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Privacy Policy

Upswing  is committed to protecting and safeguarding any personal data that it gathers, stores, compiles & executes . We act in the best interests of our clients and their customers  and we are transparent about our processing of client personal data.

Upswing  provides a subscription cloud-based Predictive data analytics solutions, guest facing applications  to its clients (Hotels) & their customers (Guests)


This document describes how we use and process any data on all of the services that we provide to our clients and which our clients use when providing their services to their customers. This one Privacy Policy applies to any kind of information we collect through this website, the services we provide, the solutions we provide or other means connected to these services (such as contacting our customer service team via telephone, the website or by email).




When our clients subscribe to our services, personal information is collected 1) directly from client during the sales process, 2) Once Upswing is connected to all the data sources (PMS, POS, OTA, Review sites, any other source). Upswing will keep collecting data pre & post implementation of our solutions.


 Collection of personal information can occur through other interactions including:

  • Conversations with our team members;

  • When client complete registrations, requests or application for our services;

  • When client communicate with us directly (by telephone, email or any means); and

  • When we interact with client during trade shows, masterclasses, webinars, training and special events.


Upswing  collects and processes personal information from its clients that is legally necessary for the performance of a contract & our solution. This includes for the purpose of proving the client with right solution, insights, predictions, recommendations  & being able to contact client, interact with client and verify client on any matters relating to client contract with Upswing , of use, the provision of customer support services, customer training, to create orders, transaction records, billing and payment and any other matters incidental to the performance of our services.

Personal information is any information that can be used to uniquely identify an individual. We may collect the following personal information from our clients: 

  • Name

  • Business address

  • Email address(es)

  • Travel purpose

  • Payment mode

  • KYC document

  • Telephone number(s)


Other information which may be collected may include:

  • Client marketing preferences, including the type of marketing materials client wish to receive and the method of delivery (email, SMS), and

  • Information client provide to us via our customer service team, website, and application for Upswing .


Where needed under applicable law, Upswing  will obtain client consent prior to processing client personal data for direct marketing purposes.

Upswing  will hold the personal information of our clients for a long as is necessary for the provision of the services that client subscribe for, to comply with all legal, taxation and other regularity requirements and for sales and marketing purposes both during and after the period of client subscription.


Upswing  Clients will collect personal information of their customers to perform relevant operations.


Upswing  acts as the data processor, big data, predictive data solutions provider  to our clients. Our clients therefore have the primary responsibility for the protection of their guests personal information.


Therefore, Upswing  will process on behalf of our clients, personal information of their guests including but not limited to:

  • Client name

  • Preferred contact details, including email or social media address, home address, telephone number, and date of birth,;

  • The names of anybody travelling with client;

  • Client payment information; and

  • Any other relevant information including special requests or preferences, and any information that requires to fulfill data needs for Upswing's solution


Our clients collect and processes personal information from its guests for the performance of a contract, specifically to administer their online bookings from customers. If the required personal information is not provided, our clients cannot finalize the booking and ensure client stay with them is as enjoyable as possible. Our client’s may also use guests personal information to provide customer service by informing the guests of any changes to the booking, latest deals and special offers and other products or services which they believe may be of interest to client. An Upswing  client may also use client personal information for the purpose of sending guest a survey or for future marketing and sales activities. If guests would like to find out the specific purposes that our client has collected guests personal information, please refer to the privacy policy of the client or contact the property direct.

Upswing  also may from time to time have a need to access client personal information that has been collected and processed by our client.

Our clients may hold guests personal information for as long as is reasonably necessary for the performance of the booking and for such time thereafter as they have a legal basis. In regard to any booking client have made with a client of Upswing , client should consult the privacy policy of our client for the specifics of their data retention policy.


Upswing may use third party tool to analyze the data, contractors or service providers needing to contact our clients, and then only to the extent reasonably necessary to fulfill our obligations to our client, or to comply with government or other regulatory requirement.

In order to support the use of the Upswing  services, client details may be shared with members of the Upswing  corporate family which act as service providers for Upswing , including in relation to customer support services.

Upswing  may disclose personal information to third parties to comply with any court order or other legal obligation or when data is requested by government or law enforcement authorities.

Upswing  may use service providers to process client personal data on our behalf. This processing is for several purposes, including sending out marketing material to the email address client provided when subscribing to Upswing . Third party service providers shall either be bound by:

  • Our data privacy policy or have similar obligations in relation to the storage and processing of personal information, or

  • Confidentiality clauses and are not allowed to use client personal data for other purposes than instructed by Upswing .


Customer Lists:

  • Upswing  does not disclose the personal information of our clients customers to any third parties.

  • Upswing  does not sell or rent personal information.


Screen shots used in demonstrations and examples in manuals, advertising or on our website do not include the details of any real person.

Customer References:

  • Upswing  will respond to requests from potential clients by providing names of selected clients as examples of where its products are used.

  • If referees are requested, Upswing  will contact existing customers to obtain agreement before releasing contact details.


Third Party Integration:

Different parties integrated into the Upswing  services in a number of ways and for various reasons. Upswing  acts as the data processor for our clients and any personal information disclosed by and through these integrations is done so at the direction of and is the responsibility of our client.



Upswing  is a service provider and data processor to our clients. Upswing  services are not designed or directed at children. If an Upswing  client becomes aware that they processed information of a child without the valid consent of a parent or guardian, they may reserve the right to delete it.



Upswing  will from time to time market to its clients. client have the right to ask us to stop processing client personal information for marketing purposes. client can unsubscribe from emails by clicking the unsubscribe link on the footer of the email communication client have received.  client can also exercise the right at any time by contacting us on the details set out in the “Contact Us” section of our website to amend client marketing communication preferences.


Upswing  Clients

Upswing  clients have the right to review the personal information we hold about client. client can request an overview of client personal data by emailing us to the email address stated below.


Before providing personal information to client or another person on client behalf, we may ask for proof of identity.

If any of the personal information we hold about client is inaccurate or out of date, client may ask us to correct it.

We rely on client to ensure that client personal data is complete, accurate and current. Please do inform us promptly of any changes to or inaccuracies of to client personal data. 

Client have the right to object to us processing client personal information or to delete client personal information or have its processing restricted in certain circumstances.

Customers of Upswing  Clients

The rights of customers of Upswing  Client’s to review the personal information our client holds about client, to amend the personal information, to restrict the processing of the personal information and to delete client personal information is governed by regulations in place in client jurisdiction and the privacy policy of the Upswing  Client. Please contact the property direct and/or the relevant regulator if client have any queries in this regard.

Upswing  as the service provider and data processor has provided functionality to our clients to review customer personal information, restrict certain processing and to delete the personal information.  The use of that functionality is the responsibility of the Upswing  client who is the controller of that data.

Upswing  is also able to provide our clients with functionality where client may view the personal information held about client and make corrections to client personal information themselves.

Where client personal information is processed by an Upswing  client on the basis of client consent, client may be entitled to withdraw that consent at any time subject to applicable law. Moreover, where an Upswing  client processes client personal data based on legitimate interest or the public interest, client may, subject to applicable law have the right to object at any time to that use of client personal data when no opt-out mechanism is available to client. 

Please contact the property direct and/or the relevant regulator if client have any queries in this regard.



Upswing  has implemented reasonable measures designed to secure personal information from accidental loss from unauthorized access, use, alteration and disclosure. Upswing  encrypts data in transmission and at rest, and all access to computer hardware containing personal information is password protected. Staff access to personal information is given on a need to know basis only.

Upswing  Clients have access to their customers’ personal information. Upswing  Clients are the data controllers for their data. Upswing  is not responsible for the security standards of Upswing  Clients. Upswing  services provide the client with functionality to restrict access to data.


If client have any questions relating to security at an Upswing  client please contact the property direct.



No data transmission over the Internet can be guaranteed to be secure. While Upswing  will endeavor to protect customer information, it cannot guarantee the security of any information any person may transmit when they access its website.

Even though Upswing  encrypts data transmitted over the Internet, it still cannot guarantee data transmitted cannot be encrypted by persons with nefarious intentions. Nonetheless, the likelihood of this occurring is extremely low.



Remote access to customers’ databases is needed to provide an efficient and rapid response to requests for assistance.

Upswing  staff will only connect to a customer’s data with the full knowledge of the customer and will advise when connection is terminated.




Cookies may be placed on client computer or internet-enabled device whenever client visit Upswing  online booking pages. This allows the site to remember client computer or device and serves a number of purposes. Although most browsers automatically accept cookies, client can choose whether or not to accept cookies via client browser’s settings (often found in client browser’s Tools or Preferences menu). 

Client may also delete cookies from client device at any time. However, please be aware that if client do not accept cookies, client may not be able to fully experience some of the features. Cookies by themselves do not tell us client email address or otherwise identify client personally.

Cookies are only used by online booking pages provided by Upswing  to improve the online booking process. By remembering the preferences of visitors to the online booking pages Upswing  streamline the reservation process.

Cookies are used for no other process and the information pertaining to them are not shared with any other person or entity.

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