CFNC Privacy of Information

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.

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:

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 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 also 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 open or service your account, and each of these employees is required to comply with the terms of our Privacy Policy. Physical, electronic, and procedural safeguards are in place to protect and prevent misuse of all 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 Privacy 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
Central Carolina 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
Mutual Community Savings Bank, SSB
RBC Centura Bank
First Bank
Four Oaks Bank & Trust
Lexington State Bank
Omni National Bank
Randolph Bank & Trust
United Community Bank
Bank of Stanly
SouthTrust Bank
Northwestern National Bank

Information Policy of College Foundation, Inc.

College Foundation, Inc., provides online information access and interactive tools to individuals planning for college, individuals inquiring about paying for college, borrowers, and other student assistance program participants. While you are at our website, 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 website and will be cleared when you close your browser. If you have any questions about the Privacy Policy or the Information Policy of the Foundation, please contact us.


Pathways of North Carolina

A Privacy Policy Statement from Pathways of North Carolina
Effective as of July 1, 2004
Xap Corporation ("Xap"), the company that operates Pathways of North Carolina, recognizes and respects the privacy interests of Pathways of North Carolina users. Xap 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'S PRIVACY POLICY AND ITS EXCEPTIONS
Except as set forth below, personally identifiable data you enter on Pathways of North Carolina 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) and Xap 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 purpose, except with your express consent, at your direction, 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, Xap or UNCGA will supply such information contained in your Pathways of North Carolina account as Xap or UNCGA reasonably determines, based on the advice of counsel, it is legally required to supply. In addition, Xap or 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 Pathways of North Carolina.

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 Pathways of North Carolina, 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 Pathways of North Carolina, and the third reason is to enable Xap to respond to your questions or contact you when necessary in connection with the functioning of Pathways of North Carolina. 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 Pathways of North Carolina, your browser will automatically transmit to Pathways of North Carolina'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.

MINIMUM AGE OF 13 REQUIRED TO ESTABLISH AN ACCOUNT
Pathways of North Carolina will not collect any information from persons who are not yet 13 years old. If you are under 13 years of age, you are not authorized to create an account on Pathways of North Carolina, but you can utilize those portions of Pathways of North Carolina that do not involve the collection of personal information from users.

If you are 13 years of age or older, you are encouraged to create an account on Pathways of North Carolina and to utilize all of Pathways of North Carolina, which will help you plan, prepare and pay for your future education.

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: Your personal identifying information may also be used for the following purposes: 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: UNCGA, which administers the Pathways of North Carolina program, will have access to your personally identifying information. UNCGA has agreed to treat all personally identifying information that you entered on Pathways of North Carolina and which has been made available to UNC as educational records under the provisions of the Family Educational Right and Privacy Act (FERPA), and on that basis the personally identifying information will receive from UNCGA the privacy protections afforded by FERPA.

When visiting Pathways of North Carolina, you may link from Pathways of North Carolina 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 Pathways of North Carolina 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 Pathways of North Carolina server and when in route between the Pathways of North Carolina 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. Pathways of North Carolina uses 56-bit, Secure Socket Layer encryption supported by both Netscape's and Microsoft's browsers.

Data residing on the Pathways of North Carolina 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 of Xap who require such access to administer and maintain the Pathways of North Carolina system or to provide requested customer support to users of Pathways of North Carolina, 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 Xap employee who has access to the data residing on the Pathways of North Carolina 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 Pathways of North Carolina. Cookies enable you to maintain continuity as you move from page to page on Pathways of North Carolina 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 Pathways of North Carolina and are erased when you log off Pathways of North Carolina 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 Pathways of North Carolina services might not function properly when cookies are not utilized.

LINKS
Pathways of North Carolina hosts links to other sites or resources having privacy policies that may differ from those of Pathways of North Carolina. Xap is not responsible for the privacy practices or the content of any websites to which Pathways of North Carolina links or for the conduct of persons operating those websites. Xap, UNCGA and the colleges and the associations of colleges and agencies represented on Pathways of North Carolina do not have control over and do not endorse such external sites and resources. Xap, UNCGA, and the colleges, association of colleges or any other state agency represented on Pathways of North Carolina shall not be liable for any content, advertising, products or other materials on or available from such sites or resources. In addition, Xap, UNCGA, the colleges, association of colleges or any other state agency represented on Pathways of North Carolina 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 AND DELETING YOUR INFORMATION
You may update, otherwise modify or delete from the data stored on Pathways of North Carolina any personal information you previously provided. To modify personal information, (i) log on to Pathways of North Carolina, (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 personal information, (i) log on to Pathways of North Carolina, (ii) access your user profile, and (iii) delete the information you want to remove from Pathways of North Carolina using standard word-processing techniques. Please recognize that if you delete information, it will no longer be available on Pathways of North Carolina so that, for example, if a college to which you previously submitted an application were to attempt to retrieve that application from Pathways of North Carolina after you made the deletion the deleted information would no longer be accessible. Similarly, when accessed over Pathways of North Carolina, 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 Pathways of North Carolina 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's National College Savings Program

Program 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 North Carolina's National College Savings Program, has certain nonpublic personal information about Participants and Beneficiaries obtained from 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 Account investments and otherwise to operate the Program. The Authority may disclose the information collected, as described above, to a third party in order to market jointly the programs and services that the Foundation 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, maintain the confidentiality of all nonpublic personal information. The Authority requires all of these persons to protect the confidentiality of nonpublic personal information about Participants and Beneficiaries. The Authority may also share information about Participants and Beneficiaries with the Participant's financial advisor designated by the Participant on the Enrollment Agreement. The Authority does not otherwise provide nonpublic personal information about Participants or Beneficiaries to third parties, except to the attorneys, accountants or auditors who represent the Program 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.