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Privacy Statement

TRUSTe online privacy certification
YOUR PRIVACY IS OUR PRIORITY

At Higher One, Inc. (further referred to as "Higher One," "We," "Us," and "Our"), we take your privacy and online security very seriously. During card set up, you’re providing us with personal information about yourself. Higher One understands the importance of protecting the safety and confidentiality of the information you provide and we treat this information with the utmost security and respect. This Privacy Statement (this 'Statement') details what personal information we collect from our users’ as well as how we use it and safeguard it. This Statement applies exclusively to www.GPCOne.com (the 'Site').

In addition to any legal compliance associated with the handling of your information, Higher One wants to earn your trust. Therefore, we’ve taken a number of steps to make sure that your information is as safe as possible, including but not limited to:

Higher One has been awarded TRUSTe’s Privacy Seal signifying that this privacy statement and practices have been reviewed by TRUSTe for compliance with TRUSTe’s program requirements including transparency, accountability and choice regarding the collection and use of your personal information. TRUSTe’s mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions.

If you have questions or concerns regarding this Statement, you should first contact us at privacy@higherone.com. If you do not receive acknowledgement of your inquiry, or the inquiry is not addressed to your satisfaction, contact TRUSTe. TRUSTe shall then serve as a liaison with us to resolve your concerns. The TRUSTe program covers only information collected through this Web site.

Information Collection and Use
When you visit the Site as a user, you can browse anonymously. When you visit the Site to activate your debit card, we require certain personal information from you. Specifically, we request your card number and require you to establish a username and passcode. We also collect your banking information including account number and routing number, which is stored as a part of your user account record, which includes information such as your name, email and physical address, phone number, social security number, government issued ID, and date of birth. This collected information establishes your online account profile. Please note that we use this collected information to service your account needs as they arise. Higher One does not share your personal information with any third parties for their promotional purposes. We may also use your email depending on your selected preferences to send you promotional emails with news of our contests and new product offerings.

Higher One collects certain information from visitors and users of the Site including, but not limited to, Internet addresses. This web site navigational information is collected and retained to help diagnose technical problems, to analyze trends, to track users' movements and to administer the Site in order to constantly improve the quality of the Site and our service. Higher One may also track and analyze individual usage and volume statistical information from our visitors and customers. We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at privacy@higherone.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Information Sharing and Disclosure
Under certain circumstances, Higher One may disclose collected information to third parties or government agencies where necessary to comply with (i) a formal request or (ii) applicable law including, but not limited to, responding to a subpoena, a judicial proceeding, or a court order. We also reserve the right to disclose information to our service providers where necessary in allowing us to facilitate services to you on our behalf.

Higher One may disclose and transfer the information obtained from you through this Site or the service as part of a merger, acquisition or other sale of its assets or business. In such an event, the users shall be notified of any material changes to the information practices governing your information by email, or a prominent notice on the Site. If Higher One is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Higher One uses third party agents, such as financial banking institutions and financial services companies, to fulfill your transactional and payment processing banking needs made on the Site. These third party agents provide services for Higher One in compliance with all the legal requirements of operating in this capacity and are authorized to use your shared personal information specifically and exclusively for fulfilling banking transactions on our behalf. We also employ the services of a third party agent in hosting our FAQ section.

When a user elects to transfer money to another Higher One account holder, we request the third party’s name, email, mailing address and banking information such as account and routing number to fulfill the requested transaction. We do not use or share this third party personal information for any purposes beyond fulfilling your request.

Access & Opt-Out
If, at any time after establishing your preferences to receive promotional offers from us you change your mind, you may opt-out of receiving these secondary communications. To opt-out, you must select the "Unsubscribe" link present in each email we send out to our users. You can also unsubscribe by updating your account preferences when you access your personal account information. We reserve the right to send users notification and administrative emails, which are considered a part of your service. To modify any of your account information, access your account through the site and update your preferences. To delete your account information entirely, please contact us at privacy@higherone.com.

Cookies
When you visit our Site, our Web server sends a cookie to your computer. Cookies are files that Web browsers place on a computer’s hard drive and are used to indicate whether you have visited the Site previously.

Choices about Cookies: You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. (Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.) Should you choose to reject all cookies, you will not be able to use services that require you to "sign in," and you may not be able to take full advantage of all of our offerings.

Our Practices Regarding Cookies: Higher One uses cookies for a number of purposes, including to: access your account information when you "sign in," so that we can provide you with customized content, keep track of preferences you specify while you are using the Site, estimate and report our total audience size and traffic. From time to time, we may make use of pixel tags such as web beacons. Used in combination with cookies, a Web beacon is an often-transparent graphic image, usually no larger than 1 pixel x 1 pixel, that is placed on a Web site, or in an e-mail and is used to monitor the behavior of the user visiting the Web site, or sending the e-mail. When the HTML code for the Web beacon points to a site to retrieve the image, at the same time it can pass along information such as the IP address of the computer that retrieved the image, the time the Web beacon was viewed and for how long, the type of browser that retrieved the image and previously set cookie values.

Third Party Cookies
We may from time to time engage third parties to track and analyze non-personal information usage and volume statistical information from visitors to our Site to help us administer our Site and improve its quality. Such third parties may use cookies and web beacons to help track visitor behavior. These tracking technologies shall not be used to associate individual website visitors to any personal information. All data collected by such third parties on our behalf is used only to provide us with information on Site usage and is not shared with any other third parties. We do not have access to third party tracking technologies.

We use a third-party tracking service, which uses HTML tags to track non-personal information about our visitors to our site in the aggregate to capture usage and volume statistics. Some of our business partners use HTML tags on our site. This privacy statement covers the use of these tracking technologies only.

Third-Party Sites
The Site contains links to other websites. Higher One is not responsible for the privacy practices or the content of these other websites. Users and visitors will have to check the policy statement of these other websites to understand their respective policies. Users and visitors who access a linked site may be disclosing their private information. It is the responsibility of the user to keep such information private and confidential.

Third Party Partnership Disclosure
When you open an account with Higher One, you are automatically enrolled in a rewards program. This program is hosted by a third party service provider (Cartera Commerce, Inc ) with whom we share your personal information to facilitate this service. The information shared is Higher One UserID, First Name, Gender, Account Type, Primary Email Address, Last 4 Digits of Card Number and Zip Code. Our third party agent is authorized to access this information for the explicit purpose of fulfilling a service on our behalf; consequently your personal information is not used for any promotional purposes. You will receive administrative communications via email from the third party service provider to confirm your enrollment in the program, confirm earnings, and for verification purposes. You can opt-out of such OneRewards emails by selecting the "Unsubscribe" link located in the email. You can opt out of the rewards program by either (a) logging-in to your Account website, clicking on "Cash Back / OneRewards" in the Account menu and then selecting the "Unsubscribe from OneRewards" link at the bottom of the OneRewards page or (b) by emailing privacy@higherone.com.

Targeted Ads Disclosure
We partner with a third party ad network to either display advertising on our Web site or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect non-personal information about your activities on this and other Web sites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving your targeted ads, you may opt-out by clicking here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

Security and Data Storage
Our Site has security measures in place to help protect against the loss, misuse, and alteration of the personal information and data under our control. Higher One hosts the Site in a secure server environment that uses a firewall and other industry-standard technology to help prevent interference or access from outside intruders including the use of Secure Socket Layer technology during the transmission of sensitive information. Higher One also requires that unique user names and passwords must be entered each time a user logs on to the Site.

Social Media Widgets
Our Web site includes social media features, such as the Facebook button and widgets, such as the Share this button or interactive mini-programs that run on our Site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy statement of the company providing it.

Changes to this Statement
Higher One may update this Statement at any time so please review it frequently. If we make any material changes, we will notify you, by email or by a notice posted on the home page of the Site prior to such changes becoming effective.

Questions
If you have any questions about this Statement or the practices of this Site, please contact us using one of the methods listed below.

Email
privacy@higherone.com

Customer Service Mailing Address:
Higher One, Inc.
105 Munson St
New Haven, CT 06511

More options to Contact Us

Your trust in Higher One is essential to us and that is why it is critical that Higher One goes above and beyond what is required of us to assure you and your family that we’re concerned and proactive with your online security. If you have problems or concerns, you can contact Customer Service at anytime (24 hours a day). Log on to your program website, and click on the link for "EasyHelp", where you can find answers to frequently asked questions, or even submit a question or concern.

Privacy Statement last updated: 9/14/2013