Effective as of January 1, 2015

SAGE Scholars, Inc. and/or SAGE CTB, LLC and/or First Benefits LLC (“SAGE” or “we”) has adopted a set of Privacy Principles applicable to all its U.S.-based companies. We have implemented those Principles in this Privacy Policy, which describes how we collect, use and share personally identifiable information (“PII”) we obtain from and about individuals located in the U.S., both online and off-line. SAGE does not capture or use any private health information.

From time to time SAGE may revise this Privacy Policy to reflect changes in the law, our PII collection and use practices, the features of our web site, technology or industry initiatives. If we make revisions that change the way we collect your PII, those changes will be posted in this Privacy Policy and the effective date will be noted at the beginning of the Policy. Therefore, you should review it periodically so that you are up to date on our most current policies and practices.

Protecting SAGE member privacy is of the highest importance. SAGE pledges that it will never disclose “Sponsor” information, including, but not limited to e-mail address, name, Social Security number, mailing address, or any Tuition Rewards account information to groups not responsible for your Tuition Rewards accrual or to non-member colleges & universities.

By volunteering your e-mail address, SAGE is able to notify you from time-to-time about updates to our program – for example, when additional colleges, financial providers, and partners join our consortium. Again, e-mail addresses are not shared for commercial purposes outside of the SAGE Scholars Tuition Rewards consortium. The names and contact information of SAGE account holders are NOT rented or sold to other organizations. If you volunteer your e-mail for the purpose of receiving announcements from your health plan, then the health plan may send information about other programs and offerings for which you may be eligible.

COLLECTION OF PERSONALLY IDENTIFIABLE INFORMATION (“PII”) BY SAGE SCHOLARS, INC.

Information: SAGE collects personally identifiable information when you voluntarily submit the information to us in order to create, register or update your Tuition Rewards account. This information may include PII such as your name, mailing address, e-mail address, telephone number, certain asset, policy or banking account number(s), and a Social Security number. The information we may collect varies based on the requirements for data tracking set forth by the financial partner with whom you are earning Tuition Rewards.

Cookies: Cookies are small bits of information that the Internet site operated by SAGE Scholars places on the hard drive of your computer. These cookies are used to store “session” information and are required to enable account log in functions. At no time does the cookie contain any PII.

You can program your computer to warn you each time a cookie is being sent or to refuse cookies completely (however, refusing cookies completely will effectively disable your ability to log into your account).

PROTECTING CHILDREN’S PRIVACY

We recognize that some of the users of our site may be under the age of 16 (“Minors”). We are committed to protecting Minors’ privacy online and meeting the requirements of the federal Children’s Online Privacy Protection Act. We encourage parents and guardians to spend time online with their children and to participate in the activities offered on the Site.

If a minor is the asset owner who is being identified to earn Tuition Rewards Points, and the minor wishes to register for online access to his or her Tuition Rewards account at www.tuitionrewards.com, we require that a parent or legal guardian be present at the time the minor registers for access. Any parent or legal guardian who suspects a minor may have registered with us and would like more information about privacy information, or would like the minor’s account removed, should contact us immediately via e-mail to support@sagescholars.com, or by written request to the mailing address at the bottom of this privacy policy.

MEMBER COLLEGE & UNIVERSITY ACCESS TO INFORMATION

Member colleges have access to the SAGE Scholars student database, for free, where they can search for students who are sponsored in the SAGE Scholars Tuition Rewards program and / or the SAGE Scholars MyFourYears.com Site, and are currently in high school grade 9 or higher. Member schools can retrieve records on students consisting of name, mailing address, and, if voluntarily provided, telephone number, e-mail address and other data as provided by the child’s Sponsor or Sponsors. Member colleges and universities also have access to the size of each student’s Tuition Reward once allocated. Unless otherwise indicated by the sponsor or account holder, no Sponsor contact or financial information is made available to member colleges, nor is student information available to any parties other than Member Colleges and SAGE.

The SAGE Scholars Tuition Rewards (www.tuitionrewards.com) web site may be linked to Internet sites operated by other companies or organizations. Although we choose our business partners carefully, SAGE is not responsible for the privacy practices of web sites operated by third parties that are linked to our site. Once you’ve left a SAGE Scholars site (including, but not limited to, www.tuitionrewards.com, www.myfouryears.com, www.marketcapandgown.com, www.guardiancollegetuitionbenefit.com, www.collegetuitionbenefit.com and www.sagescholars.com) via such a link, you should check the applicable privacy policy of the third party site to determine how they will handle any PII they collect from you.

SECURITY: SAGE SCHOLARS, INC. PROTECTS THE SECURITY OF PII.

SAGE Scholars uses reasonable administrative, technical, personnel and physical measures to safeguard PII in its possession against loss, theft and unauthorized use, disclosure or modification. In addition, SAGE Scholars uses reasonable methods to make sure that PII is accurate, up-to-date and appropriately complete.

CONTACTING US:

This site is owned and operated by SAGE Scholars, Inc., and/or SAGE CTB LLC, and/or First Benefits LLC. If the site is www.collegetuitionbenefit.com or www.collegetuitionbenefit.com and you have any questions or suggestions with respect to this policy, or if you wish to ask us to delete, correct, or show you your information as provided above, please write us at First Benefits LLC, 150 E. Swedesford, Ste 100, Wayne PA 19087 or email us at admin@CollegeTuitionBenefit.com . For all other sites, if you have any questions or suggestions with respect to this policy, or if you wish to ask us to delete, correct, or show you your information as provided above, you can write to us at SAGE Scholars, Inc. 21 South 12th Street, 9th Floor, Philadelphia PA 19107. You may also contact us via fax at (215) 564-9934, or e-mail to support@sagescholars.com.