Privacy Policy

Last Updated: September 3, 2026
Effective Date: March 1, 2020

1. About This Policy

UpsideHOM, Inc. (“Upside,” “we,” “us,” or “our”) is a housing stability company. We work with health plans, employers, and government programs to help people find stable housing and keep it.

This Privacy Policy explains how we collect, use, share, and protect personal information when you:

• visit joinupside.com or any Upside website, landing page, or co-branded benefit page (the “Sites”);
• contact us, complete a form, register for a webinar, subscribe to our communications, or apply for a job;
• use the Upside platform as a client user — health plan staff, employer staff, or partner organization; or
• receive housing support from an Upside Care Guide.

Important: information from housing programs is handled differently

If you are a member or employee participating in an Upside housing program, most of the information we hold about you is not governed by this policy. It is governed by:

• the Business Associate Agreement (BAA) between Upside and your health plan, under which Upside acts as a Business Associate subject to the Health Insurance Portability and Accountability Act (HIPAA);
• your health plan’s Notice of Privacy Practices;
• the services agreement between Upside and your employer or program sponsor; and
• the rules of any state program your case falls under.

Under those agreements, Upside handles your information on behalf of your health plan, employer, or program sponsor. To ask about that information — or to request access, a correction, or a copy of your record — contact your health plan or benefits administrator, or write to us at privacy@joinupside.com and we will route your request to the right place.

This policy governs our Sites, our marketing, our business contacts, and any personal information we handle for our own purposes.

2. Information We Collect

Information you give us

From our Sites and events. Your name, email address, phone number, organization, job title, and anything else you enter in a contact form, demo request, webinar registration, or job application. If you contact us, we keep a record of the correspondence.

From the platform. When a client sets up users, we collect names, usernames, email addresses, postal addresses, phone numbers, job titles, and transactional information such as services purchased.

From housing program participation. When a Care Guide works your case, we collect what we need to solve the housing problem — household composition, income and benefits documentation, housing history, identification documents, landlord and property details, and case notes. See Section 1 for how this information is governed.

Information we collect automatically

On our Sites. IP address, device and browser type, referring website, pages visited, links clicked, and the date and time of your visit.

On the platform. Usage information about which features are used and how, log data including IP address, and performance metrics. You may also be asked for feedback. Giving it is optional.

Information we receive from others

• Health plans, employers, and program sponsors who refer participants to us
• Landlords, property managers, utility companies, housing authorities, and public agencies involved in a case
• Marketing partners, business contact databases, and advertising platforms
• Analytics and identity resolution vendors (see Section 5)

3. How We Use Information

We use personal information to:

• Deliver housing navigation and stabilization services
• Respond to inquiries, demo requests, and support requests
• Set up, operate, secure, and improve the Sites and the platform
• Report program performance to health plan, employer, and government partners — in aggregate or de-identified form wherever possible
• Send marketing and educational communications you can opt out of at any time
• Review and process job applications
• Detect and prevent fraud, abuse, and security incidents
• Meet legal, regulatory, contractual, audit, and accreditation obligations
• Establish, exercise, or defend legal claims

We do not use housing case information or health information to sell you anything or to target advertising. We do not sell housing case information or health information.

Automated processing and AI

Upside uses automated tools, including AI, to support Care Guides. Two examples: the platform sorts new referrals by urgency, and it generates a preliminary housing match before the first call. These tools inform human work. They do not make final decisions about your eligibility, your services, or your case. A Care Guide reviews and owns every case decision.

4. How We Share Information

We share personal information with:

Service providers. Hosting, customer relationship management, email delivery, analytics, payment processing, document management, and security vendors. They are bound by contract to use the information only to provide services to us.

Health plans, employers, and program sponsors. The organization that referred a participant receives case status, service documentation, and reporting as permitted by our agreement with them.

Housing providers and community partners. Landlords, property managers, utility companies, housing authorities, shelters, and nonprofit programs — where sharing is necessary to secure or sustain housing and the participant has agreed.

Government and regulatory bodies. Including state Medicaid agencies and Homeless Management Information Systems (HMIS), where state program rules require it.

Professional advisors. Attorneys, auditors, accountants, and insurers.

Legal and safety. When required by law, subpoena, or court order, or to protect the rights, safety, or property of any person.

Business transfers. In connection with a merger, acquisition, financing, reorganization, or sale of assets. We will notify you if your information becomes subject to a different privacy policy.

5. Cookies, Analytics, and Advertising

We use cookies, pixels, tags, and similar technologies on our Sites to keep the Sites working, remember your preferences, measure traffic, and understand which content and campaigns perform.

Some of these technologies are operated by third-party analytics and advertising partners. Those partners may connect your activity on our Sites to other information they hold about you, including your email address or postal address, and we or they may use that connection to send you marketing. Information collected through these technologies can be linked to you personally.

We do not use advertising or marketing tracking technologies on pages where a member or employee enrolls in or accesses housing services.

Your choices

• Opt out of identity-based marketing tied to our Sites at https://app.retention.com/optout
• Change or block cookies in your browser settings
• Use the cookie preference controls on our Sites
• We honor Global Privacy Control (GPC) and similar browser opt-out preference signals as a valid opt out of the sale or sharing of personal information for that browser

6. Text Messages

Care Guides reach participants by phone, email, and text. If you give us your mobile number, you may receive text messages about your case or your request.

• Message frequency varies
• Message and data rates may apply
• Reply STOP to opt out. Reply HELP for help
• We do not sell or share mobile phone numbers or text messaging consent with third parties for their own marketing

7. How Long We Keep Information

We keep personal information as long as we need it for the purposes described in this policy, then for as long as required by law, contract, or our records retention schedule — whichever is longer.

• Housing case records: kept according to the applicable health plan agreement, state program rules, and HIPAA requirements — generally at least six years
• Website, marketing, and business contact information: kept while the relationship is active and for a reasonable period afterward, or until you ask us to delete it
• Job applicant information: kept for the period required by applicable employment law

8. Your Privacy Rights

Everyone

At any time, you can ask us to:

• Tell you what personal information we hold about you
• Correct or update it
• Delete it
• Stop sending you marketing — click unsubscribe in any email, or write to us
• Explain or address a concern about how we use your data

How to make a request: email privacy@joinupside.com, or write to the address in Section 13.

We verify your identity before acting on a request. We do not charge a fee in most cases, and we do not treat you differently for making a request. If we deny your request, you may appeal by replying to our decision, and we will respond in writing.

We may keep aggregated or de-identified information, and we may keep information we need to meet legal obligations, resolve disputes, or enforce our agreements.

California residents

Under the California Consumer Privacy Act, as amended, you have the right to know what we collect and why, to access a copy, to correct inaccurate information, to delete information, to opt out of the sale or sharing of personal information, to limit the use of sensitive personal information, to receive your information in a portable format, to be free from discrimination for exercising these rights, and to appeal a denial.

Categories of personal information collected in the past 12 months: identifiers; customer records; commercial information; internet and network activity; approximate geolocation derived from IP address; professional and employment information; inferences. For housing program participants, we also collect sensitive personal information, including government identifiers, health information, and financial account information.

We disclose personal information to service providers and to the health plan, employer, or program sponsor that referred you, for business purposes described in Section 3.

We do not sell personal information for money. Some website advertising and analytics activity described in Section 5 may qualify as a “sale” or “share” for cross-context behavioral advertising under California law. To opt out, use the controls in Section 5 or write to ccpa@joinupside.com.

We use sensitive personal information only to provide the services you asked for and for other purposes permitted without a right to limit under California law.

An authorized agent may submit a request on your behalf with your written permission and proof of identity.

Shine the Light. California residents may request a notice identifying the categories of personal information we share with affiliates or third parties for their own direct marketing purposes. Submit a written request to ccpa@joinupside.com.

Other U.S. states

If you live in a state with a comprehensive consumer privacy law — including Colorado, Connecticut, Virginia, Texas, Oregon, Montana, Delaware, Minnesota, Maryland, New Jersey, and a growing list of others — you have similar rights to access, correct, delete, and obtain a portable copy of your personal information, to opt out of targeted advertising, sale, and certain profiling, and to appeal a denied request. Use the contact methods above.

9. Security

We use administrative, technical, and physical safeguards to protect personal information. These include encryption of data in transit and at rest, role-based access controls, audit logging, employee training, and security review of our vendors. Access is limited to employees and contractors who need the information to do their jobs.

Our platform infrastructure is HIPAA-compliant and SOC 2-aligned.

No system is completely secure. We cannot guarantee the security of information you transmit to us. If we learn of a security incident affecting your personal information, we will notify you and the appropriate regulators as required by law.

10. Children’s Privacy

Our Sites are not directed to children under 13, and we do not knowingly collect personal information from children under 13 through our Sites. If you believe a child has given us personal information, write to privacy@joinupside.com and we will delete it.

Housing programs often serve households with children. Information about minors in a participating household is provided by the parent or guardian in the program and is handled under the agreements described in Section 1.

11. Links to Other Sites

Our Sites link to sites we do not operate. We are not responsible for their content or their privacy practices. Read the privacy policy of any site you visit that collects personal information.

12. Accountability and Changes to This Policy

We review this policy at least once a year and update it when our practices change. Employees who handle personal information are trained on this policy, and failure to follow it may result in discipline up to and including termination.

When we update this policy, we post the revised version here with a new “Last Updated” date. If the changes are material, we will give additional notice — by email or a notice on the Sites — before they take effect.

13. Contact Us

Privacy questions and requests: privacy@joinupside.com
California requests: ccpa@joinupside.com

By mail:
UpsideHOM, Inc.
Attn: Privacy Team
1489 W Palmetto Park Road, Suite 325, Boca Raton, FL 33486

We investigate and work to resolve any complaint or dispute about how we handle personal information.