Privacy Principles

1. We respect your privacy.
We will not provide your personally identifiable information to nonaffiliated third parties (including our contributing companies) for marketing purposes without your permission, except in limited circumstances in connection with the Virburbia Rewards service.

2. We secure your data.
We monitor for intrusion attempts 24 hours a day, 7 days a week; deploy encryption technology, firewalls and systems monitoring; and audit our safeguards with the help of leading security firms.

3. We offer you choices.
You may choose whether and to what extent you receive marketing messages from Virburbia and our contributing companies. If you do not wish to receive marketing messages, you may opt out at any time. And we offer you choices, so that you receive only those offers that are of interest to you.

Virburbia Privacy Statement

Protecting your privacy is a top priority at Virburbia. We want you to understand how we handle the personal information about you that we may obtain, and how we may and may not share it. This statement covers all of our information handling practices for Virburbia, Inc. and its subsidiaries, including Virburbia Investments, Inc. and Virburbia Investment Advisors, LLC, for the benefit of current and past customers. Please also see our separate statement, Privacy of Virburbia Rewards Service, for additional information about our practices relating to our Rewards service.

Information We May Obtain.

As part of providing you products or services, we may obtain personal information from the following sources:

• Information you provide to us on applications and other forms, that you otherwise enter on our web site, or that you provide to us in writing or by telephone, such as when you contact our customer service staff. 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 our web site.
• Information from your transactions with us, our affiliates or nonaffiliated third parties such as account activity and your purchase information in our Rewards service.
• Information from third parties, including public sources, such as verification services and consumer reporting agencies (to comply with regulatory requirements, ensure the accuracy of data and prevent fraud), or from other sources (such as from other institutions like a bank or broker you use to transfer funds into a Virburbia account, or public sources).

We use the information we obtain in order to develop, offer and deliver our products and services, to offer products and services of our affiliates, participating companies, marketing partners and other companies, to process transactions in your accounts, and to fulfill legal and regulatory requirements.

Please note that information you voluntarily include in bulletin boards, chat rooms and other online forums, such as the Virburbia Community, may be viewed and used by anyone with access to those forums. Virburbia is unable to control any use of such information.

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Sharing Information With Nonaffiliated Third Parties

Information about our members is an important part of our business. We do not share your personal information with nonaffiliated third parties except as permitted or required by law, including as provided below:

• Agents and Service Providers. In order to provide our products and services, we may share personal information about you with agents and service providers to perform functions on our behalf, such as to send email and postal mail, analyze data, provide marketing services, process applications and credit card payments, and service accounts. We contractually obligate these service providers to access and use personal information only as needed to perform their functions and for no other purposes.

• Financial Services Providers. In order to make certain financial products available to you (for example, credit cards, loans or insurance), we sometimes enter into marketing agreements with nonaffiliated financial institutions that offer those products. We select the financial institutions we work with very carefully. Generally, we provide these entities with only customer contact information. For some products, we might also provide them limited additional information. These entities are permitted to use the information we give them only for the specific products being offered under our contract. If you prefer that we do not share your information with nonaffiliated financial institutions so that they may market their products and services directly to you, you may opt-out of that information sharing by sending us an email at This e-mail address is being protected from spambots. You need JavaScript enabled to view it containing your name, address, account number and request. You may also opt-out of that information sharing by updating your Virburbia account member profile opt-out preferences on our website to opt-out of receiving communications from our participating companies.

• Protection of Virburbia and Others. We may disclose personal information about you to 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. We may also disclose personal information as we believe appropriate to enforce or apply our rights under our agreements with customers, to protect the rights, property or safety of Virburbia, our customers and others, including exchanging information for fraud protection and credit risk reduction.

• Business Transfers. If there is a change of control in Virburbia's business (whether by merger, sale, or otherwise), its customer information could be sold as part of that transaction and your personally identifying information potentially could be used by the purchaser. Notice will be posted on the website so that you are aware of this change of control.

Virburbia does not share member information with nonaffiliated, non-financial institutions to enable them to market their products and services directly to you. Occasionally, we engage third party service providers in the business of facilitating communications to send you information from certain participating companies, but only subject to strict confidentiality provisions that prohibit those third parties from providing your personal information to the participating companies. If we ever make the decision to share member information with nonaffiliated third parties other than financial institutions as described above so that they may market their products and services directly to you, we will notify you ahead of time, and you will have the opportunity to opt-out of that information sharing.

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Use of Cookies and other Technologies

Our web servers place and read "cookies" on our site's visitors' web browser 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 in to the Virburbia site. Consequently, if your browser does not accept session cookies, you will be unable to enroll or log in to our service using our site. You will, however, be able to browse our site as a visitor. The information Virburbia collects from cookies and web server logs is used to administer the web service and customize information you receive when visiting our site. Virburbia 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 includes 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 our web site, to track users' movements around the web site and to gather demographic information about our user base as a whole. We, certain third parties who host portions of our web site, and certain advertising affiliates or others 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 our site and to determine which content is effective. In addition, third party advertising affiliates and others may use web beacons to help us track the effectiveness of our advertisements placed on third party web sites. Web beacons on our site are not used to collect personally identifiable information about our customers. Finally, we 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 "Choices Regarding the Receipt of Marketing Messages."

If you have not opted-out of receiving marketing messages from us about our products and services, we may use information from our log files, cookies or web beacons to help us make those communications more useful or interesting to you.

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Choices Regarding the Receipt of Marketing Messages

You may choose whether and to what extent you receive marketing messages from Virburbia about products and services offered by Virburbia or third parties. You may also choose whether and to what extent you receive marketing messages from our participating companies based on our information. If you do not wish to receive any of these marketing messages, you may opt out. . And we offer you choices, so that you may elect to receive offers that are of interest to you in the ways you wish. If you do not wish to receive marketing messages, you may opt out by sending us an email at This e-mail address is being protected from spambots. You need JavaScript enabled to view it containing your name, address, account number and request. You may also opt-out of receiving marketing emails from Virburbia and marketing messages from our participating companies, by updating your Virburbia account member profile opt-out preferences on our web site. We reserve the right to send you specific administrative notices that are required by law, regulation, or as needed to service your account. In addition, our participating companies reserve the right to contact you using information from sources other than Virburbia.

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Security of Your Personal Information

Virburbia is committed to earning and keeping your trust. We understand the need for our customers' personal information to remain secure and private, and we have implemented policies and procedures designed to safeguard your information. The only Virburbia employees who are authorized to see your personal information are those who need it as part of their jobs.

Please remember that you also play a valuable part in data security. You should never share your Virburbia password with anyone. If you feel your password has been compromised, you should change it immediately. After you have finished using our site, you should log out of your Virburbia account and exit your browser so that no unauthorized persons can use our site under your name and account information.

Collection of Information from Children.

None of Virburbia's products or services are intended for purchase by children. Accordingly, Virburbia does not knowingly collect, either online or offline, personally identifiable information from children under the age of 13.

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State Laws

In addition to the rights described in this policy, please note that you may have additional rights under state law. For example, if your address on file with us is a California address, we will not share personal information about you with a financial institution with whom we have a joint marketing relationship unless we provide you the required notice under California law and you do not opt-out of that information sharing. In addition, if your address on file with us is a Vermont address, we will not share consumer report information about you with our affiliates unless you expressly consent to that information sharing.

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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 our web site at least 30 days prior to their implementation.

Privacy of Virburbia Rewards Service

What information does Virburbia collect, and why?

Enrollment Information. To set up your membership with the Virburbia Rewards service, you will need to provide certain contact information, such as your name, mailing address, email address, phone number, username, and password. This information will also allow us to contact you about new college savings opportunities, unless you opt out of receiving these messages.

Purchase Information. As a Rewards service member, you can choose to receive a rebate of from your shopping experience, or save for college, or give your rebate to a charity of your choice, or layaway for a future purchase by shopping with our participating companies. We may require additional information in order to keep track of and collect your rewards. For example, if you use a credit card to make a purchase, we may use your credit card number to identify the transaction. A phone company might require your telephone number, while an airline might require your frequent flyer account number. In order to keep track of and collect your rewards, Virburbia collects from some participating companies, grocery retailers or third party processors details of your transactions such as the date and amount of your transaction.

Rewards Account Information. We will maintain records to keep track of the rewards you earn from your purchases with our participating companies. You can use our website to view your Rewards service account balances and recent account activities, update your account profile, establish goals,  or contact a customer service representative.

Student Information. In order to link an eligible investment account or student loan account to the Rewards service so that we may direct your savings from your Rewards service account to the investment or student loan account you will need to provide certain information about the students or future students for whom you are saving such as the name, date of birth and social security number of the student and the account number of the investment or loan account. You can also personalize your Rewards service account to reflect your progress toward achieving your personal college savings goals by providing additional information about your future college students, such as when they anticipate starting college and whether they plan to attend a public or private institution. We may use this information to contact you about college savings opportunities, unless you opt out of receiving these messages.

Investment Account Information. When you open an investment account, the investment manager is required by law and by industry regulations to obtain certain personal information before creating your investment account. We and our investment manager partners will share certain personal information (such as your or your student's social security number or address) and demographic data with one another to facilitate the application process and monthly processing, and to comply with applicable law. This sharing of information is required to manage your account. Additionally, we may use this demographic information (such as your future college student's date of birth) to contact you about relevant college savings opportunities, unless you opt out of receiving such messages.

Family and Friends Network Information. You may use our Tell-a-Friend service to notify your family and friends about Virburbia by providing their names and email addresses. You can also increase your savings through Virburbia by creating a savings network of family and friends that directs a portion of its Virburbia savings to your particular cause.

Virburbia will automatically send a one-time email inviting your family and friends to visit Virburbia. We store the information for the purpose of sending these emails and to measure overall response rates to these services. Your family and friends may This e-mail address is being protected from spambots. You need JavaScript enabled to view it to request that their information be removed.

Family and friends who contribute to your investment accounts will receive a confirmation email.

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How does Virburbia use my information?

Management of Your Account. When you become a member, we use your contact and transaction data to manage your account.

Use of Third Parties for Fulfillment Purposes. We may use certain third parties to provide marketing and administrative services, such as keeping track of your purchases, analyzing data or delivering special saving offers to you on our behalf or on behalf of our participating companies. Third parties may also be used to help us administer our rewards programs.  In order to obtain these services, we may need to share certain personally identifiable information about our members. However, these third parties will be bound by legal agreements to not use or disclose the information we provide them for any purpose other than to perform the requested service.

On occasion, contests, sweepstakes or surveys on our web site may be co-sponsored by Virburbia and another company, or may be sponsored by companies other than Virburbia. Some or all of the data collected through these contests, sweepstakes or surveys may be shared with the sponsor(s) or companies indicated on the entry form or in the applicable rules.

Notification About Products and Services. We offer you the chance to maximize your Virburbia membership through opportunities made available to you on our site and, unless you opt out of receiving them, through email, mail, and telephone messages. We may use information about you to provide you offers tailored to your interests. Sometimes, we send offers to selected groups of members on behalf of our participating companies and/or affiliates. Occasionally, we engage third parties in the business of facilitating communications to send you information from certain participating companies, but only subject to strict confidentiality provisions that prohibit those third parties from providing your personal information to the participating companies. In addition, unless you opt-out, we may share your information with nonaffiliated financial institutions with whom we have a marketing relationship so that those participating companies may market to you the specific products being offered under our contract with them. If you do not want to receive any of these marketing communications, you may opt out of receiving them.

Use of Information from Third Parties. We may obtain information about you from our participating companies and other third parties in order to provide you with opportunities tailored to your interests. You may opt out of receiving these offers by updating your account profile at any time on our website, or by contacting a customer service representative at This e-mail address is being protected from spambots. You need JavaScript enabled to view it . We may also use information obtained from our participating companies and other third parties in conjunction with member account and enrollment information for analytical and audit purposes.

Use of Non-Personally Identifiable Information. We may also provide aggregated, non-personally identifiable information about our members or their circle of Family and Friends to third parties for audit, marketing and other purposes. Because aggregated data is not associated with any particular person, these third parties will not have access to any personally identifiable information about you or your circle of Family and Friends.

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What are my choices regarding the receipt of marketing messages?
We reserve the right to send you specific administrative notices that are required by law, regulation, or as needed to service your account. You may choose whether or not to receive messages from Virburbia and our participating companies that may better suit your interests based on your preferences and transaction history. If you do not wish to receive these messages from Virburbia and/or our participating companies, you may opt out by sending us an email at This e-mail address is being protected from spambots. You need JavaScript enabled to view it containing your name, address, account number and request. You may also opt-out of receiving marketing emails from Virburbia and marketing messages from our participating companies by updating your Virburbia account member profile opt-out preferences on our web site. Our participating companies reserve the right to contact you using information from sources other than Virburbia.

How can I access and update my Virburbia data?
You may access and update information stored in your account profile by visiting the Virburbia site. Please keep your contact, account, and preference information up-to-date. Doing so ensures that your rewards are properly tracked and received. It also helps us inform you of new participating companies who may help you fulfill your goals.

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What about links to other sites and participating companies' use of information?
Through our various online offerings, we may provide links to third-party websites, such as those of our participating companies or your investment manager. Each of these sites may have separate privacy and different data-collection practices from Virburbia, and we are not responsible for the actions or practices of these third parties, nor for the content on these sites. We encourage you to review the privacy policies of their sites. Finally, please remember that when you shop or do any other business with any of our participating companies, any information you provide to them is subject to their own privacy and data collection practices, for which Virburbia is not responsible.

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How do I contact Virburbia about this Privacy Statement?
If you have any questions about this privacy statement, our information-handling practices, or other aspects of privacy at Virburbia, please This e-mail address is being protected from spambots. You need JavaScript enabled to view it by email or at JA-Partners, LLC, Customer Care - Privacy Policy Issues,1903 Lone Oak Road, Johnson City, TN 37604-3404

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Last Updated 1-13-09