YOUR PRIVACY IS OUR PRIORITY

At Higher One, 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.higheroneaccount.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:

• Implementing numerous stringent physical and electronic security features to prevent unauthorized access;
• Conducting frequent reviews of our computer systems, including security features and data encryption;
• Limiting employee access to customer information to only those employees who need it for the normal performance of their jobs by requiring our employees to acknowledge, in writing, their individual responsibility to maintain the confidentiality of all customer information; and
• Always applying the same privacy policies and practices to our former customers that we do to our existing customers.

Higher One is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent organization whose mission is to build users’ trust and confidence in the internet by promoting the use of fair information practices. Higher One has elected to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe.

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.

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.

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.

Higher One uses a third party agent to fulfill your transactional and payment processing banking needs made on the Site. This third party agent is a financial banking institution in compliance with all the legal requirements of operating in this capacity and is 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 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-personally identifiable 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 personally identifiable 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.

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 (Edhance) with whom we share your personal information to facilitate this service and is only open to current students. The information shared is Higher One UserID, Name, Birth Year, Gender (if available), Role at College (if available), Enrollment Status (if available), Primary Email Address, School Affiliation, Card Number, Card Status, and Last Activity Date. 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 navigating through the following steps: (a) logging-in to your Account website, (b) clicking on the OneRewards menu option, (c) clicking on "Enter OneRewards.com", (d) clicking on the "My Account" menu option, and (e) selecting the Preferences tab. You can opt out of the rewards program by either (a) logging-in to your program website at www.higheronecard.com, clicking on Higher One's internet-based customer service system "EasyHelp" and then opening an "incident" requesting removal from the Program or (b) by calling a Higher One customer service representative at 1-866-751-7734.

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.

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.

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

Customer Service Mailing Address:
Higher One, Inc.
25 Science Park
#201
New Haven, CT 06511

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 Policy last updated: 9/30/2009