Privacy Statement
The Board of Trustees of the College Savings Plans of Nevada Privacy Statement
The Board of Trustees (the "Board") considers the privacy and security of the nonpublic, personal information it holds concerning each account owner and designated beneficiary of the SSGA Upromise 529 Plan (the "Plan") a top priority. The Board has also received an assurance from Ascensus Broker Dealer Services, Inc. (the "Program Manager") that it is also a top priority for the Program Manager. Specifically, the Board and the Program Manager adhere to the following privacy policy for the benefit of current and past account owners and designated beneficiaries:
The types of nonpublic, personal information collected by the Board and the Program Manager may include:
- Information the account owner or designated beneficiary provides to the Plan on the application or otherwise, such as name, address, and Social Security number;
- Information the account owner or designated beneficiary provides to the Plan on the application or otherwise, such as name, address, and Social Security number;
- Information the Board and the Program Manager may acquire as a result of administering an account, such as transactions (contributions or distributions) or account balances; and
- Information from third parties, such as credit agencies.
Neither the Board nor the Program Manager will disclose such nonpublic, personal information to anyone except as permitted by law. The account owner should also carefully review the privacy policy of Ascensus College Savings, which is referenced below and more fully described in the account opening materials and below. Privacy policies may be modified or supplemented at any time.
Security
The Board and the Program Manager maintain appropriate physical, electronic, and procedural safeguards to protect this nonpublic, personal information about account owners and beneficiaries.
Ascensus College Savings Privacy Statement
Protecting your privacy is a top priority at Ascensus College Savings. We want you to understand how we handle the personal information about you that we may obtain and the high standards we employ to safeguard this information. Ascensus Broker Dealer Services, Inc. and its affiliate, Ascensus Investment Advisors, LLC (collectively, "Ascensus College Savings"), collect personal information on 529 plan web sites in our capacity as service providers on behalf of state administrators of 529 plans (each, a "State Administrator"), as well as through other web sites that we maintain. This statement covers the information handling practices for Ascensus Broker Dealer Services, LLC. and Ascensus Investment Advisors, LLC (referred to in the privacy statement collectively as "we" or "us").
Information We May Obtain
We may obtain your personal information from the following sources:
- Information you provide to us on applications and other forms, that you otherwise enter on a 529 plan web site or other web sites that we maintain, or that you provide to us in writing or by telephone, such as when you contact a 529 plan's customer service center. This information may include items such as your name, address, telephone number and social security number. In addition, please see Use of Cookies and other Technologies below for information we receive automatically when you visit a 529 plan web site or other web sites that we maintain.
- Information from your transactions with us, our affiliates or nonaffiliated third parties.
- Information from third parties, including public sources, such as verification services and consumer reporting agencies (to comply with regulatory requirements, help ensure the accuracy of data and prevent fraud, for example), or from other sources (such as from other institutions like a bank or broker you use to transfer funds into a 529 plan account, or public sources).
We use the information we obtain primarily to process transactions in your accounts, and to fulfill legal and regulatory requirements. With a State Administrator's consent, we may also use this information to offer products and services related to your 529 plan account.
Unless prohibited by law, you have the right to view any personally identifiable information collected from you through your visits to or use of a 529 plan web site or other web sites that we maintain, to make corrections to such information if necessary, or to request that such information be removed from our systems. You may do so by contacting us at the address indicated at the end of this policy or, with respect to information submitted through your use of a 529 plan web site, by contacting a customer service representative for the applicable 529 plan.
Security of Your Personal Information
Ascensus College Savings is committed to earning and keeping your trust. We understand the need for your personal information to remain secure and private, and we have implemented policies and procedures designed to safeguard your information. We restrict access to nonpublic personal information about you to those employees who need that information in order to provide products or services to you. We maintain physical, electronic, and procedural safeguards to guard your nonpublic personal information.
Please remember that you also play a valuable part in data security. You should never share your 529 plan account information, user name or passwords with anyone. If you feel your password has been compromised, you should change it immediately. After you have finished using a 529 plan web site, you should log out of your 529 plan account and exit your browser so that no unauthorized persons can use the 529 plan web site under your name and account information. If you become aware of any suspicious or unauthorized conduct, you agree to contact Ascensus College Savings immediately.
Email submissions over the internet may not be secure. Please consider this fact before emailing any personal or confidential information.
How We Handle Your Personal Information
We do not provide your information to any affiliated or unaffiliated third parties to enable them to market their products and services directly to you, nor do we share your information with affiliated or unaffiliated third parties other than under the following circumstances:
- Service Providers. We may share personal information about you with unaffiliated third-party agents and service providers to perform functions on our behalf, such as printing and mailing 529 plan account statements and servicing 529 plan accounts. Before we disclose any of your personal information to these service providers, we require them by legal agreement to keep this information confidential and to use it only as authorized. They are not authorized to use this information for their own purposes or to sell this information to any other person
- Other Individuals or Organizations. We may share personal information about you with other individuals or organizations, at your direction or as directed by your representative in order to service your 529 plan account (for example, if you authorize a financial advisor to submit transactions on your behalf or if you request to enroll in the Upromise Service).
- Legal Requirements. We may disclose personal information about you to affiliated and unaffiliated third parties when we believe such disclosure is appropriate to comply with a legal requirement, such as a law, regulation, court order, subpoena or search warrant, or in the course of a legal proceeding or to protect the rights, property, or safety of Ascensus College Savings and you, including exchanging information for fraud protection.
- Affiliates. We may also disclose personal information about you, as necessary, to our affiliates, to satisfy contractual obligations with a State Administrator or to enforce our rights thereunder, or to protect the rights, property or safety of Ascensus College Savings and you, including exchanging information for fraud protection.
Use of Cookies and other Technologies
Our web servers place and read "cookies" on the 529 plan web sites and other web sites that we maintain for a variety of purposes. Cookies are small data files that are stored on an Internet user's web browser by a web server. One important use of cookies is to help identify you while you are logged onto a 529 plan web site or other web sites that we maintain. Consequently, if your browser does not accept cookies, you may be unable to enroll or log onto the 529 plan web sites and other web sites that we maintain. You will, however, be able to browse the 529 plan web sites and other web sites that we maintain as a visitor. The information Ascensus College Savings collects from cookies and web server logs is used to administer your account and customize information you receive when visiting a 529 plan web site or other web sites we maintain. Ascensus College Savings may also use and share aggregate information from cookies and web server logs to analyze and improve our web service offerings. This information does not identify individual visitors or customers.
As is true of most web sites, we gather certain information automatically and store it in log files. This information may include the internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, to administer the 529 plan web sites and other web sites that we maintain, to track users' movements around the web sites and to gather demographic information about our user base as a whole.
We employ cookies and/or small pieces of code known as "web beacons" or "clear gifs" that, on an anonymous basis, count users that have visited a page that contains these web beacons. We use web beacons to help us better manage content on the 529 plan web sites and other web sites that we maintain and to determine which content is effective. Web beacons on the 529 plan web sites and other web sites that we maintain are not used to collect personally identifiable information about you. Finally, we may use web beacons in our HTML-based emails to let us know which emails have been opened by recipients so that we may gauge the effectiveness of our communications. If you would like to opt out of these emails, please see the instructions in the email regarding how to opt-out.
If you have not opted-out of receiving marketing messages, we may use information from our log files, cookies or web beacons to help us make those communications more useful or interesting to you. As a result of your accessing the 529 plan web sites and other web sites that we maintain, we may collect information about your web site usage. We utilize this data in conjunction with data from the rest of our online visitor population to determine how to provide better products or services. The reports which are created from web site usage information contain aggregate visitor statistics and will not personally identify you.
Choices Regarding the Receipt of Marketing Messages
You may choose whether and to what extent you receive marketing messages from us related to a 529 plan. If you do not wish to receive marketing messages, you may opt out by following the instructions in the email regarding how to opt out. We reserve the right to send you specific administrative notices that are required by law, regulation, or as needed to service your 529 plan account.
Collection of Information from Children
None of the 529 plan products or services we offer or maintain are intended for purchase by children. Accordingly, we do not knowingly collect, either online or offline, personally identifiable information from children under the age of 13.
Changes to This Privacy Statement
If we materially change this statement or our information handling practices as described in this statement, we will notify you by email and/or through a notice on the 529 plan web sites, as applicable, and the other web sites that we maintain prior to the implementation of any such change.
Additional Rights
In addition to the rights described in this policy, please note that you may have additional rights under state law.
State Street Global Advisors Privacy Statement
Under the terms of the agreement among the Board, SSGA, Ascensus Broker Dealer Services, Inc. and Ascensus Investment Advisors, LLC, SSGA is required to treat all Account Owner and Beneficiary information confidentially. SSGA is prohibited from using or disclosing such information, except as may be necessary to perform its obligations under the terms of the agreement, or if required by applicable law, by court order, or other order.
Privacy of Upromise® Service
Upromise, Inc., offers a loyalty program (the "Upromise Service"), which enables participants in the Upromise Service to earn rebates and other cash awards from participating merchants. The Upromise Service is a separate service from the Plan and Upromise, Inc. has its own separate privacy policy. If you choose to enroll in the Upromise Service, the privacy policy for Upromise, Inc. may be found at www.upromise.com.