Privacy Policy

Upperline LLC (“Upperline” or “we” or us”) is committed to respecting the privacy of information and data that may be used to identify you (your “personal information”). This Privacy Policy describes our policies and practices regarding the most common ways we collect, use, disclose, or otherwise process your personal information in connection with this web site (www.fintechfocus.com). In certain circumstances, we may provide you with supplemental disclosures regarding our data processing activities.

Information We Collect and How We Use Your Personal Information

Applicants to the FinTech Focus Program

Upperline collects and uses personal information about applicants to the FinTech Focus Program (referred to collectively as “applicants”). If you are or have been an applicant to the FinTech Focus Program, we may collect and use the following types of personal information about you:

• Information and supporting documentation that you provide in your application (e.g., name, address, date of birth, race, ethnicity);
• Financial information, including financial information about your family members (e.g., information collected in connection with applications for financial aid and/or scholarships)
• Survey responses (if you choose to respond to a survey sent by us or on our behalf)

Your personal information is used primarily to evaluate your application and related activities, communicating with you about your application, and other administrative functions related to the admissions and enrollment process. We may also use or disclose your personal information for the following purposes:

• To consider requests for accommodations;
• For research and statistical purposes;
• To provide you with information about future Upperline, courses and events that you might be interested in attending;
• To send surveys for research purposes;
• For compliance with legal obligations, to respond to subpoenas, court orders, or other legal process, and to enforce our agreements;
• To prevent or investigate fraud or other unlawful activity, and to protect the security of Upperline’s property, website, and other systems; and
• To protect the health, safety, or rights of you, other students, faculty, staff, and visitors.

We may share your information with the following funders and financial institutions that are working with Upperline to fund and host the FinTech Focus Program: Per Scholas and Morgan Stanley Services Group Inc., JPMorgan Chase Bank, N.A., Bank of America N.A., Wells Fargo and Goldman Sachs (the “Financial Institutions”). We may also share your information with governmental bodies as necessary for compliance with law, with law enforcement authorities when necessary, and other third parties to enforce our legal rights

Participants in the FinTech Focus Program

When you are a participant in the FinTech Focus Program, we maintain records containing your personal information. We may collect and use the following types of personal information about you, as applicable:

• Your contact information and biographical data (e.g., name, address, date of birth, race, ethnicity);
• Information and supporting documentation that you provided in your application;
• Information about technology usage (e.g., IP addresses, software downloads); and
• Survey responses (if you choose to respond to a survey sent by us or on our behalf).

We use this information for the following purposes as applicable:

• To provide educational and related services (e.g., maintaining relevant records of your participation in the program, providing you with access to educational materials);
• To administer the financial aspects of the relationship (e.g., collecting tuition, coordinating with lenders or other funders);
• To enable your participation at events and in other opportunities (e.g., other programs, internships);
• To protect the educational integrity of the program;
• To accommodate special needs (e.g., disability accommodations);
• For research and statistical purposes related to our educational and/or other services;
• For compliance with legal obligations, to respond to subpoenas, court orders, or other legal process, and to enforce our agreements;
• To prevent or investigate fraud or other unlawful activity, and to protect the security of Upperline’s property, website, and other systems; and
• To protect the health, safety, or rights of you, other students, faculty, staff, and visitors.

We may share your personal information with the following:

• Faculty and staff at Upperline in order to fulfill their responsibilities under the FinTech Focus Program;
• The Financial Institutions, Per Scholas and their staff to enable them to fulfill their responsibilities under the FinTech Focus Program; and
• Governmental bodies as necessary for compliance with law, with law enforcement authorities when necessary, and other third parties to enforce our legal rights.

Website Visitors

The FinTech Focus web site is an information system intended to present an integrated view of the FinTech Focus program to prospective students. If you visit this site to view or download information, or submit information to us, we or our third-party vendors may automatically collect the following types of personal information:

• The name of the domain from which you access the Internet;
• The date and time of your visit;
• The page/s you visit; and/or
• Your computing platform.

Some of this information may be collected through the use of cookies, which are text files that are placed on your hard disk by a web server, or similar technologies, such as web beacons. Some of these cookies are managed by third parties that we do not control, such as Google Analytics. You have the ability to accept or decline cookies by changing your browser settings. If you choose to decline cookies, some features on this website may not work properly. Usage of a cookie is in no way linked to any personally identifiable information on our site. The data collected with cookies and similar technologies are used in the aggregate for purposes of analyzing site traffic, managing the site, and providing accountability regarding the usefulness of our work.

If you use our web site to complete forms, use our applications, or submit information to us, we will collect the information that you provide to us, as well as related information such as your login ID. If you provide us with information, we will use that information for the purposes described on the form/application.

We may also use your personal information for the following purposes:

• For compliance with legal obligations, to respond to subpoenas, court orders, or other legal process, and to enforce our agreements;
• To prevent or investigate fraud or other unlawful activity, and to protect the security of Upperline’s property, website, and other systems; and
• To protect the health, safety, or rights of you, other students, faculty, staff, and visitors.

Privacy Protection for Children Under the Age of 13

Upperline does not collect personal information directly from children who are under 13 years old. However, a child of this age may occasionally be eligible for certain programs administered by Upperline, in which case, a parent or legal guardian of such child must provide the child’s personal information to Upperline. The parent or legal guardian must also provide his or her own contact information (e.g., email address, mailing address and phone numbers). All communications pertaining to the program or service will be sent directly to such parent or legal guardian. The personal information (identifiable or not) of such parent or legal guardian collected is subject to this privacy policy.

Unless otherwise stated herein, this privacy policy applies to a child’s information that we collect from a parent or legal guardian, except that (1) we do not share identifiable information of a child with any third party (other than the Financial Institutions and Per Scholas for the purposes stated in this privacy policy), (2) we will only send our promotional communications or newsletters to the parent or the legal guardian who provided the child’s information to us, and (3) we do not link or tie, and prohibit third party advertisers from tying or linking, any such child’s identifiable information to log files, cookies, or other tracking mechanisms used on the web site.

For more information on online privacy protection for children under 13, please visit: https://www.ftc.gov/tips-advice/business-center/guidance/complying-coppa-frequently-asked-questions.

Your Access to and Control Over Information

You may opt out of any future contacts from us at any time. You can do the following at any time by contacting us via the email address or phone number given on our website:

• See what data we have about you, if any;
• Change/correct any data we have about you;
• Have us delete any data we have about you; or
• Express any concern you have about our use of your data.

Security

We take precautions to protect your information. When you submit sensitive information via the website, your information is protected both online and offline.

Wherever we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for "https" at the beginning of the address of the web page. While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only those individuals who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.

Links

This web site may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.

Updates

Our Privacy Policy may change from time to time and all updates will be posted on this page.

If you feel that we are not abiding by this privacy policy, you should contact us immediately via telephone at  (646) 653-2833 or via email.