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Upromise TurboSaver™ Privacy Statement

Last Updated: August 22, 2010

Key Points

TurboSaver is a web browser software application (commonly known as a "toolbar"), which is administered by a third party toolbar provider. These "Key Points" highlight some of the important information in the Privacy Statement, and provide links to the relevant sections in the Statement. You should read the entire Privacy Statement, which follows, before downloading TurboSaver and/or enabling the Personalized Offers feature, if offered. If you do not accept this Privacy Statement, do not download TurboSaver or any of its features.

  1. Upromise Privacy Statement and TurboSaver Privacy Statement

    The Upromise Privacy Statement describes the types of personal information we obtain about you in connection with the Upromise Service generally, and how we use and share that information, including information obtained when you use TurboSaver. This TurboSaver Privacy Statement supplements the Upromise Privacy Statement and describes the types of personal information we may obtain about you if you download the TurboSaver toolbar and how we use and share that information. It also describes the information we obtain, and how we use and share that information if you activate Turbosaver's optional "Personalized Offers" feature, which Upromise may make available to you. In the event of any inconsistency between the Upromise Privacy Statement and this TurboSaver Privacy Statement, this Privacy Statement will govern. If you download and/or use TurboSaver, this TurboSaver Privacy Statement applies to you. This Privacy Statement may change from time to time, so you should check back frequently for any updates.

  2. Information Collected by TurboSaver Toolbar
    1. General

      If you download TurboSaver we will collect certain information when your browser is open. As described more fully in this Privacy Statement, we collect this information for a number of reasons, including to improve TurboSaver features and functionality and starting with TurboSaver Version 7.0 and above, to help us understand how often individual Upromise partners are visited and/or appear in search results.

      When we say information is collected by TurboSaver, we mean that it is collected by the TurboSaver application on your computer and then transmitted over the public Internet to the toolbar provider and/or in some cases to Upromise, either directly or through the toolbar provider.

    2. When you download TurboSaver, one or more pieces of code, commonly referred to as a "cookie," is placed on your computer or hard drive and you are assigned a unique ID (the "TurboSaver ID"), which may identify you personally to Upromise.

      When you download TurboSaver, and at times during your use of TurboSaver, Upromise places "cookies" on your computer or hard drive. Cookies are small text files containing unique alphanumeric identifiers that enable Upromise's systems to recognize your browser and apply your TurboSaver settings.

      You are assigned a TurboSaver ID when you download the toolbar. Upromise can use the TurboSaver ID to identify you personally. The toolbar provider cannot use the TurboSaver ID to identify you personally, but may have information from another source which would allow it to personally identify you.

      In order to realize all the benefits of TurboSaver, your browser has to be set to accept cookies. If your browser is set not to accept cookies, Upromise cannot reward you for qualified online purchases. You should be aware that even if your browser is set not to accept cookies when you download TurboSaver, Upromise and our toolbar provider may continue to collect the information described in this Privacy Statement. This information may be associated with you if you subsequently set your browser to accept cookies. By not accepting cookies or clearing your cookies, you will not be uninstalling or disabling TurboSaver. To see how to uninstall TurboSaver, click here.

    3. TurboSaver collects and transmits information about your Internet browser, your Installation of TurboSaver and your TurboSaver settings to improve the product and help you get the most out of it.

      1. When you first download the toolbar, and after that whenever you update or uninstall the toolbar, open a web browser session using the toolbar, change your settings or perform similar activities, TurboSaver collects and transmits certain information about your Internet browser and your TurboSaver settings. This information, which we call "Event Information," includes your TurboSaver ID, the Internet browser (including the version and subversion) you are using (e.g., Internet Explorer or Firefox), and information about your TurboSaver settings such as whether you have the toolbar in full or hidden mode and whether you have the Personalized Offers feature turned on. Upromise can use the TurboSaver ID to identify you personally. The toolbar provider, however, cannot use the TurboSaver ID to identify you personally.

        We use Event Information to understand which TurboSaver features users like, and which features could benefit from improvement, based on how the features are used. We may also use Event Information to diagnose and address technical issues with TurboSaver.

      2. When you are on a Upromise website or a Upromise-designated website of one of our corporate affiliates, TurboSaver collects and transmits information about your installation of TurboSaver and your TurboSaver settings. We call this information "Custom Log Information" and it includes the TurboSaver version installed on your computer along with information about your TurboSaver settings (for example, whether it is in full or hidden mode, whether the display savings balance feature is turned on, whether you have TurboTips turned on, the period of time you have your notification bar set to display, or whether the Personalized Offers feature is turned on). It also includes your TurboSaver ID, the date you installed the toolbar, the web page from which you downloaded the toolbar, the marketing piece which prompted installation, a reference number to track the version of that marketing piece, and your first name. We use this Custom Log Information to provide TurboSaver and improve your TurboSaver experience, which may include suggesting ways in which you may optimize your use of TurboSaver. For example, if we learn from Custom Log Information that your TurboSaver is running in hidden mode that web page could display to you a helpful message about how to put your version of TurboSaver into full mode and explain the benefits of the full mode feature. Based on your Custom Log Information, we may also send you a TurboTip or other message to suggest ways in which you may better use TurboSaver, or may prompt you to upgrade your TurboSaver to a newer version if you are using an older version.

    4. In TurboSaver Version 7.0 and above, TurboSaver collects and transmits information to let us know when you visit Upromise partner websites, when a link to a partner website or any restaurant appears in your search results, and your use of TurboTips, each of which may be associated with your TurboSaver ID. To see how to determine what version of TurboSaver you are running, click here.

      To help us understand how often individual Upromise partners are visited and/or appear in search results so that we may optimize your use of TurboSaver, which may include by targeting college savings and other opportunities to you based on this information, when you use TurboSaver Version 7.0 and above, TurboSaver collects and transmits the following information about your online activities, which may be associated with your TurboSaver ID:

      1. When you visit any Upromise partner web site, TurboSaver collects and transmits the domain name of the web site.
      2. When you use search engines such as Google or Yahoo! to do a web search, TurboSaver collects and transmits the domain name of any Upromise partner that appears in the search results.
      3. When you use certain search engines such as Yelp or Citysearch to search in their restaurant categories, TurboSaver collects and transmits restaurant detail text portions of the web page restaurant search results to see if the search results contain Upromise partner restaurants.
      4. TurboSaver's TurboTips feature may suggest ways that you can get the most out of TurboSaver. TurboTips may be shown to you based on your TurboSaver settings and other information we learn about you. TurboSaver collects and transmits information about the TurboTips delivered to you and information about your interaction with those suggestions, such as whether or not you clicked on a link presented in a TurboTip.
    5. TurboSaver collects and transmits information about whether and how you interact with the toolbar, and this information may be associated with your TurboSaver ID.

      TurboSaver collects and transmits information about what you click on in TurboSaver's "Options" menu or on any of the icons in the toolbar. We use this information to provide TurboSaver to you, improve TurboSaver and its features, and improve your TurboSaver experience. For example, we may show you a TurboTip to suggest ways in which you may better use TurboSaver.

  3. When you enable and use the Personalized Offers feature, if offered, TurboSaver collects and transmits information about the web sites you visit and your activities on those sites, which may include ads you see, data you enter into web forms, searches you run and purchases you make, all of which may be associated with your TurboSaver ID.

    Upromise may offer a Personalized Offers feature for TurboSaver Version 7.0 and above. If it does, the feature will be completely optional, and will not be enabled unless you specifically choose to do so. If you do choose to enable TurboSaver's Personalized Offers feature, TurboSaver collects and transmits information about your online activities, whether or not you are on a Upromise partner site, to present targeted college savings or other opportunities to you that may be especially relevant to you. The Personalized Offers feature in any version of TurboSaver prior to TurboSaver Version 7.0 has been disabled, whether or not you have it set to "enable" or "disable."

    For purposes of this Privacy Statement, online activity means information about the web pages you visit, including those designated as secure web pages by a locked padlock icon in Internet Explorer or FireFox. This may include the web site addresses (including the full URL) of the web pages you visit, certain data you enter in online forms and search fields, products placed in online shopping carts or actually purchased, information you give when completing an application form or checking your online accounts, certain advertisements or videos that you view, and similar information.

    For the Personalized Offers feature, Upromise requires the toolbar provider to use industry standard methods to prevent collection and transmission of personally identifiable information (e.g., information that is unique to you and may be used to identify you, such as last name, email and postal addresses, credit card numbers, social security numbers, user names, passwords or IDs, excluding your TurboSaver ID). These methods include employing a "blacklist" of identifiers that indicate data fields that may never be collected (e.g., "login," "date of birth," or "member name"). The methods also include employing a "whitelist" of identifiers that indicate data fields that may be collected and transmitted (e.g., "model," "brand," or "product id").

    You should be aware, however, that due to inconsistencies in the ways web sites identify data fields, it is possible that when the Personalized Offers feature is enabled, TurboSaver may collect and transmit personally identifiable information, including potentially sensitive data. While neither Upromise nor its toolbar provider intends to collect or use this kind of personally identifiable information, there will likely be instances when this information will be inadvertently collected or transmitted. Upromise will never use this kind of personally identifiable information, and we prohibit the toolbar provider from doing so.

    If you do not agree to inadvertent collection of personally identifiable information as described above, do not turn on the Personalized Offers feature. If you want to turn off the Personalized Offers feature, select "Options" in the TurboSaver menu and disable the feature.

  4. Information collected and transmitted by TurboSaver is used for a variety of purposes

    Upromise may use the information collected and transmitted by TurboSaver for the following purposes:

    • To help us maintain and operate the TurboSaver toolbar.
    • To help us better understand how users use TurboSaver, which helps us improve its features and functionality.
    • To help us understand how often individual Upromise partners are visited and/or appear in search results.
    • To help you optimize your use of TurboSaver.
    • To help us better target college savings opportunities and other content to you in an effort to create a personally relevant experience. For example, if you have installed TurboSaver Version 7.0 or above, we may use information about the partner websites you visit to provide you special offers. In addition, if you enable the Personalized Offers feature, you may be eligible to receive college savings or other opportunities based on your online activity, as described in Section 3 above. Upromise may also combine this information with personally identifiable information Upromise may separately have about you as a Upromise member, such as your individual transaction information, to assist with targeting offers to your preferences.
    • To help us formulate and predict responses to various marketing campaigns, and to deliver and help determine the effectiveness of various marketing campaigns.
    • To help us support you when you contact Upromise customer care.
  5. How Collected Information is Shared

    TurboSaver generally collects and transmits the information described in this Privacy Statement to our toolbar provider. Our toolbar provider uses the information collected and transmitted by TurboSaver to help us provide services to you. For example, if you enable Personalized Offers, our toolbar provider may facilitate the presentation to you of advertisements, promotions or surveys based on your online activity. Whether you take advantage of any such advertisement or promotion or participate in any such survey is completely up to you.

    The toolbar provider may also use non-personally identifiable information collected and transmitted by TurboSaver for research about the online behavior of Internet users. The research, which is provided to Upromise and other unrelated third parties, includes aggregated data only, and never identifies any user specifically.

    Upromise may share non-personally identifiable information collected and transmitted by TurboSaver with unaffiliated third parties, including for example our partner companies to formulate, predict responses to, deliver and determine the effectiveness or value of various savings or other opportunities. We may also provide aggregated, non-personally identifiable information about TurboSaver users to these third parties for audit, marketing and other purposes. Upromise may share information with affiliates of our parent corporation Sallie Mae, in accordance with the Upromise Privacy Statement.

  6. Security and Encryption

    The privacy and security of any information collected and transmitted by TurboSaver is very important to us. Upromise uses the following features and technologies to help safeguard your information:

    • Encrypted Transmission. Upromise requires its toolbar provider to cause TurboSaver to transmit Event Information, all information collected in connection with the Personalized Offers feature, and web service calls (such as those required to display account balance, coupons or the restaurant search overlay) using encryption.
    • Restricted Access. Upromise has implemented policies and procedures designed to protect against unauthorized access to or unauthorized disclosure of data collected by TurboSaver.

    When you turn on the "Display Savings Balance" feature in TurboSaver, your Upromise account balance may be visible on the toolbar whether or not you are logged in to your Upromise account. If you are using a shared or public computer and do not wish to have your savings seen by other users, you should clear your browser of any cookies to prevent your Upromise balance from being shown unintentionally.

  7. Settings

    To view or change your TurboSaver settings, choose "Options" in your TurboSaver menu.

  8. Version

    In order to determine what version of TurboSaver you have, choose "About" in the TurboSaver menu and the version number of your TurboSaver application will be displayed.

  9. Uninstalling TurboSaver

    To uninstall TurboSaver, see the TurboSaver Frequently Asked Questions. When you uninstall TurboSaver, Event Information for the uninstall event will be sent to Upromise. If you need additional assistance, please contact Upromise Customer Care.

  10. Use of Information after Uninstalling

    Please note that Upromise or its toolbar provider may continue to use information collected from your TurboSaver application which was collected prior to your uninstallation of TurboSaver, but all such information remains subject to the TurboSaver Privacy Statement in effect at the time of uninstallation.

  11. Additional Information

    For additional general information about TurboSaver, see the TurboSaver Frequently Asked Questions.

    For additional information about Upromise's privacy policies, see the Upromise Privacy Statement.

©2010 Upromise, Inc.