Online privacy policy  

SimpleTuition SmarterBank Rewards and Payments Platform Online Privacy Policy
Privacy Policy to Protect Confidential Information

Effective November 18, 2011
Address:
SimpleTuition, Inc.
268 Summer Street
Boston, MA 02210
Phone: 617-630-6100

Online Privacy Policy for SmarterBank

This Online Privacy Policy for the SmarterBank applies only to the SmarterBank website . All other SimpleTuition websites, products and services are governed by a separate privacy policy .

At SimpleTuition, we respect and value your privacy. Our Online Privacy Policy ("Privacy Policy") describes and applies to the information we collect from you when you visit the SmarterBank website ("Website"). The terms "we," "our," and "us" in this Privacy Policy refer to SimpleTuition and/or its affiliates, divisions, or subsidiaries. Our Privacy Policy generally describes how we collect, share, use, and protect your information.

Information That We Collect

When you visit our Website, we receive and collect certain information about you. The information that we receive and collect depends in part on what you do when you visit our Website. You may be able to improve your experience on our Website when you tell us who you are - for example, by signing up for email, applying for products, making inquiries, or requesting further information about a product or service.

Some of the information you may submit is personally identifiable information, but much of it is not. Personally identifiable information is information that identifies a particular person. Examples include your name, phone number, address, and social security number. It is possible to browse our Website without actively submitting any personally identifiable information.

We may use this information for a number of purposes, for example, to better service your requests and/or inquiries, monitor Website usage and/or performance, improve the customer experience of our Website, ensure technological compatibility with your computer, protect against fraud or identity theft, or conduct aggregate analyses on usage patterns.

From time to time we may supplement the personally identifiable Information you provide through our Website with information from other sources, such as information validating your address or with information obtained from a consumer reporting agency when you enroll in our SLMC Service. Thus, information we obtain through our Website may be intermingled with and used in conjunction with information obtained through sources other than our Website, including both offline and online sources.

Discussions on Community Tools

We may, from time to time, make chat rooms, forums, message boards, news groups and other community tools available to you. Please remember that any information, including any personally identifiable Information that is disclosed in these areas becomes public information for other users to view and for us to use. For example, from time to time, we may use the content you write (including your name or screen name if you post it) for promotional purposes, in email newsletters or elsewhere, and by using our Website or these chat rooms, forums, message boards, news groups, and other community tools, you agree that we may do so. You should exercise caution when deciding to disclose your personal information in these areas, since anyone - not just us - may use publicly posted information.

Information You Choose to Submit

For most of the browsing on our Website, we neither require nor collect personally identifiable information. You can browse our Website and take as much time as you want to review our services without having to submit such information.

Except as otherwise indicated in this Policy, we will only supply your personally identifiable Information to a third party with your consent. When we collect your information you will be given the option to opt in or opt out based upon information disclosed at the time your information is collected. If you do not opt in, or you opt out, your information will not be disclosed.

If you open a SmarterBank account you will also be subject to the Privacy practices of The Bancorp Bank and do not have the option to Opt-out. You may view their privacy policy at https://thebancorp.mybankingservices.com/Global/docs/privacy/001_PrivacyPractices.pdf

On this Website, when you provide us with an email address for a referral, we may share your name and email address as well as the recipient's email address with a third party as necessary in order to provide this referral service. This information will not be used for any other purpose. If you choose to use our referral service to tell a friend about our Website, we will ask you for your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Website. The third party used in the referral program stores this information for the sole purpose of sending this email and tracking the success of our referral program. You or your friend may contact us at privacy@simpletuition.com , or use the link provided in each email, to request that we remove this information from our database.

Finally, please note that the personally identifiable Information you provide to the Website that is connected to a specific application or process hosted by SimpleTuition is considered a company asset and may be included among transferred assets if SimpleTuition, any of its Related Companies or any of their assets are ever acquired by a third party.

Automatically Collected Non- Personally Identifiable Information

We collect certain non-personally identifiable information (that is, generic information that does not identify you personally) when you visit the Website. Such generic information may include the type of products and services you are interested in, the type of browser you are using (e.g., Netscape, Internet Explorer), the type of operating system you are using, (e.g., Windows '98 or Mac OS) and the domain name of your Internet service provider (e.g., America Online or Earthlink). We may use click-stream data and other non-personally identifiable information to anonymously determine how much time visitors spend on each page of our Website, how visitors navigate throughout our Website and how we may tailor our web pages to better meet the needs of visitors. We sometimes may use the non-personally identifiable information that we collect to improve the design and content of our Website and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze how our Website is used, as well as to offer you additional products, programs or services. We may share aggregate information with others, including our affiliates (Related Companies) and non-affiliated companies.

Information Collected via Cookies and Other Similar Technology

"Cookies" are small text files that are placed on your computer to distinguish you from other visitors to our Website. The use of cookies is a standard practice among websites to collect or track information about your activities while using the website. We or our third party vendors and service providers may place cookies or similar files on your hard drive for many of the reasons listed above while visiting our Website. Most people do not know that cookies are being placed on their computers when they visit websites because browsers are typically set to accept cookies. You can choose to have your browser warn you every time a cookie is being sent to you or you can choose not to accept cookies. You can also delete cookies from your computer at any time. If you refuse cookies, the functionality of our Website may be impacted or become non-functional.

In addition to using cookies, we or our third party vendors and service providers may also use similar technologies to track users' interactions with our Website. Some of these technologies include web beacons (transparent graphical images placed on a website) and flash objects.

We may use these technologies on our Website to verify your identity, remember personal settings including your preferences, to offer you additional options or enhance your online experience, and to improve our products and services. We may also use them for marketing site personalization, and tracking of online applications and programs and/or track the effectiveness of advertisements for our products and services, referred to as banner ads, that we may place on our Website or other linked and/or partner websites. Cookies used for tracking advertising effectiveness do not collect personally identifiable information. In order to better serve you, some of these technologies allow us the ability to view your past interactions with our Websites and/or online banking environment for customer service, troubleshooting, risk analysis and fraud detection, as well as other related purposes.

EMail Communications and Suspicious Emails

Forms of communication such as, email, text messaging, our Website Contact Us or similar forms, or other forms of electronic communication are inherently insecure. Please refrain from submitting sensitive personal information (such as account number or social security number) via email or similar method of communication.

When you send an email to us, you are communicating with us electronically and consent to receive reply communications from us or our providers electronically. We may retain the content of the email, your email address, and our response in order to better service your needs or for legal and regulatory reasons.

Please be advised that SimpleTuition will never ask for you to send personal or financial information by, in response to, or via link in an email.

All personal data is housed within our secure environment. SimpleTuition will never ask you to supply, update or edit any information outside of the security layers of the SimpleTuition web site. For more information concerning the security procedures and safeguards we employ to protect your personal information from unauthorized access, please see our Online Information Security Policy .

Understanding the types of email fraud - Common Schemes:

Phishing: Phishing is a fraud technique commonly used to attack or trick people into revealing their account number and password.

Here is how a psyching scam typically works: The "phisher" sends out emails that are designed to look legitimate, as though they were really from a reliable source (like SimpleTuition). The fake emails either ask for security details or direct customers to a counterfeit site. If the use of the site is deployed, it will usually prompt the customer to enter security details - password, security questions, user name, account numbers, etc. This information is captured and then used to commit fraud.

If you suspect a phishing attack, forward the suspect email to privacy@simpletuition.com , then delete the email from your mailbox.

Spoofing: Many forged emails ask you to supply, confirm, or update personal information by clicking on a link in the email. The link will connect you to a web page or log in that appears to belong to the company that is mentioned in the email - but it's not. The spoof may be pop up window or an embedded image over the actual site. The goal of these criminals is to get you to enter your personal data so they can steal your identity.

If you suspect you have received a fraudulent email, forward the suspect email to privacy@simpletuition.com , then delete the email from your mailbox.

Personal Information on Children - A Special Note to Parents

Our Website is not geared towards children. Our Website will not knowingly accept personally identifiable Information from anyone under 13 years old. If you believe that your child under 13 has gained access to our Website without your permission, you may contact us at http://www.simpletuition.com/contact_us .

We respect the privacy of your children and encourage all parents to supervise their children's computer usage. We advise all visitors to our Website under the age of 13 not to disclose or provide any personally identifiable information on our Website. To learn more about the Children's Online Privacy Protect Act (COPPA) please visit the Federal Trade Commission's website .

Notice to Persons Accessing this Website Outside the United States

If you reside outside the U.S., any information you provide to us on our Website will be transferred out of your country and into the U.S. If you do not want your personally identifiable information to leave your country, do not provide the information to us. By providing personally identifiable information to us, you explicitly consent to the transfer of your information to the U.S.

Third Party Websites

Our Website may contain links to third party websites. These links and pointers to third party websites are not part of our Website. Neither SimpleTuition nor its affiliates, divisions, subsidiaries or parent company make any representations or warranties regarding these third party websites. We are not responsible for any losses or damages in connection with the information, security, privacy practices, availability, content or accuracy of materials of such third party websites. These third party websites might have privacy policies different from us and third party websites may provide less privacy and/or security than our Website. We encourage you to review the privacy and security policies of all third party websites before you share any personally identifiable information.

Additional Uses or Sharing of Your Information

Unless you are a customer and have opted-out of receiving marketing offers based on your eligibility information, we may use information about your relationship with us, such as what types of accounts you have, as well as transactional information, and the state/region in which you bank to tailor advertisements to you while you are on our Website. These advertisements may take the form of banner ads to offer you additional products and services, or enhance your online experience.

In addition to those methods discussed in this Online Privacy Policy, we may use and share your information, including personally identifiable information, without limitation, in the following manner:

Changes to our Online Privacy Policy

Because our business needs may change over time, we reserve the right to change this Online Privacy Policy at any time. Please review this Online Privacy Policy from time to time and before you provide any nonpublic personal information to our Website. If we change this Online Privacy Policy, we will post those changes on the homepage of the Website and other places we deem appropriate so that you are aware of the current Online Privacy Policy. Your continued use of the Website following the posting of any changes to this Online Privacy Policy means you accept such changes. This Online Privacy Policy is effective as of the date indicated at the beginning of the policy.

Questions or Comments

If you have any questions or comments concerning our Online Privacy Policy, please contact us at privacy@simpletuition.com .

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