Privacy Policy

Effective date: 14 September 2026

1. Who we are

This Privacy Policy is issued jointly by Turn Up Technologies Limited, a company registered in England and Wales with its registered office at 83 Victoria Street, London SW1H 0HW, United Kingdom, and Turn Up Technologies LLC, a Texas limited liability company with its registered address at 5900 Balcones Dr 20058, Austin, TX 78731, United States. In this policy, “Turn Up Technologies”, “we”, “us” and “our” refer to both companies, each of which acts as an independent controller of the personal data it handles.

Turn Up Technologies Limited is the controller for clients and website visitors in the United Kingdom, Europe and the rest of the world. Turn Up Technologies LLC is the controller for clients and website visitors in the United States and Canada, and is the sending party for all SMS and text message communications described in Section 8.

We operate the website https://turnuptechnologies.co (the “Site”) and provide software development, mobile and web application development, search engine optimisation, paid advertising management, social media management, AI integration and related digital services (the “Services”).

If you have any questions about this policy or how we handle your personal data, contact us at business@turnuptechnologies.co or write to either of the addresses above.

2. Scope

This policy applies to personal data we collect through the Site, through our client onboarding and project delivery processes, through email, telephone and text message communications, through social media and advertising platforms, and through third-party tools we use to run our business.

It does not cover the privacy practices of our clients. Where we process personal data on behalf of a client (for example, when we build a website, run an advertising campaign or manage a CRM for a client), we act as that client’s processor, and the client’s own privacy policy governs how that data is used.

Client project data. When we deliver a project or retainer, we may receive personal data belonging to your customers, staff or users, for example customer records in a CRM, order data in an ecommerce store, form submissions on a website we build, or audience data in an advertising account. We process that data only on your documented instructions, only for the purpose of delivering the agreed Services, and under the data processing terms in your proposal or a separate data processing agreement. We do not use it for our own purposes, do not combine it with data from other clients, and return or delete it at the end of the engagement in line with your instructions.

Platform access and credentials. To deliver the Services you may give us logins or admin access to your website, hosting, domain registrar, advertising, analytics, social media, email marketing, app store or other accounts. We store credentials in an encrypted password manager with access limited to the team members working on your account, use them only for the Services, and remove our access or return the credentials when the engagement ends or on request. We recommend you rotate passwords after handover.

3. Personal data we collect

We collect the following categories of personal data:

Identity and contact data. Your name, job title, company name, email address, telephone number, postal address and, where you communicate with us on social media, your username or handle.

Enquiry and project data. The content of any enquiry you send us through the Site, by email, by telephone or by text message, together with information you give us about your business, your goals, your budget and your existing systems so that we can scope and deliver the Services.

Contractual and billing data. Details of the Services we agree to provide, proposals, statements of work, change requests, contract documents, invoices, payment records, refund and cancellation records and, where you pay by card or bank transfer, the limited transaction data returned to us by our payment provider (such as the last four digits of a card, the payment date and the amount). We do not store full card numbers. Payments are handled by PCI-compliant payment processors who process your card details under their own privacy policies.

Communications data. Emails, call recordings and transcripts where you have been notified that a call is recorded, text message content and opt-in and opt-out records, meeting notes and support tickets.

Technical and usage data. Your IP address, browser type and version, operating system, device identifiers, referring URLs, pages viewed, time spent on pages, clicks and similar interaction data collected through cookies and comparable technologies. See our Cookies Policy at https://turnuptechnologies.co/cookies-policy/ for details.

Marketing and preference data. Your marketing preferences, your consent records for email and SMS communications, and your engagement with the marketing we send.

Recruitment data. If you apply for a role with us, your CV, application form, references and interview notes.

We do not intentionally collect special category data (such as health, religious or biometric data) or data relating to criminal convictions, and we ask you not to send it to us.

4. How we collect personal data

We collect personal data when you:

• Fill in a form on the Site, including the Contact Us and Schedule a Call forms
• Email us, call us, text us or message us on WhatsApp, LinkedIn or another platform
• Book a meeting through a scheduling link
• Enter into a contract with us or receive an invoice from us
• Subscribe to our newsletter or download a resource from the Site
• Interact with our advertising on Google, Meta, LinkedIn or another platform
• Browse the Site, through cookies and similar technologies
• Apply for a job with us

We also receive personal data from third parties, including business directories, professional networking platforms, referral partners and analytics and advertising providers.

5. Why we use personal data and our legal basis

Under UK and EU data protection law we must have a lawful basis for each use of personal data. The table below sets out each purpose and the basis we rely on.

Where we rely on legitimate interests, we have assessed that our interests are not overridden by your rights and freedoms. You can ask us for details of that assessment.

6. Who we share personal data with

We share personal data with the following categories of recipient, in each case only to the extent needed for the purpose:

Our group companies. Turn Up Technologies Limited and Turn Up Technologies LLC share data with each other, and with our delivery teams in Dubai, Toronto and Karachi, to deliver the Services and run our business.

Service providers. Hosting and cloud infrastructure providers, email and communications platforms, CRM and project management tools, telephony and SMS platforms, payment processors, accounting software, analytics providers and IT support providers. Each acts under contract and may only use the data to provide its service to us.

Advertising platforms. Google, Meta, LinkedIn and similar platforms, for the purposes of measuring and targeting our own advertising, only where you have consented to advertising cookies.

Professional advisers. Lawyers, accountants, auditors and insurers.

Authorities. Courts, regulators, law enforcement and tax authorities, where required by law.

Business transfers. A buyer or prospective buyer of all or part of our business, subject to confidentiality.

We do not sell personal data. We do not share your personal data with third parties for their own direct marketing purposes.

7. International transfers

We are a group with offices in the United Kingdom, the United States, the United Arab Emirates, Canada and Pakistan, and we use service providers around the world. Your personal data may therefore be transferred to, stored in and accessed from countries outside the one in which you live.

Where we transfer personal data from the United Kingdom or the European Economic Area to a country that has not been found to provide adequate protection, we rely on the UK International Data Transfer Agreement or Addendum, or the EU Standard Contractual Clauses, together with supplementary measures where needed. You can request a copy of the relevant transfer mechanism by contacting us.

8. SMS and text messaging

This section applies to text messages sent by Turn Up Technologies LLC using our business telephone numbers.

What we collect. When you provide your mobile phone number to Turn Up Technologies through a form on our website, during a call, in person, by email or in writing, and agree to receive text messages from us, we collect and store your phone number together with a record of your consent, including the date, time and method of opt-in.

How you opt in. We collect SMS consent in two ways.

Verbal: Turn Up Technologies collects SMS consent verbally in person or by phone. Customers provide their phone number and are asked if they would like to receive customer support SMS messages. They are informed that msg/data rates may apply, msg frequency vary, reply HELP for support/STOP to opt-out. Privacy Policy at turnuptechnologies.co/privacy-policy

Website: On our website, there is a Contact form to fill out to get information and phone number is requested with a disclaimer for opting-in if they want to receive customer support SMS messages from Turn Up Technologies. We inform msg/data rates may apply; msg frequency vary. Reply STOP to opt-out or HELP for support. Privacy Policy at turnuptechnologies.co/privacy-policy

What we send. We use your phone number to send the customer support messages you have agreed to receive, including replies to your enquiries, appointment and meeting confirmations, project and account updates and service notifications. We will only send promotional or marketing text messages if you have separately and expressly opted in to receive them.

No sharing of mobile data. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent will not be sold, rented or shared with any third parties, excluding vendors and service providers who assist us in delivering the messages and who are bound by contract to use the information solely for that purpose. All other categories of personal information described in this policy exclude text messaging originator opt-in data and consent, which is never shared with any third party.

Opting out and getting help. You may opt out of text messages at any time by replying STOP to any message you receive from us. After you send STOP, we will send one final message confirming that you have been unsubscribed and no further messages will be sent. For help, reply HELP to any message or email business@turnuptechnologies.co. Message and data rates may apply. Message frequency may vary.

Retention. We retain your phone number and consent records for as long as needed to provide the messaging service you requested and to demonstrate compliance with applicable law. If you opt out, we keep a record of your opt-out so that we do not message you again.

The full terms that govern our text messaging programme are set out in the SMS/Text Messaging Terms section of our Terms and Conditions at https://turnuptechnologies.co/terms-and-conditions/.

9. Marketing

We may send you marketing by email about our Services where you have opted in, or where you are an existing client and the marketing relates to services similar to those you have bought from us and you have not opted out. We only send marketing text messages with your express prior consent.

You can stop receiving marketing at any time by clicking the unsubscribe link in any email, replying STOP to any text message, or emailing business@turnuptechnologies.co. We will continue to send you service messages that are necessary to deliver the Services.

10. Cookies and similar technologies

The Site uses cookies and similar technologies to make it work, to understand how it is used and, with your consent, to support our advertising. Details of the cookies we use, how long they last and how to manage them are in our Cookies Policy at https://turnuptechnologies.co/cookies-policy/.

11. How long we keep personal data

We keep personal data only for as long as we need it for the purpose it was collected, and then for any further period required by law or needed to deal with claims.

As a guide:

• Enquiry data where no contract follows: 24 months from the last contact
• Client contract, project and billing records: 7 years from the end of the contract, to meet UK and US tax and accounting requirements
• Marketing consent and preference records: for as long as you remain subscribed, plus 3 years after you unsubscribe so we can prove compliance
• SMS opt-in and opt-out records: for the life of the messaging programme plus 4 years
• Call recordings: 12 months unless needed for a dispute
• Recruitment data for unsuccessful candidates: 6 months after the role closes
• Technical and usage data: as set out in our Cookies Policy

When data is no longer needed we delete it or anonymise it.

12. Security

We use technical and organisational measures appropriate to the risk to protect personal data, including encryption in transit, access controls, multi-factor authentication on core systems, staff confidentiality obligations and contractual security commitments from our service providers. No system is completely secure, and we cannot guarantee the security of data transmitted to us over the internet.

13. Your rights

Depending on where you live, you may have the following rights in relation to your personal data:

• To be told how we use it, which this policy provides
• To access a copy of it
• To have inaccurate data corrected
• To have it deleted in certain circumstances
• To restrict or object to certain processing, including direct marketing at any time
• To receive it in a portable format where processing is based on consent or contract
• To withdraw consent at any time where we rely on consent
• Not to be subject to a decision based solely on automated processing that has a legal or similarly significant effect on you

To exercise any of these rights, email business@turnuptechnologies.co. We will respond within one month, or as otherwise required by the law that applies to you. We may need to verify your identity before acting on a request. We will not charge a fee unless a request is manifestly unfounded or excessive.

United Kingdom and EEA residents. You have the right to complain to your supervisory authority. In the UK this is the Information Commissioner’s Office at https://ico.org.uk. We would appreciate the chance to resolve any concern first.

California residents. Under the California Consumer Privacy Act you have the right to know the categories and specific pieces of personal information we have collected, the sources, the purposes and the categories of third parties we share it with, the right to delete, the right to correct, and the right not to be discriminated against for exercising these rights. We do not sell personal information and do not share it for cross-context behavioural advertising except through advertising cookies you can decline in our cookie banner.

Texas residents. Under the Texas Data Privacy and Security Act you have the rights to access, correct, delete and obtain a copy of your personal data, and to opt out of targeted advertising, sale and profiling. We do not sell personal data. You can opt out of targeted advertising cookies through our cookie banner. If we decline a request you may appeal by emailing business@turnuptechnologies.co with “Privacy Appeal” in the subject line.

Canadian residents. Under PIPEDA you have the right to access and correct your personal information and to withdraw consent. You may complain to the Office of the Privacy Commissioner of Canada.

14. Children

The Site and the Services are directed at businesses and are not intended for anyone under 18. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, contact us and we will delete it.

15. Third-party links

The Site may contain links to other websites. We are not responsible for the privacy practices of those sites and encourage you to read their policies.

16. Changes to this policy

We may update this policy from time to time. The effective date at the top shows when it was last changed. Where a change materially affects how we use your personal data, we will notify you by email or through a notice on the Site.

17. Contact

Turn Up Technologies Limited 83 Victoria Street, London SW1H 0HW, United Kingdom

Turn Up Technologies LLC 5900 Balcones Dr 20058, Austin, TX 78731, United States

Email: business@turnuptechnologies.co