and audit records of changes; and
- access to production systems limited to staff who need it.
No method of transmission or storage is completely secure, so we can’t guarantee security. If we learn of a breach that affects your personal information, we will notify you and your organization as the law requires.
9. International transfers
We are based in the United States, and we store and process data in the United States. Some of our service providers process data in other countries too. When we transfer personal information out of the EEA, the UK, or Switzerland, we rely on a lawful transfer mechanism, such as the European Commission’s Standard Contractual Clauses (with the UK and Swiss addenda) or a recipient’s certification under the EU-U.S. Data Privacy Framework and its UK and Swiss extensions.
10. Your choices
- Your profile. You can update your name, photo, password, time zone, two-factor authentication, and passkeys in your profile, and see which devices are signed in to your account. To change your email address, write to us.
- Your data. You can ask us for a copy of your personal information, or ask us to correct or delete it, by writing to [email protected]. To delete your account, write to us from the email address on the account. We will delete your account and the personal information tied to it within 30 days of confirming the request, except for what we must keep for legal, tax, or security reasons (see How long we keep information). Deleting your account doesn’t delete Workspace Data you added to an organization’s workspace; that stays with the organization. An organization’s administrators can ask us to delete its whole workspace the same way.
- Workspace Data. Your organization controls its workspace, so requests about entries, files, or other content in it are best sent to your organization’s administrators. We will pass along requests we receive and help the organization respond.
- Emails. Most emails we send are needed to run your account, such as verification, password, security, and billing emails, and you can’t opt out of them while you have an account. You can change project reminders in your profile; scheduled reports are set up by your organization. If we send product news, each email will include a way to unsubscribe.
- Push notifications and reminders. You can turn these off on the Account screen of the Upstep mobile app or in your device’s settings.
- Cookies. See Cookies and similar technologies.
11. Rights in the EEA, UK, and Switzerland
If you are in the EEA, the UK, or Switzerland, you have the right to:
- access the personal information we hold about you and get a copy of it;
- have inaccurate information corrected;
- have your information erased;
- restrict how we use your information;
- object to our use of your information based on legitimate interests;
- receive information you gave us in a portable format; and
- withdraw consent at any time, where we rely on consent, without affecting earlier processing.
To use these rights, write to [email protected]. We will respond within one month, and may ask you to confirm your identity first. You also have the right to complain to your local data protection authority, such as the authority in your EU country of residence, the UK Information Commissioner’s Office, or the Swiss Federal Data Protection and Information Commissioner.
12. US state privacy rights
Depending on where you live (for example California, Colorado, Connecticut, Oregon, Texas, or Virginia), you may have the right to:
- know what personal information we collect, use, and disclose, and get a copy of it;
- correct inaccurate personal information;
- delete personal information;
- opt out of the sale or sharing of personal information, targeted advertising, and certain profiling. We don’t do any of these;
- limit the use of sensitive personal information. We use it only to provide and secure the Service; and
- not be treated differently for using these rights.
To make a request, write to [email protected]. We will confirm your identity by asking you to respond from, or verify access to, the email address on your account. You can use an authorized agent; we will ask for proof that you gave them permission. If we deny your request, you can appeal by replying to our response. If we deny the appeal, you can contact your state attorney general.
California disclosures
In the past 12 months we have collected the categories of personal information below, for the purposes in How we use information. We have not sold personal information or shared it for cross-context behavioral advertising, and we don’t knowingly sell or share the personal information of anyone under 16.
- Category
- Identifiers
- Examples
- Name, email address, user and device IDs, IP address, push notification tokens
- Disclosed for business purposes to
- Our service providers, and your organization
- Category
- Customer records
- Examples
- Name, email address, and a card’s brand, last four digits, and expiration date
- Disclosed for business purposes to
- Stripe and our hosting providers
- Category
- Commercial information
- Examples
- Subscription plan and payment history
- Disclosed for business purposes to
- Stripe and our hosting providers
- Category
- Internet or other electronic network activity
- Examples
- Pages and screens viewed, clicks, device and browser details, logs, and error reports
- Disclosed for business purposes to
- Our analytics, error-monitoring, and hosting providers
- Category
- Geolocation data
- Examples
- Approximate location estimated from your IP address
- Disclosed for business purposes to
- Our analytics provider
- Category
- Professional or employment-related information
- Examples
- Hours worked, time entries, roles, teams, and projects, as entered by you or your organization
- Disclosed for business purposes to
- Your organization, and our hosting providers
- Category
- Audio, electronic, or visual information
- Examples
- Profile photos, logos, and files you attach
- Disclosed for business purposes to
- Your organization, and our hosting providers
- Category
- Sensitive personal information
- Examples
- Account login details: your email address and password
- Disclosed for business purposes to
- Our hosting providers, only to sign you in and secure your account
We collect these categories from the sources in Information we collect, and keep them for the periods in How long we keep information.
We don’t share personal information with third parties for their own direct marketing. We don’t sell or share personal information, so there is no sale or sharing for a Global Privacy Control signal to stop. We don’t track you across other companies’ websites, so we don’t respond differently to Do Not Track signals.
13. Children
Upstep is a business service and is not meant for children. We don’t knowingly collect personal information from anyone under 16. If you believe a child has given us personal information, write to [email protected] and we will delete it.
14. Changes to this policy
We may update this policy as the Service changes. We will post the new version here and update the date at the top. If a change is significant, we will also tell you by email or in the Service before it takes effect.
15. Contact us
Questions, requests, or complaints about this policy or your personal information can go to 5448C8 Software LLC at [email protected].
Upstep is operated by 5448C8 Software LLC.