GIFT OF COLLEGE INC. Privacy Policy

This web site (the “Site”) is owned and operated by GIFT OF COLLEGE, INC. (“Gift of College”, “we”, “us”).  Your privacy is important to us. This Privacy Policy outlines the types of personally identifiable information (such as your email address, first and last name, and address) and other information (such as log files) that we gather while you are visiting the Site, as well as ways in which we process, use and disseminate such information. This Privacy Policy does not pertain to information collected on any other site owned by us, our subsidiaries or other businesses.

We reserve the right to change, modify, add, or remove provisions of this Privacy Policy. Any changes to this Privacy Policy will be posted here, and we encourage you to check back from time to time to ensure continuing familiarity with the most current version of our Privacy Policy. You can determine when this Privacy Policy was last revised by referring to the “Last Updated” legend at the top of this Privacy Policy. This should help you to determine whether the Privacy Policy has been revised since your previous visit to the Site.

Please read this Privacy Policy as well as the Terms of Use carefully. Your use of the Site constitutes your acceptance to be bound by this Privacy Policy and the Terms of Use without limitation, qualification or change. If at any time you do not accept all the terms and conditions contained herein and in the Terms of Use, you must immediately discontinue use of the Site.

Personally identifiable information is information that identifies you as an individual, such as your name. We collect personally identifiable information that you submit to us through the Site. Personally identifiable information may include, but is not limited to: 

email address;

first and last name;

mailing address;

telephone number;

credit or debit card numbers maintained for a limited period of time by a third-party payment processor; 

529 plan account provider, account owner, and account beneficiary names and 529 plan account numbers;

Student loan provider, borrower, student loan account number, and specific instructions, if any;

Payroll information 

 

We may also from time to time request additional information that is helpful or necessary for running the Site and providing products, services and information. You do not have to provide personally identifiable information to use certain portions of the Site. In order for you to take advantage of particular products and services provided through the Site, such as setting up a profile, receipt of requested information or viewing of certain areas of the Site, we may require that you furnish personally identifiable information.

Non-personally identifiable information is any information that does not reveal your specific identity. Non-personally identifiable information includes, but is not limited to: 

browser information, such as log files;

information collected through cookies, pixel tags and other technologies;

demographic information; and 

aggregated information that does not personally identify you or any other user of the Site.

When you use the Site, information is gathered from your Internet browser. This information may include log files (which allows us to determine the identity of your Internet Service Provider), your operating system and the type of browser software that you are using to access the Site.

The Site may use a standard technology called a “cookie”, or web beacons or other similar technology to collect information about how you use the Site. Cookies reside on your computer and help the Site recognize your computer’s browser as a previous visitor. In addition, on occasion the Site may also set a “session cookie” which helps us administer the Site. The session cookie expires when you close your browser and does not retain any information about you after it expires.

If you use a standard web browser, you should be able to modify your browser preference to provide you with choices relating to cookies; for example, you should have the choice to accept all cookies, to be notified when a cookie is set or to reject all cookies. If you choose to reject cookies, you may be unable to use certain Site services (e.g., those services that require you to log on to the Site).  For more information on modifying your browser preference, please refer to the documentation accompanying your browser.

Your IP address is a number that is automatically assigned to the computer that you are using by your internet service provider.

An IP address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice on the Internet and is done automatically by many web sites.

We may use your personally identifiable information to contact you when reasonably necessary and in the following ways:

Fulfillment of Requests and Response to Inquiries. We may use personally identifiable information about you to fulfill the purpose for which such information was provided and to provide our services, such as to process contributions to student loan and 529 accounts, facilitate payroll deduction and/or employer contributions or matching contributions, facilitate a gift contribution or purchase of a gift card, create shareable profile links, send materials or communications to you or process or fulfill your request, to connect you with vendors when requested by you, who will provide you with information about products and services, and to respond to your inquiries.

Administrative Communications. From time to time, in our sole discretion, we may use personally identifiable information about you to send to you important information regarding the Site, our At-Work offerings, changes to our terms, conditions and policies and/or other administrative information. Because this information may be important, you may not opt-out of receiving such communications.

Marketing Communications. From time to time, we may use personally identifiable information about you to personalize your experience with the Site by informing you of products, programs, events, services and promotions of us, our affiliates, our partners and/or third parties that we believe may be of interest to you. If you would prefer that we do not send electronic marketing messages to you or contact you via telephone, please see the “Opt-In/Opt-Out Policy” section below.
 

When you use the Site to make a contribution to independent, pre-existing 529 plans established, run and/or otherwise offered or maintained by third parties, including, without limitation, individuals and/or financial services firms, states, state agencies, investment, and program management firms and to student loan providers that are unaffiliated with Gift of College©, or when you make a purchase from us or use the Site to participate in Gift of College At-Work offerings, we may use personally identifiable information about you in order to process or fulfill your contribution, your payroll deduction, employer’s contribution, a gift giver’s contribution or your purchase request, for example, to submit certain information to the unaffiliated third parties that run and/or maintain the applicable 529 plan(s), to facilitate employer payroll deduction, contributions or matching, to process your payments for purchases, to communicate with you regarding your contribution, or purchase, or to provide you with related customer service. We may use your contact information to verify and authorize the use of your credit or debit card for contributions, services and/or products for which you have registered, requested or ordered. 

Internal Business Purposes. We may also use personally identifiable information about you for our internal business purposes, such as data and trend analysis, market studies, audits, developing new products and services, enhancing the Site, identifying usage trends and determining the effectiveness of any promotional campaigns.

Voluntarily Disclosed Information. Without limiting the generality of anything in the Terms of Use, because we reserve the right to use content created or provided by you in connection with our products and services, to the extent that you include personally identifiable information in such content, we may use such personally identifiable information, as part of the content, in connection with the Site and promotion thereof.

In Compliance with Applicable Law. We may use personally identifiable information about you in the event that we believe, in our sole discretion, that such action is reasonably necessary to comply with government requests or court orders; to enforce the Terms of Use or other published guidelines; to protect ourselves, our users or others; to respond to circumstances that we feel constitute an emergency; to allow us to pursue available remedies or limit the damages we may sustain; or as otherwise required or permitted by applicable laws, rules or regulations. Please be aware that, in connection with the foregoing, we may use information about you gathered through other sites controlled, owned or operated by us or our affiliates to the extent permitted under the applicable privacy policy governing collection and use of such information.

We may use non-personally identifiable information to measure the number of visits, average time spent on the Site and pages viewed as well as to diagnose problems with our servers and to administer the Site. We may then use this information to analyze and improve the features and functionality of the Site.

Because non-personally identifiable information does not personally identify you, we may use and disclose non-personally identifiable information for any purpose. In some instances, we may combine non-personally identifiable information with personally identifiable information (such as combining your name with your geographic location). If we combine any non-personally identifiable information with personally identifiable information, we will treat the combined information as personally identifiable information as long as it is combined.

We use IP addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site. We may also use and disclose IP addresses for all the purposes for which we use and disclose personally identifiable information. Please note that we treat IP addresses, server log files and related information as non-personally identifiable information, except where we are required to do otherwise under applicable laws, rules or regulations.

We may disclose your personally identifiable information to third parties, to the extent permitted by law, in the following ways:

Affiliates and Partners. We may share personally identifiable information about you with our affiliates and partners so that they may use such information for the purposes described in this Privacy Policy.

Third Party Service Providers. We may, from time to time, work with third parties who provide services including but not limited to data analysis, information verification, payroll deduction, employer contributions and/or matching, payment processing, web site hosting, auditing services, order fulfillment, infrastructure provision, IT services, customer service, e-mail delivery services and other similar services. We may share personally identifiable information about you with such third parties for the purpose of enabling such third parties to provide such services (for example, if you choose to make a contribution, or purchase through the Site, we may share your personally identifiable information with the unaffiliated third parties that run and/or maintain the applicable independent, pre-existing 529 plan(s), with student loan providers, employers and/or other third party service providers to fulfill such contribution, payroll deduction or purchase request). 

Third Party Marketing Communications. We may share personally identifiable information about you with our affiliates, partners or other third parties to allow them to contact you regarding products, programs, services and promotions that we and/or they believe may be of interest to you. If you would prefer that we do not share your information with our affiliates or partners for such entities’ marketing purposes, please see the “Opt-In/Opt-Out Policy” section below. We may also share personally identifiable information about you if you request information from vendors so that they can provide you with the requested information. WE ARE NOT RESPONSIBLE OR LIABLE FOR ANY THIRD PARTY’S USE OF YOUR PERSONALLY IDENTIFIABLE INFORMATION.
 

Contributions or Purchases. When you use the Site to make a contribution to an independent, pre-existing 529 plan established, run and/or otherwise maintained by third parties, including, without limitation, individuals, financial services firms, states, state agencies, investment, and program management firms that are unaffiliated with Gift of College and when you use the Site to make a contribution to student loan providers that are unaffiliated with Gift of College©, or when you make a purchase from us, we may disclose your personally identifiable information, as necessary, to fulfill your contribution, payroll deduction and/or purchase request. By giving the Site your credit or debit card and related personal information, you are authorizing us to give that information to the unaffiliated third parties that run and/or maintain the applicable independent, pre-existing 529 plan(s), student loan providers, or the merchant (if the merchant is a separate entity), as applicable, and the credit or debit card company, in order to confirm and fulfill your request.

Voluntarily Disclosed Information. Without limiting the generality of anything in the Terms of Use, because we reserve the right to use content created or provided by you in connection with our chat room, forum, message board or news groups, to the extent that you include personally identifiable information in such content, we may republish or otherwise disclose such personally identifiable information, as part of the content, in connection with the Site and promotion thereof. If we republish or otherwise disclose your content, we may also publish or disclose your member name to provide authorship credit. Please be aware that when you disclose personally identifiable information in a profile or forum on the Site, the information may become public and accessible to all or a part of the Site community and can in turn be used by third parties in any manner and for any purpose, so it is important for you to exercise discretion and appropriate caution when deciding to reveal personal information on the Site. In the event that you encounter any Site user who you believe is improperly collecting or using information about you or other users, please notify us immediately by contacting us in accordance with the “Contact Us” section below.

Assignment. We reserve the right to transfer any and all information that we collect from Site users to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).

In Compliance with Applicable Law. We may disclose personally identifiable information about you in the event that we believe, in our sole discretion, that such disclosure is reasonably necessary to comply with government requests or court orders; to enforce the Terms of Use or other published guidelines; to protect ourselves, our users or others; to respond to circumstances that we feel constitute an emergency; to allow us to pursue available remedies or limit the damages we may sustain; or as otherwise required or permitted by applicable laws, rules or regulations.

OPT-OUT: When you supply us with personally identifiable information in connection with your use of the Site, we may send information to you about our product and service offerings and we may share personally identifiable information about you with our affiliates, partners or other third parties for their marketing purposes.

You may, of course, choose not to receive additional marketing information from us or choose not to allow our sharing of your personally identifiable information as follows: 

At any time, you can follow a link provided in our marketing-related email messages (but excluding e-commerce confirmations and other administrative emails) to opt out from receiving such communications; 

When you receive a promotional telephone call from us, you can ask the operator to place you on our “Do Not Call” list; or

At any time, you can contact us by clicking on the Contact Us link on the Site to opt out from receiving such email or telephonic communications. 

If you decide to contact us to change your contact preference to “Do Not Contact Me”, please specify clearly which of the following choices you are opting out of:

Receiving marketing communications from us;

Allowing us to share personally identifiable information about you with our affiliates and partners for their marketing purposes; and/or

Allowing us to share personally identifiable information about you with other third parties for their marketing purposes.

We will endeavor to implement your requested change as soon as reasonably practicable after receiving your request. Please be aware that your requested change will not be effective until we implement such change. Please note that if you choose not to allow our sharing of your personally identifiable information, we are not responsible for removing your personally identifiable information from the databases of third parties with which we have already shared your personally identifiable information as of the date that we implement your request. If you wish to cease receiving marketing-related e-mails from these third parties, please contact them directly or utilize any opt-out mechanisms in their privacy policies or marketing-related e-mails.

Please note that if you do opt-out of receiving marketing-related messages from us, we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages. We reserve the right, from time to time, to contact former customers or users of the Site for administrative purposes or in order to comply with applicable laws, rules or regulations.

If you would like to review, correct, update, suppress, delete or otherwise limit our use, on a prospective basis, of your personally identifiable information that has been previously provided to us, you may do so by contacting us in accordance with the “Contact Us” section below and providing the context of your provision of information, your full name, mailing address, phone number and email address so that we may identify you in the opt-out process.

In your request, please make clear what information you would like to have changed, whether you would like to have your personally identifiable information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personally identifiable information. We will endeavor to implement your requested change as soon as reasonably practicable after receiving your request. We are not responsible for correcting, updating or suppressing your personally identifiable information from the databases of third parties with whom we have already shared such information as of the date that we implement your request.

Please note that we may need to retain certain information for record keeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed therefrom.

For your protection, we will only implement such requests with respect to the personally identifiable information associated with the particular e-mail address that you use to send us your request, and we may need to verify your identity before implementing your request.

We may use vendors, partners and other third parties to list advertisements and help deliver personalized content when you visit our Site. These partners, vendors and third parties may include, without limitation, advertisers (including advertisers using both banner and text advertising), retargeters, analytics companies and search engines such as Google, Inc. Such third parties may use cookies and web beacons to collect information about your online activity (such as the sites and pages you have visited within the Site and other third party sites) in order to help us (and in some cases, third party advertisers) deliver personalized content and advertising to you while you are on the Site or on other sites. 

PLEASE NOTE THAT WE ARE NOT RESPONSIBLE FOR THE ACTS AND/OR OMISSIONS OF THIRD-PARTY VENDORS.

Consistent with the Children’s Online Privacy Protection Act:

This Site does NOT knowingly collect, use, or disclose personally identifiable information provided by anyone under the age of 13 (including online contact information). Adults who use the Site are responsible for the content they place in profiles which may include information about individuals under the age of 13. In the event that a child under the age of 13 attempts to register or make a contribution, donation or purchase through the Site and we are aware of such child’s age, we will NOT accept the registration and will delete information received from the child. In the event we become aware that a child has posted personal information on our site, we will attempt to delete that information once we become aware of the age of the child who makes such a posting.

We employ reasonable security measures consistent with standard industry practices, for information collected through the Site. For instance, we have measures and tools, such as firewalls, in place to help protect against the loss, misuse and alteration of the information under our control, and usernames and passwords submitted by users of the Site are encrypted using Secure Sockets Layer or other encryption mechanisms. However, you should exercise discretion with respect to the submission of any personally identifiable information to the Site. Transmitting information via the Internet is never completely secure and, therefore, any information submitted may be intercepted, collected, used or disclosed by third parties. We ask that you do not send us credit or debit card information or other sensitive information on or through the Site or otherwise, unless requested by us or the Site to process or fulfill your contribution, payroll deduction, purchase request, or respond to your inquiry. We cannot, and do not, guarantee that information supplied by users will not be accessed on our servers, or intercepted, collected, used or disclosed by others while being transmitted to or from the Site over the Internet. You acknowledge and agree that any information you transmit through the Site or upload for storage in connection with the Site is so transmitted or stored at your own risk. 

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us by contacting us in accordance with the “Contact Us” section below.

The Site may contain links to other web sites, including e-commerce partners, vendors or advertisers, which may or may not be owned or operated by us. Links to such web sites are made without any representations or warranties relating to the integrity, security or legitimacy of such web sites. The inclusion of a link on the Site does not imply endorsement of the linked web site by us, our affiliates or our partners.

When you provide personally identifiable information to one of the Site’s e-commerce partners, vendors, advertisers or any other external web site reached by clicking through a link on the Site, this transaction will occur in connection with the web site of the e-commerce partner, vendor, advertiser or other external web site, not the Site, and, as such, the personally identifiable information you provide is collected pursuant to and controlled by the privacy policy of such e-commerce partner, vendor, advertiser or other external web site. We are not responsible for the privacy practices or the content of web sites that are not owned and operated by us, including such sites’ use of any information (such as IP number, browser type or operating system) collected when visitors to the Site click through links to those web sites. This Privacy Policy cannot and does not apply to external web sites and, once you leave the Site, you are subject to those web sites’ privacy policies and procedures. We strongly encourage you to become familiar with the privacy practices and privacy policies of external web sites before providing personally identifiable information. If you have concerns about any linked web site, please contact us in accordance with the “Contact Us” section below.

We retain information, including personally identifiable information, for the period required to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by applicable laws, rules or regulations. 

The Site is controlled and operated by us from the United States and is not intended to subject us or any of its affiliates or partners to the laws or jurisdiction of any state, country or territory other than that of the United States. We do not represent or warrant that the Site, or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access the Site do so on their own initiative and at their own risk and are SOLELY responsible for complying with all APPLICABLE laws, rules and regulations. We may limit the Site's availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.

The information disclosure practices described in the Site are in accordance with federal United States law. You may have other privacy protections under state laws, such as Nevada, California and Vermont. To the extent these state laws apply, we will comply with them with regard to our information disclosure practices.

Nevada Residents. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General. 555 East Washington Street, Suite 3900, Las Vegas, NV 89101; phone number (702) 486-3132; email: BCPINFO@ag.state.nv.us. 

California and Vermont laws place additional limits on disclosing information about California and Vermont residents so long as they remain residents of those states. 

California Residents. In accordance with California law, we will not disclose information we collect about California residents to unaffiliated companies, except as permitted by law, which includes disclosures with the consent of the California resident and disclosures to service the resident’s accounts with us, as well as other lawful disclosures. 

Vermont Residents. In accordance with Vermont law, we will not disclose information we collect about Vermont residents to unaffiliated companies and will not disclose application and third-party credit-related information about Vermont residents to our affiliated companies except as follows: as permitted by law; to companies that perform marketing or other services on our behalf; name, contact and transaction and experience information to other companies with which we have joint marketing agreements; or with the authorization or consent of the Vermont resident.

The Site is governed by and operated in accordance with the laws of United States of America. We make no representation that the Site is governed by or operated in accordance with the laws of other nations. By using the Site and submitting any personal information, visitors from outside of the USA acknowledge that the Site is subject to USA law, consent to the transfer of personal data to the USA, and waive any claims that may arise under any other laws, rules and regulations, including, without limitation, their own national laws.

If you have any questions about our company, the Site or this Privacy Policy, please contact us by clicking on the Contact Us link on the Site or by writing to the following address: Gift of College Inc., P.O. Box 87408, Phoenix, AZ 85080-7408