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Upper Partners

Privacy Policy


This Privacy Policy describes Upper Partners policies regarding the collection, use, and disclosure of information about you in connection with your use of our website ( (the “Site”) and the platform provided directly to our Users (the “Services”). The terms “we”, “us”, and “Upper Partners,” refers to Upper Partners, with its headquarters in Fullerton, CA.

When you use our Services, you consent to our collection, use, and disclosure of information about you as described in this Privacy Policy.

Information We Collect

Upper Partners collects personal information to facilitate your use of the Upper Partners Site or Services. “Personal Information” means information that identifies or is reasonably capable of identifying an individual, directly or indirectly, and information that is being associated with an identified or reasonably identifiable individual.

Personal Information That We Collect Directly From You

Upper Partners collects the following categories of information directly from individuals through the Site or Services depending on your use of the Services:

Category of Personal Information

  • First Name

  • Last Name

  • Phone Number

  • Email Address 

  • Physical Address

  • Social Security Number

  • IP Address

  • Browsing History

  • Transaction History

  • Content of Any Message sent to Upper Partners from the Upper Partners Site

  • Company Name or DBA

  • Company Address

  • Company Telephone Number

  • Company Email Address

  • Company Website URL

  • Company Employment Identification Number (EIN) (Tax Information in other jurisdictions or any type of federal identification, such as an ITIN)

  • Bank Name

  • Bank Address

  • Bank Account Number

  • Bank Account Routing Number

  • SWIFT Number (International)

  • W-2 Form

  • IRS Form 9411 (includes first name, last name, signature, and phone number)

  • IRS Form 941-X

  • Profit and Loss Statement 

  • Payroll Ledgers

  • PPP Loan Application Information

  • 1065 Federal Tax Document(s)

  • Form 1040 (includes full names, social security numbers, physical addresses, and other personal information of the filer, spouse, and/or dependent)

  • Corporate, Personal, or Entity State Tax Document(s)

  • Corporate, Personal, or Entity State Tax Return(s)

  • Form 1120 or Form 1120S

  • Email Communications

  • User Support Communications

  • Any Attachments Attached to an Email Communication or Other User Support Communication

How We Use the Information We Collect

For the general Internet user and potential User, the Personal Information we collect and the practices described above are undertaken in an effort to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve Upper Partners’’ offerings. We may use your Personal Information to:

  • Provide You with Upper Partners Services. Upper Partners uses your Personal Information to provide you with its Services and Site pursuant to its Terms of Use for the Site and this Privacy Policy.

  • Comply with Legal and Regulatory Requirements. Upper Partners processes your Personal Information as required by applicable laws and regulations. 

  • Protect the Security and Integrity of Our Site. Upper Partners uses your Personal Information to further our security practices related to Personal Information. 

  • Provide You with User Support. Upper Partners processes your Personal Information anytime that you reach out with issues arising from your use of the Site.

  • Optimize and Enhance Our Services. Upper Partners uses your Personal Information to understand how our Site is being used to help us improve our Site.

  • Market Our Services to You. Upper Partners may contact you with information about our Services. We will only do so with your permission, which can be revoked at any time.

  • Other Business Purposes. Upper Partners may use your information for additional purposes if that purpose is disclosed to you before we collect the information or if we obtain your consent.

For our Users, we may use the Personal Information we collect or receive through the Service (alone or in combination with other data we source) for the purposes and on the legal bases identified below:

  • To perform our contract with you for use of the Services or where we have not entered into a contract with you, in accordance with our legitimate interests to operate and administer our Services. 

  • To enforce compliance with our contractual obligations and applicable law, and to protect the rights and safety of our Users in reliance on our legitimate interest to protect against misuse or abuse of our Services and to pursue remedies available. 

  • To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.

  • To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements in reliance on our legitimate interests.

  • To prosecute and defend a court, arbitration, or similar legal proceeding.

  • To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.

  • To provide, support, and improve the Services to perform our contract with you for the use of the Services or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and improving the Site and Services and providing certain features. When we share your Personal Information with third parties, we take steps to protect your information in a manner that is consistent with our obligations under applicable privacy laws.

  • To combine and anonymize data about our Users and our Users’ use of the Services in order to create aggregate, anonymized statistics, which we may use to provide certain features within the Services and for promoting and improving the Services in reliance on our legitimate interests

How We Share the Information We Collect

Upper Partners will not share your Personal Information with third parties, except as described below.

  • Third-Party Service Providers and Vendors. Upper Partners may share your Personal Information with third-party service providers for business or commercial purposes. Your Personal Information may be shared so that they can provide us with services, including identity verification, fraud detection and prevention, security threat detection, payment processing, User support, data analytics, Information Technology, advertising, marketing, data processing, network infrastructure, storage, transaction monitoring, and tax reporting. Upper Partners shares your Personal Information with these service providers only so that they can provide us with their services, and we prohibit our service providers from using or disclosing your Personal Information for any other purpose. Our third-party service providers are subject to strict confidentiality obligations.

  • Law Enforcement. Upper Partners may be compelled to share your Personal Information with law enforcement, government officials, and regulators.

  • Corporate Transactions. Upper Partners may disclose Personal Information in the event of a proposed or consummated merger, acquisition, reorganization, asset sale, or similar corporate transaction, or in the event of a bankruptcy or dissolution.

  • Professional Advisors. Upper Partners may share your Personal Information with our professional advisors, including legal, accounting, or other consulting services for purposes of audits or to comply with our legal obligations.

  • Consent. Upper Partners may share or disclose your information with your consent.

If Upper Partners decides to modify the purpose for which your Personal Information is collected and used, we will amend this Privacy Policy.


When you access the Upper Partners’ Site, we may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (“Cookies”) on your computer or other devices used to visit the Upper Partners Site. We use Cookies to help us recognize you as a User, collect information about your use of the Upper Partners Site to better customize our Services and content for you, and collect information about your computer or other access devices to assess and improve our Site and Services.

The purposes for which Upper Partners uses Cookies in its Site include:



Website Functionality Cookies

These cookies allow you to navigate the Upper Partners Site and use Upper Partners Site and Service features.

Website Analytics

These cookies allow Upper Partners to measure and analyze how our Users use the Site, to improve the Upper Partners Site functionality, and enhance your user experience.

Please note that if you reject cookies, you will not be able to utilize some or all of the features of the Upper Partners Site. If you do not consent to the placing of Cookies on your device, please do not visit, access, or use the Upper Partners Site. 

Your Privacy Rights - General Information

Upper Partners is required under certain United States domestic data laws to provide certain information to individuals about how Upper Partners collects, uses, and shares your Personal Information, and about the rights and choices that you may have concerning your Personal Information. The following sections provide an overview of the Personal Information that Upper Partners collects, uses, and shares, outlines the rights that you have concerning your data, and the actions that you can take to make certain requests concerning your Personal Information.

Personal Information That Upper Partners Collects, Uses, and Shares

For ease of reference, we have compiled the list below to demonstrate how we use the categories of Personal Information we have collected, used, and disclosed. The purposes for the collection, use, and sharing of information include: [Open PDF] 

Information for Nevada Residents

Nevada law (SB 220) requires website operators to provide a way for Nevada consumers to opt out of the sale of certain information that the website operator may collect about them. Upper Partners does not sell your personal information to third parties as defined in Nevada law, and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. If you have any questions regarding our data privacy practices or our compliance with Nevada data privacy law, please contact us at

Retention of Data

Upper Partners retains Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, Upper Partners refer to these criteria in order to determine retention period:

  • Whether we have a legal or contractual need to retain the data;

  • Whether the data is necessary to provide our Services or Site; and

  • Whether our Users would reasonably expect that we would retain the data until they remove it or until their accounts are closed or terminated.

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

Children's Privacy

Upper Partners’ Site is not intended for general audiences and is not directed to children under 17. We do not knowingly collect Personal Information from children under 17 through the Site. If you become aware that a child has provided us with Personal Information without parental consent, please contact us at If we become aware that a child under 17 has provided us with Personal Information without parental consent, Upper Partners takes steps to remove such information.


No security is foolproof, and the Internet is an insecure medium. We cannot guarantee absolute security, but we work hard to protect Upper Partners and you from unauthorized access to or unauthorized alteration, disclosure, or destruction of Personal Information that we collect and store. Upper Partners addresses its guarantees as to privacy and security in the various agreements and data processing addendum that it enters into contractually with its Users.

Third Party Applications and Integrations Used by Upper Partners

The Upper Partners Site uses third-party applications and integrations to enhance its User service experience. Upper Partners disclaims any and all liability and responsibility for the use of these applications and integrations, and encourages you to review their individual privacy policies before using the Upper Partners website or otherwise engaging with Upper Partners:

The Upper Partners Site contains links to the social networks Facebook, Instagram, Twitter, and YouTube. Upper Partners disclaims any and all liability and responsibility for your use of these sites, but encourages you to review their individual privacy policies before your use of these sites:

Updates to This Privacy Policy

Upper Partners may revise this Privacy Policy from time to time. If Upper Partners makes material changes to this Privacy Policy, we will notify you by email or by posting a notice on our Site prior to or on the effective date of the changes. By continuing to access or use the services after those changes become effective, you acknowledge the revised Privacy Policy.

Contact Information

If you have questions or concerns regarding this policy or our processing of your Personal Information, please feel free to contact Upper Partners through the following:



Upper Partners

1521 E. Orangethorpe Ave. Suite A

Fullerton, CA 92831

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