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Information We Collect
We collect and receive 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 websites, or that you provide to us in writing or by telephone, such as when you contact our Customer Care Staff. This information may include your name, address, e-mail address, telephone number, location, credit card numbers, 529 college savings account numbers, and/or information about your financial institution and account, for purpose of distributing your rewards.
- Information collected through your use of the Service. We collect information about how you use the Service, including information about your transactions and account activity with us and with our partners and Service Providers who help us provide the Service.
- Information from third-parties. We may obtain information about you from third-parties including Upromise participating companies, partners, our affiliates, public sources and others. This information could include, among other things, information about your purchases and transactions with Upromise participating companies, or with the third-parties that provide portions of the Upromise Service (for the purpose of calculating your rewards and otherwise providing the Service). We may also obtain publicly available demographic data, and any information needed to comply with regulatory requirements, ensure the accuracy of data, better understand your likely interests, and/or prevent fraud.
- Information from social media. We may also receive personal information about you from third-parties when you log in through a third-party social networking or authentication service, such as Facebook, Google or similar single sign-on service. These services will authenticate your identity and provide you the option to share certain personal information with us, which could include your name, e-mail address, address book and contacts or other information. We use this information in the same way we use other personal information we collect from you as described in this Policy.
We, and our third-party partners, automatically collect certain types of usage information when you visit our websites, use our Service, read our emails or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, Flash objects, web beacons, file information and similar technology (collectively, "tracking technologies"). For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, network domain, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device, your account, and other such information. We also collect information about the way you use our Service, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take on the Service. When you access our Service from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers ("IDFA"), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address. We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the websites and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.
We use or may use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Service; (b) provide custom, personalized content and information, including targeted content and advertising; (c) recognize and contact you across multiple devices; (d) provide you with location-based information or messages (e) provide and monitor the effectiveness of our Service; (f) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (g) diagnose or fix technology problems; and (h) otherwise to plan for and enhance our service.
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Services, as some features and services on our Services may not work properly and the offers we provide when you visit or use our Services may not be as relevant to you or tailored to your interests. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML5. You can learn more about Flash objects - including how to manage privacy and storage settings for Flash cookies – on Adobe’s website or by clicking here. If you choose to delete Flash objects from our websites, then you may not be able to access and use all or part of the websites or benefit from the information and services offered.
How We Use Information
We use this information to operate, maintain, and provide to you the features and functionality of the Service, to analyze and improve our Service, to communicate with you, to fulfill legal and regulatory requirements, and as otherwise permitted by applicable law. For example, we may use the information to:
- Operate, maintain and provide the Upromise Services, including to calculate your rewards;
- Fulfil your request or for the purpose explained when you provided the information;
- Communicate with you, including via email, chat, text messages, push notifications and/or telephone calls;
- For business purposes, such as gathering analytics to understand how visitors use our website and Service, and determine whether our website content is effective;
- Develop and improve our website and Service offerings;
- Personalize your experience when you use our Service 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 websites, on third party websites and services, on other devices you may use, and through email;
- 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;
- Remember your information so that you will not have to re-enter it during your next visit and identify you across different devices that you use;
- To help maintain the safety, security and integrity of our websites, products and services, database and other technology assets and business; diagnose or fix technology problems, and otherwise plan for and enhance our Service.
Our Information Sharing Practices
We may share personal information in the instances described below. For further information on your choices regarding your information, see the Your Choices section below.
- Third party partners in order to provide the Service. Certain features of the Upromise Service are managed by third party providers. We share your personal information with these providers as needed to provide the features and functionality of the Service to you. These third parties will also collect information from you directly and may use your personal information as described by their own privacy policies.
- Agents and service providers. We may share personal information about you with agents and service providers, as needed to perform functions on our behalf, such as to send email and postal mail, analyze data, provide marketing services, and service accounts.
- 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.
- Third-parties as needed to 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.
- With our 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.
- With the public and other members of the Service. Please note that information you voluntarily post in bulletin boards, chat rooms and other online forums, such as the Community Forum, may be viewed and used by anyone with access to those forums.
- 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. We may share personal information with third parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or similar proceedings.
- With your consent. We also may share your personal information with a third-party if you consent to the sharing.
We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.
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 Policy.
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.
To exercise the right to opt-out of the potential sale of your information, you may submit a request to us by visiting the following Internet Web page link:
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
Accessing your 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.
If you have any questions about modifying or deleting your information, you may contact us using the contact information provided below. We may not be able to modify or delete your information in all circumstances.
If you do not wish to receive marketing messages from Upromise, you may indicate your preferences by clicking the "Unsubscribe" link in the email. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service or technical and security notices).
Refer to the section on Online Tracking and Advertising to learn about your choices regarding online advertising and tracking technologies.
Online Tracking and Advertising
We may share, or we may permit third party online advertising networks, social media networks or other third-party services, to collect information about your use of our websites over time so that they may play or display ads that may be relevant to your interests on our websites as well as on other websites or apps, or on other devices you may use. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the devise you are using and collect information, such as click stream information, browser type, time and date you visited the site, and other information. This information is used to display targeted ads on or through our Site or on other websites and services, including on Facebook. We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests. As noted above, depending on your browser or mobile device, you may be able set your browser to delete or notify you of cookies and other tracking technology by actively managing the settings on your browser or mobile device. You may also be able to limit interest-based advertising through the settings on your browser or device. For example, you may be able to opt-out of some interest-based advertising on your mobile device by selecting "limit ad tracking" (iOS) or "opt-out of interest-based ads" (Android).
Google Analytics and Advertising. We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.
How We Store and Protect Your Information
Keeping your information safe. We care about the security of your information and uses commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information collected through our website. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised in accordance with any applicable laws and regulations.
Data retention. 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 and request that your information be deleted. We may not be able to delete your information in all instances, such as if we are required to retain certain data for record-keeping purposes or to comply with laws.
State LawsPlease note that you may have additional rights under state laws.
We do not knowingly collect or solicit any information from anyone under the age of 13 on the websites. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us using the contact information listed below.
Links to Third Party Websites and Services