CFNC - Privacy Policies

The College Foundation of North Carolina website is sponsored by and maintained through a non-profit partnership between College Foundation, Inc., the State Education Assistance Authority, an agency of the State of North Carolina, and Pathways of North Carolina. Each of these entities is dedicated to protecting your nonpublic personal information provided through use of the College Foundation of North Carolina website.

The Privacy Policy for each entity maintaining the College Foundation of North Carolina website is provided in its entirety, as follows:

• College Foundation, Inc.
  
• Pathways of North Carolina
  
• North Carolina State Education Assistance Authority
  
• North Carolina's National College Savings Program

College Foundation, Inc.

Privacy Policy of College Foundation, Inc.

College Foundation, Inc., (the "Foundation"), on its own behalf and on behalf of the entities for which the Foundation services education loans and administers education assistance programs, is committed to protecting the confidential nature of all "nonpublic personal information" that the Foundation collects from individuals, including borrowers and other student assistance program participants, in order to provide services to you. Such "nonpublic personal information" includes, but is not limited to, the following:

• Information, such as your name, address, Social Security Number, assets and income, which you provide on applications and other forms related to financial assistance for college;
  
  
• Information such as your credit history and credit scores which we may collect from consumer reporting agencies; and
  
  
• Information related to transactions with the Foundation such as your account balance and payment history.
  

The Foundation may disclose this information as permitted or required by law or as explained below. We do not sell your nonpublic personal information to marketing or other organizations.

However, we may disclose the information we collect, as described above, to other entities that perform marketing services on our behalf or with whom we have joint marketing agreements. Under these circumstances, we will require the entity, as a condition of its contract with the Foundation, to maintain the confidentiality of all nonpublic personal information and to use it only for the intended purpose.

The Foundation maintains internal procedures to maximize the security of your nonpublic personal information. Access to your information is restricted to only those Foundation employees who need the information to provide services to you, and each of these employees is required to comply with the terms of our Privacy Policy. The Foundation also maintains physical, electronic, and procedural safeguards that comply with federal regulations to protect and prevent misuse of your nonpublic personal information.

The Foundation will notify you of any changes to our Privacy Policy as required by law. Even if there are no changes, we will provide you with a copy of our policy each year that you have an account with the Foundation. If you end your relationship with the Foundation, our policies regarding your information will continue to apply.

This Privacy Policy is provided by the Foundation on its own behalf and on behalf of the following entities for which the Foundation services education loans and administers education assistance programs:

North Carolina State Education Assistance Authority
State Employees' Credit Union
Mechanics and Farmers Bank
SunTrust Bank
Wachovia Bank, N.A.
First Charter National Bank
Branch Banking and Trust Company
First National Bank and Trust Co.
Bank of America, N.A.
Bank of Granite
Farmers & Merchants Bank
RBC Bank
First Bank
Four Oaks Bank & Trust
NewBridge Bancorp
Randolph Bank & Trust
United Community Bank
Bank of Stanly

Information Policy of College Foundation, Inc.

Pathways of North Carolina

A Privacy Policy Statement from Pathways of North Carolina

Pathways of North Carolina recognizes and respects the privacy interests of Pathways of North Carolina users. It is committed to protecting that privacy and keeping users informed about our privacy policy.

As Pathways of North Carolina evolves, we may update this privacy policy statement to reflect changes in the manner in which we deal with personal information, whether to comply with then-applicable regulations and self-regulatory standards or otherwise. The privacy policy posted here will always be current. We encourage you to review this statement regularly.

WHAT THIS PRIVACY POLICY STATEMENT COVERS:

• Pathways of North Carolina privacy policy and its exceptions
  
• The personal identifying information we collect
  
• Reasons we collect personal identifying information
  
• Ways in which personal identifying information may be used
  
• With whom personal identifying information may be shared
  
• Security measures to protect information entrusted to Pathways of North Carolina
  
• Cookies
  
• Links
  
• Modifying and deleting your information
  
• Amending this Privacy Statement
  
• Questions

PATHWAYS OF NORTH CAROLINA'S PRIVACY POLICY AND ITS EXCEPTIONS
Except as set forth below, personally identifiable data you enter on CFNC.org is not made available or distributed to third parties, except with your express consent or at your express direction. In particular, Pathways of North Carolina (including the University of North Carolina General Administration (UNCGA) which administers the Pathways of North Carolina program) will not give, sell or provide access to your personal information to any company, individual or organization for its use in marketing or commercial solicitation or for any other non-permitted purpose, except with your express consent, as is necessary for the operation of this site, or pursuant to one of the exceptions listed below.

Exceptions to the privacy policy
There are limited exceptions to the Pathways of North Carolina privacy policy. When required by law to comply with any valid legal process such as a search warrant, subpoena, statute, regulation or court order, UNCGA will supply such information contained in your CFNC account as UNCGA reasonably determines, based on the advice of counsel, it is legally required to supply. In addition, UNCGA may release specific information relevant to special cases, such as a physical threat to you or others or an attempted breach of security on the Pathways of North Carolina site.

THE PERSONAL IDENTIFYING INFORMATION WE COLLECT
Pathways of North Carolina collects personal identifying information from you including, but not limited to, your name, date of birth, address, e-mail address, telephone number, grade level, parent's e-mail address, such additional information as you choose to include in your user profile or are required to provide by the college and financial aid applications that you choose to complete, and information associated with activities you have undertaken on CFNC.org.

REASONS WE COLLECT YOUR PERSONAL IDENTIFYING INFORMATION
Pathways of North Carolina collects personal information from you primarily for three reasons. The first reason is to perform a task on CFNC.org, such as filling out a specific college admission application, requested by you. The second reason is to enable you to submit in a convenient and efficient manner information that is likely to be needed when you complete college admission, financial aid and other applications and forms made available through Pathways of North Carolina or undertake a scholarship search on CFNC.org, and the third reason is to enable to respond to your questions or contact you when necessary in connection with the functioning of CFNC.org. When the effective functioning of a Pathways of North Carolina module does not require personal information, none is collected, and any such module can be accessed without opening an account or providing any personal data.

When you log on to CFNC.org, your browser will automatically transmit to CFNC.org's server the IP address of your computer, type of browser you are using and certain other information relating to your computer and its use. Although your browser transmits this information, Pathways of North Carolina does not associate the IP address of your computer or any of this other information transmitted by your browser with any personally identifiable information regarding you. Pathways of North Carolina does not collect any personally identifiable information other than what users submit and their browsers transmit.

WAYS IN WHICH PERSONAL IDENTIFYING INFORMATION MAY BE USED
Pathways of North Carolina will use your personal identifying information to complete the following forms and surveys, to obtain information for you and to effect transactions on your behalf, in each case only upon your instructions to do so:

• Transmit applications for admission
  
• Transmit requests for electronic high school transcripts
  
• Transmit financial aid applications
  
• Transmit financial aid calculators
  
• Transmit a scholarship search
  
• Transmit freshman planners, which can assist you in selecting courses and otherwise planning to meet admission requirements
  
• Communicate your interest in or your requests for information or material to colleges or other institutions you have specified

Your personal identifying information may also be used for the following purposes:

• We may use your personal identifying information for enrollment verification purposes.
• We may use your identifying information to help diagnose problems with CFNC.org's server and to administer the CFNC.org website.
  
• Summary data representing a compilation of aggregate data representing CFNC.org users may be collected by UNCGA and provided to various entities including colleges and other educational institutions represented on CFNC.org. NO PERSONAL IDENTIFYING INFORMATION IS MADE AVAILABLE AS PART OF THESE SUMMARY REPORTS, AND THE DATA IS AGGREGATED IN SUCH LARGE SETS THAT NO PERSONAL INFORMATION CAN BE IDENTIFIED. Some examples of summary data are the number of monthly visitors to the site, the number of admission applications submitted over CFNC.org, and the CFNC.org functions utilized by students in specified age or grade ranges.

WITH WHOM PERSONAL IDENTIFYING INFORMATION MAY BE SHARED
In each of the circumstances described below, data specifically required to perform a task you request will be made available to a recipient you designate:

• If you submit an application for admission to a college or other educational institution, the personal data required to transmit that application will be provided on your behalf to the admissions office of the institution to which you are applying.
  
• If you start an application for admission to a college or other educational institution, your name and other data entered on that application may be provided to the admissions office of that institution, even though you have not yet submitted that application to that institution.
  
• If you request that a copy of your electronic high school transcript be sent to a college or other educational institution, the personal data required to transmit that request will be provided on your behalf to the North Carolina Department of Public Instruction and the admissions office of the institution to which you have requested the transcript be delivered.
  
• If you request that your data be transferred to FAFSA on the Web to help you fill out your federal financial aid application, data relevant to that application will be provided to a processor specified and authorized to process your financial aid applications (FAFSA) by the U.S. Department of Education.
  
• If you request that a college or other educational institution send you material or save a college or education institution in your My CFNC profile, your contact information will be provided to that institution.
  
• If you register for the College Redirection Pool, your contact information will be provided to all CFNC institutions.
  
• If you register for the Transfer Assured Admissions Policy (TAAP), your contact information will be provided to all CFNC institutions.
  
• Unless you opt out, your My CFNC profile will automatically be associated with the specific high school you select on the Student Planner section of CFNC.org. Information saved in your My CFNC profile will be made available to qualified educational professionals at the school you select. Please be aware that those whom you have authorized will be permitted to view personally identifying information about you unless you opt-out. If you do not opt-out, this will constitute consent to share education records under Family Educational Right and Privacy Act (FERPA).
  

UNCGA, which administers the Pathways of North Carolina program, will have access to your personally identifying information. UNCGA will treat personally identifying information you enter on CFNC.org as educational records under the provisions of the Family Educational Right and Privacy Act (FERPA). These educational records will receive from UNCGA the privacy protections afforded by FERPA. UNCGA will consider as “directory information,” and thus not protected from disclosure, the following:

• name
• date and place of birth
• addresses: local and permanent
• email and telephone number(s)
• institution(s) applied to and major(s) declared (if any)
• dates of application and/or intended attendance
• previous institutions attended
• degree(s) earned
• honors / awards received and honorary organizations
• participation in officially recognized activities and sports

When visiting CFNC.org, you may link from CFNC.org to other websites for a variety of purposes such as visiting an official college website. This Pathways of North Carolina privacy statement does not apply to any other website, including websites to which CFNC.org may be linked. For your protection, we recommend that you read and understand the privacy policy at any website prior to providing personal information on that website.

SECURITY MEASURES TO PREVENT MISUSE OF INFORMATION ENTRUSTED TO PATHWAYS OF NORTH CAROLINA
Pathways of North Carolina causes the data you input to be encrypted when in route between your browser and the CFNC.org server and when in route between the CFNC.org server and some other browser or server. This practice helps prevent unauthorized third parties from intercepting and gaining access to your private data during transmission over the Internet. CFNC.org uses Secure Socket Layer encryption supported by both Netscape's and Microsoft's browsers.

Data residing on the CFNC.org server is password protected, and access is provided only to the account holder who created the password, anyone to whom that account holder entrusted the password, those employees who require such access to administer and maintain the CFNC.org system or to provide requested customer support to users of CFNC.org, and those employees of UNCGA who require such access to create reports based on aggregated information that is rendered no longer personally identifying in the aggregation process. Each employee who has access to the data residing on the CFNC.org server has agreed in writing to respect the privacy of all such personal data.

COOKIES
A "cookie" is a small file that a website transfers to a user's computer, which may then be stored on its hard drive. Pathways of North Carolina uses cookies to remember you and personalize your web-viewing experience by keeping track of your session when logged on to CFNC.org. Cookies enable you to maintain continuity as you move from page to page on CFNC.org and to avoid the nuisance of being asked to provide the same information repeatedly. Cookies also allow us to make sure that only your browser can exchange information regarding your account with our servers. Cookies cannot be used to steal personal information or to gain access to information that you did not directly provide. The cookies we use are set when you log on to CFNC.org and are erased when you log off CFNC.org or completely close your browser.

Don't want cookies?
Most browsers are initially set to accept cookies. If you don't want cookies, you can set your browser to disable or refuse cookies or to alert you when cookies are being used. You should note, however, that various CFNC.org services might not function properly when cookies are not utilized.

LINKS
CFNC.org hosts links to other sites or resources having privacy policies that may differ from those of Pathways of North Carolina. It is not responsible for the privacy practices or the content of those websites. UNCGA and the colleges and the associations of colleges and agencies represented on CFNC.org do not have control over and do not endorse such external sites and resources. UNCGA, and the colleges, association of colleges or any other state agency represented on CFNC.org shall not be liable for any content, advertising, products or other materials on or available from such sites or resources. In addition, UNCGA, the colleges, association of colleges or any other state agency represented on CFNC.org shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such site or resource.

MODIFYING YOUR INFORMATION
You may modify the personal information data stored on CFNC.org you previously provided. To modify personal information, (i) log on to CFNC.org, (ii) access either your user profile or an application containing the information you want to change, and (iii) modify that information using standard word-processing techniques. To delete non-required personal information, (i) log on to CFNC.org, (ii) access your user profile, and (iii) delete the information you want to remove from CFNC.org using standard word-processing techniques. Please recognize that if you delete information, it will no longer be available on CFNC.org so that, for example, if a college to which you previously submitted an application were to attempt to retrieve that application from CFNC.org after you made the deletion the deleted information would no longer be accessible. Similarly, when accessed over CFNC.org, information that has been updated or otherwise modified will appear in its then-most current form, rather than in the form in which it may have been submitted at some earlier time.

AMENDING THIS PRIVACY STATEMENT
Pathways of North Carolina may amend this Privacy Statement from time to time. If Pathways of North Carolina makes any substantial changes to this Privacy Statement concerning use of your personal identifying information, it will notify you by posting a message on the CFNC.org homepage. If feasible, the notice will be posted for at least thirty days before taking effect.

QUESTIONS:
If you have any questions about this privacy statement and the privacy practices on this site, you may contact us at privacy@cfnc.org.

North Carolina State Education Assistance Authority

Privacy Statement of NCSEAA

This Web site is co-hosted and maintained in part by the State Education Assistance Authority, a political subdivision of the State of North Carolina (hereinafter "the Authority"). Together with College Foundation, Inc., and Pathways of North Carolina, the Authority is committed to protecting the privacy of visitors to the College Foundation of North Carolina Web site (hereinafter "the CFNC site"). Accordingly, the majority of Web pages provided by the Authority through the CFNC site are accessible to Internet users without their providing or our collecting any nonpublic personal information. The Authority may track the Internet addresses of the domains from which Internet users (i) visit the Authority's portions of the CFNC site, (ii) exit from the site and (iii) how they flow through the site. While the Authority may collect and analyze this information for user trends and Web site composition, as well as compile statistics regarding usage of the site, throughout this process each individual user remains anonymous.

In order to provide certain online services for you and to respond to your inquiries about the Authority's programs, the Authority may request and collect "nonpublic personal information" from you. "Nonpublic personal information" means personal information that identifies you and is not available from public sources. Such information may include your name together with your mailing address or electronic mail address and any information that you submit on an application for a scholarship, grant or loan. We do not disclose any nonpublic personal information about you to anyone except as may be required or permitted by applicable federal or State law. Since the Authority is an agency of the State of North Carolina, some nonpublic personal information may be subject to disclosure under the Public Records Act, Chapter 132 of the General Statutes of North Carolina. However, any information that reveals an account number for electronic payment as defined in G.S. § 147-86.20 and obtained pursuant to Articles 6A or 6B of the General Statutes is protected from disclosure under the Public Records Act and will remain secure for the limited time during which such information is retained by the Authority in order to complete the requested electronic payment transaction.

We restrict access to nonpublic personal information about you to Authority employees and to our agents and contractors, who need to know the information, in order to provide services to you.

While you are at our Web site, we may use "cookies" or other similar files to temporarily store information on your computer's hard drive. The stored information will not be personally identifiable; it will be used solely to facilitate your movement through our Web site and will be cleared when you log off.

This Privacy Policy may be updated periodically, and in the event of any such update the revised policy will be posted to the CFNC site in a timely manner. In addition, the Authority may provide individuals participating in its programs with annual notice of its Privacy Policy to the extent required by applicable federal law.

North Carolina College Savings Program

Authority Policies and Procedures for the Use and Disclosure of Nonpublic Personal Information

The North Carolina State Education Assistance Authority, through the Program Administrator and other service providers for the Program, obtains certain nonpublic personal information from Participants through various sources. For example, from a Participant's Enrollment Agreement, the Authority knows the Participant's name, address and Social Security number, and the corresponding information for the Beneficiary of the Account established by the Participant. By the very nature of the Program, the Authority also knows how each Account is invested, each Account balance, the frequency and amount of the Contributions of each Account, and the nature of all Account withdrawals. The nonpublic personal information the Authority has is protected by physical, electronic and procedural safeguards. The Authority also limits access to all the nonpublic information to persons who need to know that information to perform their Program services.

The nonpublic personal information the Authority has is used to initiate and maintain Accounts and otherwise to operate the Program. The Authority may disclose the information collected, as described above, to third parties in order to market jointly and to administer the programs and services that the Program Administrator administers on behalf of the Authority. However, under these circumstances, the Authority will require that the third party, as a condition of its contract with the Authority or the Program Administrator, protect the confidentiality of all nonpublic personal information to the extent required by law and limit the usage of such nonpublic personal information to the extent necessary to perform services in connection with the Program. The Authority requires all of these persons to protect the confidentiality of nonpublic personal information. The Authority may also share Account information with the Participant's consent. The Authority does not otherwise provide nonpublic personal information to third parties, except to the attorneys, accountants, or auditors who represent the Authority or service providers thereto, and as otherwise permitted or required by law.

Capitalized terms appearing in this statement have the meanings assigned to them in the Program Description for North Carolina's National College Savings Program.

Contact us:

NC 529 Plan
P.O. Box 41930
Raleigh, NC 27629-1930

Toll-free: 800-600-3453
Fax: 919-835-2304

www.CFNC.org/NC529