Educational Finance Institute, Inc. dba the Prospect Institute for Educational Finance ("Prospect") is the owner and operator of www.Prospectinstute.com (the "Site"). Users of this site may provide certain personal data and information to Prospect in order to take full advantage of the functionality, services and benefits of the Site. It is of utmost importance to Prospect to safeguard and protect the information provided, by you and to disseminate information to other parties ONLY with the explicit permission and direction of each individual User of the Site.
The purpose of this Privacy Statement is to disclose to Users and potential Users of the Site the information practices of the Site. In this Privacy Statement you will find Prospect's policies regarding the following:

1. What personally identifiable information Prospect collects.
2. What personally identifiable information third parties via the Site at the direction of each individual User.
3. What organization collects the information.
4. How Prospecct uses the information.
5. With whom Prospect may share user information.
6. What choices are available to users regarding collection, use and distribution of the information.
7. What types of security procedures are in place to protect the loss, misuse or alteration of information under Prospect's control.
8. How users can correct any inaccuracies in the information.

If users have questions or concerns regarding this statement, they should first contact [NAME OF INDIVIDUAL, DEPARTMENT OR GROUP RESPONSIBLE FOR INQUIRIES] by [CONTACT INFORMATION: EMAIL, PHONE, POSTAL MAIL]

Information Collection and Use

Information Collection
Prospect is the sole owner of the information collected on the Site. Prospect collects information from our users at several different points on our Site. In addition, a Users employer may provide some information, such as name and Social Security Number, to Prospect in order to verify the Users eligibility to use the Site.

Registration
In order to use the Site, a User must be an employee, consultant or agent made eligible by a Prospect Client. During a Users initial visit to the Site the User will be asked to register. During registration a User will be required to provide contact information such as name and email address(es) as well as name and social security number to verify the User's identity MORE INFO REQUIRED AT REGISTRATION??. Once a Users identity is verified the user will be asked to select a username and password. This username and password will be used to login during future visits to the Site. There may also be some optional information the User may provide in order to utilize various services of the Site such as demographic information (such as income level and gender) so we can provide a more personalized experience on our site.

529 Plan Enrollment
If a User wishes to enroll in a 529 Plan additional information will be requested from the User in order to properly fill-out and populate the actual enrollment form for the 529 Plan selected. This information will include but is not limited to names, social security number, address, date of birth, bank account information, and phone number, for the account owner, contingent account owner, beneficiary and contingent beneficiary MORE TYPES OF INFO??? This information is used solely to allow User to enroll in an IRS section 529 account ("529 Plans") and will only be sent to a 529 account manager upon the explicit direction of User to do so.

Bank Account Creation
Users may create a bank account in which to save for, and from which to fund, 529 Plans. In order to create this account information including but not limited to Name, address, social security number, MORE INFO> This information is used solely to allow User to open a bank account ("Bank Account") and will only be sent to a 529 account manager upon the explicit direction of User to do so.

Information Use
The Site is a proprietary web based platform that enables Users to select, enroll and regularly fund a Section 529 Plan. The Prospect Platform is comprised of educational components, State Plan specific content, decision support tools and access to certain administrative services.

Profile
We store information that we collect through cookies, log files, clear gifs, and/or third parties to create a profile of our Users. A profile is stored information that we keep on individual Users that details their viewing preferences. Consequently, collected information is tied to the Users personally identifiable information to improve the content of the site for the User. This profile is used to tailor a user's visit to our Web site, and may be used to direct pertinent information to the User. We will not and do not share your profile with other third parties unless explicitly directed to do so by a User.

Cookies
A cookie is a piece of data stored on the User's computer tied to information about the user. We use both session ID cookies and persistent cookies. For the session ID cookie, once users close the browser, the cookie simply terminates. A persistent cookie is a small text file stored on the User's hard drive for an extended period of time. Persistent cookies can be removed by following Internet browser help file directions. [Provide a link to information on cookies if possible.]

By setting a cookie on our site, Users would not have to log in a password more than once, thereby saving time while on the Site. Users may reject the Cookie, and If Users do reject the cookie reject the cookie, they may still use the Site and all of its features. Persistent cookies enable us to track and target the interests of our users to enhance the experience on our site. See the "Profile" section.

Third Party Advertising
The ads appearing on this Web site are provided by our Partners. Users information, including but not limited to Profile and Cookie information will not be provided to these partners absent visit to this site, such as number of times they have viewed an ad (but not user name, address, or other personal information), is used to serve ads to users on this site. For more information about [THIRD PARTY AD SERVER NAME], cookies, and how to "opt-out",

This privacy statement covers the use of cookies by [NAME OF SITE] only and does not cover the use of cookies by any advertisers.

Log Files
Like most standard Web site servers we use log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track user's movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to personally identifiable information. [IP addresses are tied to personally identifiable information to enable our Web-based service.] [We use a tracking utility called [XXXX] that uses log files to analyze user movement.][Webtrendslive users may have further obligations of particular language per their license with Webtrendslive. See your license agreement.] [See the Profile section below.]

Clear Gifs (Web Beacons/Web Bugs)
We employ [or our third party advertising company employs] a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. The main difference between the two is that clear gifs are invisible on the page and are much smaller, about the size of the period at the end of this sentence. [Clear gifs are tied to users' personally identifiable information.] [Clear gifs are not tied to users' personally identifiable information.]

Clear Gifs can "work with" existing cookies on a computer if they are both from the same Web site or advertising company. That means, for example, that if a person visited "www.companyX.com", which uses an advertising company's clear gif, the Web site [or advertising company] would match the clear gif's identifier and the advertising company's cookie ID number, to show the past online behavior for that computer. This collected information would then be given to the advertising company [or Web site]. To learn more about our advertising company's use of clear gifs, please go to [NAME OF ADVERTISER'S SITE.]

In addition, we use clear gifs in our HTML-based emails to let us know which emails have been opened by the recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If users would like to opt-out of these emails, please see the Opt-out section.

Communications from the Site

Special Offers and Updates
We send all new members a welcoming email to verify password and username. Established members will occasionally receive information on products, services, special deals, and a newsletter. Out of respect for the privacy of our users we present the option to not receive these types of communications. Please see the Choice and Opt-out sections.

Newsletter
If a user wishes to subscribe to our newsletter, we ask for contact information such as name and email address. Out of respect for our users privacy we provide a way to opt-out of these communications. Please see the Choice and Opt-out sections.

Service Announcements
On rare occasions it is necessary to send out a strictly service related announcement. For instance, if our service is temporarily suspended for maintenance we might send users an email. Generally, users may not opt-out of these communications, though they can deactivate their account. However, these communications are not promotional in nature.

Customer Service
We communicate with users on a regular basis to provide requested services and in regards to issues relating to their account we reply via email or phone, in accordance with the Users wishes.

Sharing

Legal Disclaimer
Though we make every effort to preserve user privacy, we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with all applicable law, a current judicial proceeding, a court order or similar legal process following proper service upon Prospect.

Aggregate Information (non-personally identifiable)
We share aggregated demographic information with our partners and advertisers. This is not linked to any personally identifiable information it is simply a communication of the demographic of our Users, or subsets of Users, as a whole.

These are the instances in which we will share Users' personal information:

[Specifically describe any sharing of personally identifiable information. For example, describe actual practices where the site is sharing personally identifiable information. Include sharing scenarios where the partner can dispose of the information either in the manner that they see fit, or where the partner can use the personal information for a limited circumstance or series of limited circumstances. Another example might include sharing with parent companies, subsidiaries or affiliated companies for reasons other than corporate record keeping purposes. Typically these kinds of sharing arrangements occur when the third party will then own or control the customer relationship. Below are some examples of the different types of relationships or situations involving sharing personal information with third parties that may exist. Keep in mind that sharing personally identifiable information for secondary purposes, must incorporate an opt-out prior to the sharing.]

Employer
If requested by the employer under which you initially accessed the Site, your employer may be provided with both aggregate and personally identifiable information, for so long a period as you remain employed by said employer. This information will be used to conduct activities such as gauging participation in 529 Plans, and providing personalized financial statements.

Third Party Intermediaries
We use an outside fulfillment company to send User 529 enrollment packages and other items requested by Users. We use a credit card processing company to bill Users who wish to fund 529 accounts via credit cards. These companies do not use personally identifiable information for any secondary purposes.

Service Providers ANY MORE TO ADD HERE?
We partner with other third parties [ANOTHER PARTY'S NAME] to provide specific services. [For example, XXXX] When the user signs up for these particular services, we share names, or other contact information [specify what information is being shared with the third party service provider] that is necessary for the third party to provide these services. These third parties are not allowed to use personally identifiable information except for the purpose of providing these services.

Business Transitions
In the event Prospect goes through a business transition, such as a merger, being acquired by another company, or selling a substantial portion of its assets, Users' personal information will, in most instances, be part of the assets transferred. Users will be notified via prominent notice on our Web site for 30 days prior to a change of ownership or control of their personal information. If as a result of the business transition, the Users' personally identifiable information will be used in a manner different from that stated at the time of collection they will be given choice consistent with our notification of changes section.

Choice/Opt-out
Our users are given the opportunity to 'opt-out' of having their information used for purposes not directly related to our site at the point where we ask for information. For example, certain optional services of the Site will have an 'opt-out' mechanism so Users who enroll in a 529 Plan by utilizing the Site can restrict the use of their personal information for any other purposes.

Users who no longer wish to receive our newsletter and promotional communications may opt-out of receiving these communications by replying to unsubscribe in the subject line in the email or email us at [EMAIL ADDRESS] [We also offer an opt-out mechanism on the [MEMBER INFORMATION PAGES] or the user may contact us at [PHONE] [EMAIL] or [POSTAL MAIL] to opt-out.]

Users of our site are always notified when their information is being collected by any outside parties. We do this so our users can make an informed choice as to whether or not they should proceed with services that require an outside party.

Links
This Web site contains links to other sites. Please be aware that we, Prospect, are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every Web site that collects personally identifiable information. This privacy statement applies solely to information collected by the Site. [any co-branding and/or framing relations where the user may not know who is collecting the information???].

Surveys [& Contests] Scholarship contest? DELETE?
[From time-to-time] our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and shipping address), and demographic information (such as zip code). Contact information will be used [shared with the contest [survey] sponsors] to notify the winners and award prizes. [Anonymous] Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site. Users' personally identifiable information is not shared with third parties unless we give prior notice and choice. Though we may use an intermediary to conduct these surveys or contests, they may not use users' personally identifiable information for any secondary purposes.

Tell-A-Friend DELETE?
If a user elects to use our referral service for informing a friend about our site, we ask them for the friend's name and email address. [NAME OF COMPANY] will automatically send the friend a one-time email inviting them to visit the site. [NAME OF COMPANY] stores [or does not store] this information for the sole purpose of sending this one-time email [and tracking the success of our referral program]. The friend may contact [NAME OF COMPANY] at [INSERT URL OR EMAIL ADDRESS] to request the removal of this information from our database.

Security
This Site takes every precaution to protect our users' information. When users submit sensitive information via the Site, their information is protected both online and off-line.

When our registration/enrollment asks Users to enter sensitive information such as bank account numbers, credit card number and/or social security number, that information is encrypted and is protected with the industry standard encryption software - SSL. While on a secure page, such as our order form, the lock icon on the bottom of Web browsers such as Netscape Navigator and Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, when users are just 'surfing'. [To learn more about SSL, follow this link [INSERT LINK].]

While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect user-information off-line. All of our Users' information, not just the sensitive information mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job (for example a customer service representative) are granted access to personally identifiable information. Our employees must use password-protected screen-savers when they leave their desk. When they return, they must re-enter their password to re-gain access to user information. Furthermore, ALL employees are kept up-to-date on our security and privacy practices. Through training and ongoing education our employees are notified and/or reminded about the importance we place on privacy, and what they can do to ensure our Users' information is protected. Finally, the servers that store personally identifiable information are in a secure environment, [behind a locked cage][in a locked facility]???.

If users have any questions about the security at our Web site, users can send an email to [EMAIL ADDRESS.]

Supplementation of Information
In order for this Web site to properly fulfill its obligation to users it is necessary for us to supplement the information we receive with information from 3rd party sources.

ID [Address] Verification anything else - credit check's?
We use [THIRD PARTY/THIRD PARTY SOFTWARE] to verify a user's [identity][address] to [state why it is necessary to verify the user's identity or address].

Correcting/Updating/Deleting/Deactivating Personal Information
If a user's personally identifiable information changes (such as zip code, phone, email or postal address), or if a user no longer desires our service, we provide a means in which to correct, update or delete/deactivate Users' personally identifiable information. This can usually be done at the [member information page].

Notification of Changes
If we decide to change our privacy policy, we will post those changes to this privacy statement, the homepage, and other places we deem appropriate so our Users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We will use information only in accordance with the privacy policy under which the information was collected.

If, however, we are going to use Users' personally identifiable information in a manner different from that stated at the time of collection we will notify Users via email or personalized messaging internal to the Site. Users will have a choice as to whether or not we use their information in this different manner. However, if users have opted out of all communication with the site, or deleted/deactivated their account, then they will not be contacted, nor will their personal information be used in this new manner. In addition, if we make any material changes in our privacy practices that do not affect User information already stored in our database, we will post a prominent notice on our Web site notifying users of the change. In some cases where we post a notice we will also email users, who have opted to receive communications from us.

Trust-e Certification

Prospect is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent, non-profit organization whose mission is to enable individuals and organizations to establish trusting relationships based on respect for personal identity and information by promoting the use of fair information practices. This privacy statement covers the site [WWW.URL OFSITE.COM do we have one universal site if coming via the intranet???]. Because this Web site wants to demonstrate its commitment to our users' privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe.

[Include this Software Disclaimer as the last sentence in the TRUSTe opening statement if the site has a downloadable software application or apple I don't believe we have this - KBPt: The TRUSTe program covers only information that is collected through this Web site, and does not cover information that may be collected through software downloaded from the site. By displaying the TRUSTe trustmark, Prospect has agreed to notify Users of Site of the above described information practices.

Contact Information

If users have any inquiries or suggestions regarding our privacy policy, please contact us at:

Phone
Fax
Email
Postal Address
Web site URL [HELP DESK OR CUSTOMER SUPPORT OR PRIVACY OFFICER]

If you do not receive acknowledgment of your inquiry or their inquiry is not satisfactorily addressed, they should then contact TRUSTe through the TRUSTe Watchdog Dispute Resolution Process (http://www.truste.org/users/users_watchdog.php). TRUSTe will serve as a liaison with the Web site to resolve users concerns.
03/31/03