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Upromise Privacy Policy Last updated 5/1/2014

This policy covers Upromise, Inc.'s practices relating to the information it collects from or about its current and past members, website visitors and users of its mobile applications, including your rights to limit the sharing of certain information we may have about you. References in this policy to the Upromise website include any mobile websites we may operate. Our affiliates, including our subsidiaries, have separate privacy policies.

This privacy policy applies to the Upromise service, the Upromise website, and our mobile applications. We do not exercise control over any other websites or services made available to you through the Upromise service, such as those of our participating companies. These sites and services may place their own cookies or other files on your computer, collect data or solicit information from you. We are not responsible for the actions or practices of these third parties. In addition, certain portions of the Upromise service, including sites, applications, programs, toolbars and utilities, may be operated by third parties, and your participation in those portions of Upromise may be subject to additional privacy policies provided by Upromise and/or the privacy policies of the third parties that operate them. If a portion of the Upromise service is subject to the privacy policy of a third party, we will disclose that and provide a link to the third party's privacy policy. We encourage you to review their policies carefully. Your use of the Upromise websites, services, applications and utilities operated by third parties may be subject to separate privacy policies and your use will constitute your consent to those separate policies. In the event of any conflict between this privacy policy and any such other privacy policy, the other privacy policy will govern only with respect to the applicable services covered by such other privacy policy. We also work with third party advertisers and may make available third party applications, both of which, to the extent permitted by applicable law, may collect information about you and/or your online activities over time and across different websites and mobile applications (collectively referred to as "Sites"), including the Upromise Sites, and are further described below in the section below titled "Third Party Advertisers and Third Party Applications and Services."

Information We May Obtain

As part of providing you products or services, we may obtain information about you from various sources, including the following:

Information you provide. We obtain information you provide to us when you join Upromise, that you otherwise enter through our website or mobile applications, or that you provide to us in writing or by telephone, such as when you contact our customer care staff. This information may include items such as your name, address, mobile device ID (UDID), telephone number, location, social security number, credit card numbers and/or other financial account information such as student loan, savings account and/or 529 college savings account numbers. If you give Upromise your current physical location, for example, when you use a Upromise mobile application or give us your current ZIP code, we may use and store that information to provide you with location-based information or messaging, including, for example, offers or advertising. If you do not want to give Upromise your location, do not enter your current location on our website or mobile applications and do not allow your browser or mobile device to send it to us. Please also see the section titled "Log information" below for information we receive automatically when you visit our website or use our mobile applications.

Information from third parties. We may obtain information about you from third parties including Upromise participating companies, our affiliates, public sources and others. This information could include, among other things, information about your purchases with Upromise participating companies, information about your transactions and account activity with us, our affiliates and others, your location if you allow your browser and/or mobile device provider to send it to us, your mobile device ID, publicly available demographic data, and information needed to comply with regulatory requirements, ensure the accuracy of data, better understand your likely interests, and/or prevent fraud.

Cookies and other technologies. When you visit the Upromise website or open a Upromise e-mail, we send one or more cookies to your computer or other device. We also use other similar technologies such as tracking pixels, tags or similar tools when you visit our website, open a Upromise e-mail, or use our mobile applications. These technologies can collect data regarding your operating system, browser type, device type, mobile device ID, screen resolution, IP address and other technical information, as well as navigation events and session information as you interact with our website or mobile applications. Among other things, this information allows us to understand how you use the Upromise service, website and mobile applications and what products and services may be of interest to you. The cookies we place can also be used to allow the advertising networks we work with to set and read their own cookies and collect similar information. Please see the section titled "Third Party Advertisers and Third Party Applications and Services" below for more information about our use of third party advertisers. You can generally remove, block, or disable cookies using the settings in your web browser. However, if you remove the cookies we place, it will impact your ability to use Upromise since you will be unable to enroll or log in to our service through our website. You will, however, be able to browse our website as a visitor. If you are a member of Upromise, information collected using cookies or similar technologies may be associated with personally identifiable information, such as name and e-mail address, we have about you.

One of the service providers we may use to track and analyze usage of our website and mobile applications is Omniture by Adobe, a third party analytics company. Omniture by Adobe uses our cookie and log information (described below), in combination with personally identifying information we may provide, such as name and e-mail address, to assist us in tracking Upromise website and mobile application usage in order to improve them and our products and services offerings. Omniture acts as our agent, and is authorized to use the information we share exclusively to provide this service to Upromise. For further information, including how to opt out, consult Omniture's privacy policies at: http://www.omniture.com/en/privacy/2o7.

Log information. When you access a page of the Upromise Sites via a browser, application, other client or device, our servers automatically record certain information known as "log information." This may include information such as the web page you are coming from or going to, terms you search, pages you view on a Upromise website or mobile application, your interaction with a website, application or online service provider, your Internet Protocol address, mobile device ID or telephone number, browser type, browser language, device type, and data contained in one or more cookies that may uniquely identify your browser, your computer, your device and/or your Upromise account. This information is logged by our web servers, allowing us to deliver services or information you have requested, better understand user behavior on our websites and applications, assist in troubleshooting problems, and improve the quality of our service. Please be aware that in some cases your internet protocol address could be used to determine your general location.

How We Use Your Information

We use the information we obtain in order to develop, offer, deliver and improve our products and services, to offer products and services of our affiliates, participating companies, marketing partners and other companies, to process transactions in your accounts, to fulfill legal and regulatory requirements, and as otherwise permitted by applicable law. For example, we may use the information to:

  • Operate the Upromise Sites and services;
  • Deliver products and services to people who use our Sites and services;
  • Understand how visitors use our Sites, and determine whether the content on them is effective;
  • Improve our websites and services offerings;
  • Personalize your experience when you use our Sites and services and customize the communications and advertisements you receive from us and our affiliates and others;
  • Deliver advertisements and other information about products, services and applications offered by Upromise, our affiliates, our participating companies and others on the Upromise Sites, via email, and when you visit or use third party Sites; and
  • To let us know which emails have been opened by recipients to understand the effectiveness of our marketing and other communications and to make those communications more useful and interesting to you.

If you do not wish to receive marketing messages from Upromise, you may indicate your preferences through your account settings page after logging in to your Upromise account.

Please note that information you voluntarily post in bulletin boards, chat rooms and other online forums, such as the Upromise Community, may be viewed and used by anyone with access to those forums. Upromise is unable to control access to or use of such information. To request removal of your personal information from our bulletin board or other online forums, contact us as described below under "Contacting Upromise about this Privacy Policy." In some cases, we may not be able to reasonably accommodate your request to remove your personal information, in which case we will let you know if we are unable to do so and why.

Our Information Sharing Practices

Information about our members, former members, website visitors and mobile application users is an important part of our business. We do not share your personal information except as permitted or required by law, including as provided below:

Affiliates. We may provide personal information about you to our affiliates to the extent permitted by applicable law. Our affiliates are the family of companies controlled by SLM Corporation and include, among others, Sallie Mae Bank and Navient Solutions, Inc.

Unless you tell us not to, we may share with our affiliates all of the information we obtain about you. If you prefer that we not share with our affiliates consumer report information that we may receive about you, you may direct us not to do so by clicking on this link and providing the requested information. Please be aware that we may continue to share any other information as permitted by law.

Sharing Information with Nonaffiliated Third Parties. We do not share your personal information with nonaffiliated third parties except as permitted or required by law, including as provided below:

  • Agents and Service Providers. In order to provide our products and services, we may share personal information about you with agents and service providers located in the U.S. and in other countries to perform functions on our behalf, such as to send email and postal mail, analyze data, provide marketing services, process applications and credit card payments, and service accounts. When we use these third parties, we may disclose any of the personal information that we collect, although we give them only the personal information reasonably needed to perform the service. We contractually obligate these service providers to access and use personal information only as needed to perform their functions for us and for no other purposes.
  • Financial Services Providers. In order to make certain financial products available to you (for example, credit cards, loans or insurance), we sometimes enter into joint marketing agreements with nonaffiliated financial institutions that offer those products. We may provide these entities with any of the personal information that we collect, although we give them only the personal information reasonably necessary under the marketing agreement. We select the financial institutions we work with very carefully, and these entities are permitted to use the personal information we give them only for the specific products being offered under our contract.
  • Maintain and Service your Upromise Account. We may disclose personal information about you to third parties as reasonably necessary to maintain and service your Upromise account, including to facilitate transactions you've requested and to track and process your Upromise earnings.
  • Protection of Upromise and Others. We may disclose personal information about you to third parties when we believe such disclosure is appropriate to comply with a legal requirement, such as a law, regulation, court order, subpoena or search warrant, or in the course of a legal proceeding. We may also disclose personal information as we believe appropriate to enforce or apply our rights under our agreements (such as, for example, our Member Agreement) with third parties, including our members, and to protect the rights, property or safety of Upromise, our members and others, including exchanging information for fraud protection and credit risk reduction.
  • Business Transfers. If there is a change of control in Upromise's business (whether by merger, sale, or otherwise), our members' information could be sold as part of that transaction and your personal information potentially could be used by the purchaser. If the purchaser intends to materially change the terms applicable to your personal information, you will be notified by a notice posted on the website or in another appropriate manner and be given appropriate choices with respect to previously collected personal information.
  • With your consent. We also may share your personal information with a third party if you consent to the sharing.

Upromise does not share personal information with nonaffiliated, non-financial institutions to enable them to market their products and services directly to you. Occasionally, we engage third party service providers in the business of facilitating communications to send you information from certain participating companies, but only subject to strict confidentiality provisions that prohibit those third parties from providing your personal information to the participating companies. If we ever make the decision to share personal information with nonaffiliated third parties other than financial institutions as described above so that they may market their products and services directly to you, we will update this privacy policy and will notify you of the update by email and/or through a notice on our website at least 30 days prior to their implementation, and you will have the opportunity to opt-out of that information sharing.

Upromise may share with third parties, including nonaffiliated, non-financial institutions, information that does not personally identify individual members or visitors for any reason Upromise deems necessary or desirable.

Third Party Advertisers and Third Party Applications and Services

Some of our advertisements on third party Sites may use behavioral information (such as how you navigate to the Sites and/or your activity on our Sites) to provide relevant advertisements to you. Upromise uses third party advertising partners that may use cookies, other technologies and information about you: (i) to deliver these ads or other offers from Upromise, our affiliates, our participating companies and others on third party Sites, and (ii) to track the effectiveness of ads and other offers Upromise delivers on third party websites. These companies are authorized to use the information we provide and they collect when you navigate to a Site within the advertising partner networks to provide this service to Upromise. Each of the companies we work with participates in the Network Advertising Initiative ("NAI") or the Digital Advertising Alliance ("DAA"), or both. If you prefer not to receive these targeted ads or offers as you visit or use these Sites, you may opt-out by clicking on and following the directions contained in both the NAI opt-out link and the DAA opt-out link. Please allow up to 10 days for the opt-out to take effect. Please also note that in order for the opt-out to work your browser must be set to accept third party cookies. Furthermore, if you use a different device, change web browsers or delete the opt-out cookie, you will need to perform the opt-out task again. Please also note that if you choose to opt-out from receiving these targeted advertisements, you may still see advertisements while you're visiting or using third party Sites. However, the advertisements you see may be less relevant to you and your interests.

We also may make third party applications available for you to download. The information collected by third party application providers is governed by their privacy policies unless otherwise stated. For example, the Upromise RewardU Toolbar is provided by a third party on behalf of Upromise and is subject to a separate privacy policy which can be accessed from the webpage where you have the option to install the Upromise RewardU Toolbar application. To learn more about the information collected by the Upromise RewardU Toolbar, including how it may be used and shared, please read the RewardU Privacy Statement. In addition,the Upromise TurboSaver Toolbar is provided by a third party on behalf of Upromise and is also subject to a separate privacy policy which can be accessed from the webpage where you have the option to download the Upromise TurboSaver Toolbar application. To learn more about the information collected by the Upromise TurboSaver Toolbar including how it may be used and shared, please read the TurboSaver Privacy Statement.

Your Choice to Limit Affiliate Marketing

Federal law gives you the right to limit some but not all marketing from Upromise affiliates. Specifically, you may limit all Upromise affiliates from marketing their products or services to you based on certain of your personal information that they receive from Upromise. This information includes your income, your account history, and your credit score, in each case to the extent Upromise possesses such information and has used it, or permitted a third party to use it, for credit eligibility purposes. Your choice to limit marketing offers from all Upromise affiliates based on such information will apply for at least 5 years from when you tell us your choice. Before your choice to limit marketing expires, you will receive a renewal notice that will allow you to continue to limit such marketing offers from all Upromise affiliates for at least another 5 years. If you have already made a choice to limit marketing offers from Upromise affiliates based on the above information, you do not need to act again until you receive the renewal notice. If you wish to limit marketing by Upromise affiliated companies as described in this paragraph, you may do so by clicking on this link and providing the requested information. Your choice to limit marketing offers will not apply in certain circumstances as provided under applicable law, such as when you have an account with the Upromise affiliate that is marketing to you.

Security of Your Personal Information

Upromise is committed to earning and keeping your trust. We understand the need for our members' personal information to remain secure and private. To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. Further, only Upromise employees who have a business need to access your personal information are authorized to do so. No method of transmission over the internet nor any method of electronic storage is 100% secure. Accordingly, we cannot guarantee absolute security over your personal information.

Please remember that you also play a valuable part in data security. You should never share your Upromise password with anyone. If you feel your password has been compromised, you should change it immediately. After you have finished using our site or applications, you should log out of your Upromise account and exit your browser so that no unauthorized persons can use our site under your name and account.

How can I access and update my Upromise data?

You may access and update information stored in your account profile by visiting the Upromise site. Please keep your contact, account, and preference information up-to-date. Doing so ensures that your contributions are properly tracked and received. It also helps us inform you of Upromise savings or other opportunities.

We will retain your information for as long as you are a Upromise member and/or we reasonably deem it necessary to provide you services, comply with our legal or other obligations, resolve potential disputes, audit our records and/or enforce our rights and obligations under our agreements. If you no longer want us to use your information to provide you services, you may terminate your Upromise membership.

State Laws

In addition to the rights described in this policy, please note that you may have additional rights under state law. For example, for accounts with a California mailing address, we will not share your personal information with a financial company for joint marketing purposes except as required or permitted by law. In addition, for accounts with a Vermont mailing address, 1) we will not share your consumer report information with our affiliates except as required or permitted by law, and 2) for joint marketing with other financial companies, we will only disclose your name, contact information and information about your transactions unless otherwise required or permitted by law.

Miscellaneous

Collection of Information from Children

Upromise's products, services, applications and utilities are not intended for purchase by children. Accordingly, Upromise does not knowingly collect, either online or offline, personal information from children under the age of 13.

Changes to this Privacy Policy

Please note this privacy policy may change from time to time. If we materially change this privacy policy or our information-handling practices as described in this policy, we will notify you by email and/or through a notice on our website prior to their implementation.

Contacting Upromise about this Privacy Policy

If you have any questions about this online privacy policy, our information-handling practices, or other aspects of privacy at Upromise, please contact us by email or at Upromise, Inc., Customer Care - Privacy Policy Issues, 95 Wells Avenue, Suite 160, Newton, MA 02459.

Definitions

Cookies - A "cookie" is a small string of text that is sent to your computer or mobile device when you use our Sites. When you use our Site again, the cookie may allow that Site to recognize your browser, computer or mobile device. Cookies may also store user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some features or services on our Sites may not function properly without cookies.

Personal Information - "personal information" is information that personally identifies you to the party receiving such information, including but not limited to your name, address, email address and social security number.

Effective Date: May 1, 2014