Privacy Policy

Last updated: October 6, 2026 · UPI Globale Edu Inc. · Ontario, Canada

1. Who we are

TransferCredit.org (the "Site") is owned and operated by UPI Globale Edu Inc., a company based in Ontario, Canada ("we", "us", "our"). This Privacy Policy explains how we collect, use, share and protect personal information when you visit the Site, create an account, buy or take a course, use our tools (such as Find My College, the Degree Planner and practice tests), chat with Iris, book a consultation or contact us (together, the "Services").

We are responsible for the personal information under our control. Our Privacy Officer oversees our compliance with this policy and can be reached at [email protected].

TransferCredit.org is an independent company. We are not owned by, part of, or affiliated with UPI Study, College Board, Prometric, the American Council on Education (ACE) or NCCRS. When you deal with any of them directly, for example to register for a CLEP® or DSST® exam or to take a UPI Study course, their own privacy policies apply.

This policy should be read with our Terms of Use.

2. Information we collect

Information you give us

• Account details: your name, email address and password. Passwords are stored by our course platform in protected (hashed) form, and we can't see them.
• Purchase details: your billing name, country and postal code, what you bought, and the price and date. Card and PayPal details are handled by our payment processors (see Section 5).
• Contact details you choose to share: for example a phone number, if you give one for text messages or support.
• What you enter in our tools: such as the college you look up, your degree goals, credits you plan to earn, and your practice test answers and results.
• Iris chat messages: what you type to Iris (see Section 4).
• Consultation bookings: your name, email, the time you book and any answers you give on the booking form.
• Messages and feedback: emails, support requests, reviews, testimonials and survey answers.

Information collected when you use the Services

• Learning data: the courses you're enrolled in, your progress, quiz and practice exam scores, and when you log in.
• Device and usage data: your IP address, browser and device type, operating system, language, referring page, pages you view, links you click, and the date and time of your visit. Approximate location (city or region) may be inferred from your IP address.
• Interaction data from analytics tools: mouse movements, clicks, scrolling and page interactions. These tools can create session recordings and heatmaps. Payment and password fields are masked and not recorded.
• Cookies and similar technologies: see Section 6.

Information from others

• Payment processors: confirmation that a payment succeeded or failed, and fraud-prevention signals.
• Partners and centers: if you enrolled through an authorized center or reseller, or take an ACE- or NCCRS-recommended course provided by our partner UPI Study, we may receive your enrollment and course-completion details from them.

Please don't send us sensitive information we haven't asked for, such as a Social Insurance or Social Security number, health information, financial account numbers or government ID.

3. How we use your information

• To provide the Services: create and manage your account, process payments, give you access to courses, track your progress, run our tools and Iris, and deliver what you bought.
• To support you: answer questions, handle consultations, and resolve billing or access problems.
• To communicate with you: send receipts, account and course notices, and (with your consent where the law requires it) news and offers. See Section 7.
• To improve the Services: understand how the Site and courses are used, fix errors, test new designs, and check that Iris's answers are accurate.
• To keep the Services safe: prevent fraud, abuse, chargeback misuse and unauthorized access, and protect our rights and the rights of others.
• To meet legal obligations: keep tax and accounting records, respond to lawful requests, and enforce our Terms of Use.

We collect and use personal information with your consent, which may be express (for example, ticking a box) or implied (for example, providing your email to receive a receipt), or as otherwise permitted or required by law. Where the EU or UK General Data Protection Regulation applies, our legal bases are: performing our contract with you, our legitimate interests in running and improving a safe service, your consent (for example, for marketing or non-essential cookies), and complying with legal obligations.

We do not make decisions that have a legal or similarly significant effect on you based solely on automated processing.

4. Iris, our AI assistant

Iris is the chat assistant on the Site. It answers questions about exams, credit and our courses, and it can suggest a study or degree plan. Iris is a computer program, not a person and not an academic advisor. It can make mistakes, and its answers are general information, not academic, legal or financial advice. Always confirm credit policies with your college's registrar.

• How it works: when you send a message, the conversation so far is sent to our server (hosted on Cloudflare) and then to Anthropic, the AI provider that generates Iris's replies. Anthropic processes messages to produce the reply, as our service provider.
• What Iris receives: only what you type, plus the page you're on. Iris does not need your name, email or account details. Please don't share sensitive information in the chat.
• Conversation records: we may keep a record of conversations to review answer quality, correct wrong answers and improve Iris. A record contains the messages, the page, the time and a random session ID. Iris does not store your IP address, does not set cookies, and does not link the conversation to your account. Records are deleted automatically after 90 days, unless we need to keep a specific conversation longer to investigate a security or legal issue.
• In your browser: Iris keeps the conversation in your browser's session storage so it doesn't disappear when you change pages. It is cleared when you close the tab.
• No training on your chats: we don't sell chat messages or use them to train AI models. Under its commercial terms, our AI provider doesn't use them to train its models either.

You can use the Site without using Iris. To ask us to delete a conversation, email us with the approximate date and time and the page you were on, so we can find it.

5. Who we share your information with

We do not sell your personal information. We share it only as described here.

Service providers

These companies process information on our behalf, under contracts that limit their use of it to providing their services to us.

Provider	What they do for us
Thinkific	Hosts the Site, your account, courses and checkout
Stripe and PayPal	Process payments and help prevent fraud. They receive your payment details directly, under their own privacy policies.
Cloudflare	Delivers and protects the Site, and runs Iris and our tools
Anthropic	Generates Iris's replies (see Section 4)
Google	Google Analytics (site analytics) and reCAPTCHA (spam and bot protection)
Microsoft	Microsoft Clarity (heatmaps and session recordings)
Calendly	Consultation scheduling
Email and SMS providers	Sending emails and, if you opt in, text messages

Partners and others

• UPI Study: some plans include ACE- or NCCRS-recommended courses provided by our partner UPI Study, a separate company. When you use one, we share the details needed to enroll you and support your course (such as your name, email and the course). UPI Study handles that information under its own privacy policy, and it issues its own transcripts.
• Authorized centers and resellers: if you enrolled through one, we may share your enrollment and progress details with that center so it can support you.
• Colleges and credit organizations: only when you ask us to, or when it's needed to complete something you requested.
• Legal and safety: when the law requires it, or to protect our rights, our users or the public, for example to prevent fraud.
• Business changes: if our business is sold, merged or reorganized, your information may be transferred to the new owner, who must continue to protect it as described here.
• With your consent: in any other case where you agree.

6. Cookies and tracking

Cookies are small files stored on your device. We and our providers also use similar technologies, such as pixels, local storage and session storage.

Type	Why we use it	Examples
Essential	Sign-in, checkout, security and keeping the Site working. These can't be switched off.	Thinkific, Stripe, PayPal, Google reCAPTCHA, Cloudflare
Analytics	Understanding how the Site is used, including heatmaps and session recordings	Google Analytics, Microsoft Clarity
Functional	Remembering your Iris conversation during your visit, and social sharing features on course pages	Iris (session storage), Facebook sharing features
Advertising	If we run ads, measuring them and showing our ads to people who visited the Site	Google, Meta

Your choices: you can block or delete cookies in your browser settings, but some parts of the Site, such as sign-in and checkout, may then stop working. You can opt out of Google Analytics with Google's browser add-on. You can manage ad personalization in your Google and Meta settings. Where the law requires it, we will ask for your consent before setting non-essential cookies.

7. Emails and text messages

• Service messages: we send receipts, account and security notices, and messages about courses you're enrolled in. These are needed to provide the Services, so you can't opt out of them while you have an account.
• Marketing emails: we send news and offers only where we have your consent, such as when you tick "Keep me up to date" at checkout, or where the law allows it based on a recent purchase or inquiry. Every marketing email has an unsubscribe link.
• Text messages: we send marketing texts only if you opt in to receive them. Reply STOP to opt out, or HELP for help. Message and data rates may apply. Agreeing to texts is never a condition of a purchase.

8. Where your information is processed

We are based in Canada, and our service providers process information in the United States and other countries. Your information may therefore be stored or processed outside your province, state or country, where it may be accessible to courts, law enforcement and national security authorities under local law. Where required, we use contractual safeguards for international transfers, such as standard contractual clauses for information from the EU or UK.

9. How long we keep it

• Account and learning data: while your account is open, and for a reasonable period afterwards in case you return or there's a dispute.
• Purchase and tax records: as long as tax and accounting laws require (in Canada, generally six years).
• Iris conversation records: up to 90 days (see Section 4).
• Analytics data: according to each tool's retention settings.
• Marketing contact details: until you unsubscribe, after which we keep a record of the opt-out so we respect it.

When information is no longer needed, we delete it or make it anonymous.

10. Security

We use reasonable administrative, technical and physical safeguards that fit the sensitivity of the information. These include encrypted connections (HTTPS), access controls, payment processing by PCI-compliant providers, and limiting access to staff and providers who need it. No system is completely secure, though, so we can't guarantee absolute security. If a breach of security creates a real risk of significant harm to you, we will notify you and the relevant regulators as the law requires. Keep your password private, and tell us right away if you think your account has been misused.

11. Your rights and choices

Depending on where you live, you may have the right to:

• Access the personal information we hold about you, and learn how it's been used and shared
• Correct information that is inaccurate or incomplete
• Delete your information, subject to legal exceptions such as tax records
• Withdraw consent, subject to legal or contractual limits. If you withdraw consent to information we need to run your account, we may no longer be able to provide the Services.
• Object to or restrict certain uses, and receive a copy of your information in a portable format (EU/UK)
• Opt out of the "sale" or "sharing" of personal information, or of targeted advertising (certain US states). We don't sell personal information. Where required, we treat a Global Privacy Control browser signal as an opt-out request.
• Not be discriminated against for exercising your rights

How to make a request: email [email protected] with the subject "Privacy request". We may need to verify your identity before we respond, and an authorized agent can make a request on your behalf with proof of authority. We respond within 30 days, or within the time the law allows if we need longer and tell you why.

Complaints: if you're not satisfied with our response, please tell us so we can try to fix it. You can also complain to the Office of the Privacy Commissioner of Canada (priv.gc.ca), to the Commission d'accès à l'information if you live in Quebec, or to your local data protection authority if you live in the EU or UK.

12. Children

The Services are not directed to children under 13, and we do not knowingly collect personal information from them. Users under 18, or under the age of majority where they live, may use the Services only with the consent and supervision of a parent or guardian. If you believe a child under 13 has given us personal information, contact us and we will delete it.

13. Other websites

The Site links to websites we don't control, such as College Board, Prometric, UPI Study, colleges and payment providers. Their own privacy policies apply when you use them, and we are not responsible for their practices.

14. Changes to this policy

We may update this policy from time to time. The "Last updated" date at the top shows when it last changed. If we make a material change, we will tell you by email or with a notice on the Site before it takes effect, and we will ask for your consent where the law requires it.

15. Contact us

Privacy Officer, UPI Globale Edu Inc. (TransferCredit.org)
Ontario, Canada
Email: [email protected] (subject: "Privacy request")

CLEP® is a registered trademark of College Board. DSST® is a registered trademark of Prometric. ACE® and ACE CREDIT® are registered trademarks of the American Council on Education. NCCRS is a program of the Board of Regents of the University of the State of New York. TransferCredit.org is independent of all of them and of UPI Study.