BrightScope Privacy Policy

Date Last Revised: Jan 23, 2009

BrightScope is committed to maintaining the confidentiality, integrity and security of any personal information about our users. We are proud of our privacy practices and the strength of our site security and want you to know how we protect your information and use it to provide you the service on BrightScope.com (the "Service").

1. Your Privacy is not for sale
2. We limit the collection and use of personal information
3. Your Registration Information is kept private
4. Changes to your Registration Information
5. Account Information
6. Account Information disclosure policy
7. Online session information and use is used only to improve your experience
8. External service providers will not be given your personal information without your permission
9. Use of Blogs and other Forums on BrightScope.com
10. Contests, Giveaways and Surveys
11. Disclosure of your information to protect our rights or if required by law
12. Your data may be transferred upon acquisition of BrightScope but only in accordance with this policy
13. You can transport or delete your data
14. Cookies and Web Beacons are used to analyze site usage and improve the Service
15. We comply with Can-Spam regulations for our newsletters
16. We use authentication to ensure that only you access your account
17. We will notify you of any changes to this Privacy & Security Policy
18. Former customers
19. Partners
20. Contact us if you have any questions or concerns

Back to Top1. Your Privacy is not for sale

Simply put, we do not and will not sell or rent your personal information to anyone, for any reason, at any time.

Back to Top2. We limit the collection and use of personal information

Certain areas and features of BrightScope.com are available to you without registration or the need to provide any information to us. However, in order to benefit from the full functionality of the Service, you need to register as a member and in so doing, to provide a Login ID in the form of an email address, a password, default company name, first name and last name and information on the role related to the company retirement plan (collectively the "Registration Information").

Access to your Registration Information is strictly restricted to BrightScope employees and contractors, as needed, in order to operate, develop or improve the Service. These individuals have been subject to prior background checks and are bound by confidentiality obligations. They may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

BrightScope requires a Login ID email address from you in the following circumstances:

• Registration for the Service;
• Registration for any BrightScope Newsletter;
• The use of any Forums on BrightScope.com; and
• To respond to any correspondence, such as emails or letters, from you.

Back to Top3. Your Registration Information is kept private

BrightScope does not sell or rent your Registration Information at any time.

BrightScope uses your Registration Information only as follows:

• to analyze site usage and improve the Service;
• to deliver to you any administrative notices, alerts and communications relevant to your use of the Service;
• to fulfill your requests for certain products and services;
• for market research, project planning, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity;
• to enforce BrightScope's Terms of Use; and
• as otherwise set forth in this Privacy Policy.

In the event that you access the Service as brought to you by one of our co-brand partners, through a co-branded URL, your email address used for Registration on the Service, may be provided to such co-brand partner.

Back to Top4. Changes to your Registration Information

If your registration information changes during your subscription to BrightScope, you may update the email address by emailing us at support@brightscope.com and providing us with your new information.

Back to Top5. Account Information

BrightScope uses your Account Information as follows:

• to offer the Service to you;
• to deliver information relevant to your financial interests, such as offers for ways to save from third party product and service providers ("BrightScope Offers")
• to deliver administrative notices such as alerts and communications relevant to your use of the Service;
• for market research, project planning, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity; and
• as otherwise set forth in this Privacy Policy.

Back to Top6. Account Information disclosure policy

BrightScope does not sell, rent or disclose your personal Account Information. BrightScope discloses your Account Information only to you and to third-party contractors who help BrightScope provide the Service to you. You should be aware that courts of equity, such as U.S. Bankruptcy Courts, may have the authority under certain circumstances to permit your personally identifiable information to be shared or transferred to third parties without your permission.

BrightScope may anonymize or aggregate data derived from Account Information and disclose such data only in a non-personally identifiable manner to:

• Advertisers and other third parties for their marketing and promotional purposes such as how many users clicked on a particular BrightScope Offer;
• Organizations approved by BrightScope who conduct research into consumer spending.
• Users of the Service for purposes of comparison of their personal financial situation relative to the broader community.

Such information does not identify you individually.

Back to Top7. Online session information and use is used only to improve your experience

When you visit BrightScope.com, we may collect technical and navigational information, such as computer browser type, Internet protocol address, pages visited, and average time spent on our Web site. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve our Web design and functionality.

We may use third party service providers to help us analyze certain online activities. For example, these service providers may help us measure the performance of our online campaigns or analyze visitor activity on BrightScope.com. We may permit these service providers to use cookies and other technologies to perform these services for BrightScope. We do not share any personally identifiable information about our customers with these third party service providers, and these service providers do not collect such information on our behalf. Our third party service providers are required to comply fully with this Privacy Policy.

Back to Top8. External service providers will not be given your personal information without your permission

There may be a number of separate products and services offered by third parties advertised by us on our site and through the Service that may be complementary to your use of BrightScope.com and these constitute BrightScope Offers. If you choose to use these separate products or services, disclose information to the providers, and/or grant them permission to collect information about you, their use of your information is governed by their privacy policy. You should evaluate the practices of external services providers before deciding to use their services. These third party Web sites may have different privacy policies than BrightScope and BrightScope is not responsible for their privacy practices. If you click on a link to a third party Web site, BrightScope encourages you to check the privacy policy of that Web site.

BrightScope may present links in a format that enables us to keep track of whether these links have been followed and whether any action has been taken on a third party Web site. We use this information to improve the quality of the BrightScope Offers and customized content on the Service.

Back to Top9. Blogs and other Forums on BrightScope.com

If you use a bulletin board, blog, or chat room on this Web site, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these forums.

Back to Top10. Contests, Giveaways and Surveys

From time to time, BrightScope may offer you the opportunity to participate in contests, giveaways and other promotions. Any information submitted in connection with such activities will be treated in accordance with this Privacy Policy. From time to time, BrightScope may also ask you to participate in surveys designed to help BrightScope improve the Web site. Any personally-identifying Information provided to BrightScope in connection with any survey will be used only in relation to that survey.

BrightScope may aggregate survey data and disclose such data only in aggregate and in a non-personally identifiable manner to:

• Advertisers and other third parties for their marketing and promotional purposes, such as the number of users who have more than one 401k.
• Users of the Service for purposes of comparison of their personal financial situation relative to the broader community.

  Such information does not identify you individually.

Back to Top11. Disclosure of your information to protect our rights or if required by law

Notwithstanding the foregoing, BrightScope reserves the right (and you authorize BrightScope) to share or disclose your registration information and account Information when BrightScope determines, in its sole discretion, that the disclosure of such information is necessary to identify, contact, or bring legal action against you:

• If you are or may be violating this Privacy Policy or BrightScope's Terms of Use;
• To prevent potentially prohibited or illegal activities; or
• If necessary or required by any applicable law, rule regulation, subpoena or other legal process.

Back to Top12. Your data may be transferred upon acquisition of BrightScope but only in accordance with this policy

Registration Information and Account Information may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other transfer (a "Transfer") involving BrightScope. BrightScope specifically reserves the right to transfer Registration and Account Information to a third party in connection with a Transfer. Should such a Transfer occur, we will use our best efforts to require that the new combined entity follow this privacy and security policy with respect to your personal information, as and to the extent required by applicable law and require that you receive prior notice if your personal information could be used contrary to this policy.

Back to Top13. You can transport or delete your data

Your data is yours. You can remove it anytime you want. When you request us to delete your account for the Service, your data will be permanently expunged from our primary production servers and further access to your account will not be possible. We will also promptly disconnect any connection we had established to your Account Information. However, portions of your data, consisting of aggregate data derived from your Account Information, may remain on our production servers indefinitely. Your data may also remain on a backup server or media. BrightScope keeps these backups to ensure our continued ability to provide the Service to you in the event of malfunction or damage to our primary production servers.

Back to Top14. Cookies and Web Beacons are used to analyze site usage and improve the Service

"Cookies" are alphanumeric identifiers in the form of text files that are inserted and stored by your Web browser on your computer's hard drive. BrightScope may set and access cookies on your computer to track and store preferential information about you. BrightScope may gather anonymous information about you through cookie technology on an aggregate level only. For example, BrightScope may assign a cookie to you, to limit the amount of times you see a particular BrightScope Offer or to help better determine which BrightScope Offers to serve to you. Please note that most Internet browsers will allow you to stop cookies from being stored on your computer and to delete cookies stored on your computer. If you choose to eliminate cookies, the full functionality of the Service may be impaired for you.

We encode our cookies so that only we can interpret the information stored in them.

We use third-party advertising companies to serve ads when you visit our website. These companies may use information (not including your name, address, email address, or telephone number) about your visits to this and other websites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here.

Web beacons are images embedded in a Web page or email for the purpose of measuring and analyzing site usage and activity. BrightScope, or third party service providers acting on our behalf, may use Web beacons to help us analyze site usage and improve the Service.

Back to Top15. We comply with CAN-SPAM regulations for our newsletters

BrightScope.com sends only verified, double-opt-in e-mail newsletters, specifically requested by BrightScope subscribers. Subscriptions to BrightScope.com newsletters are verified by sending an e-mail confirmation to your e-mail address, which requires a positive response before an e-mail address is added to BrightScope's list. BrightScope.com is fully compliant with the Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003.

Because we provide you the option of receiving our promotional newsletters, BrightScope.com subscribers have the ability to opt-out of receiving these newsletters by emailing us at support@brightscope.com. We also will send users service-related emails which they do not have the ability to opt-out of.

Back to Top16. We use authentication to ensure that only you access your account

Authentication is the process you go through on BrightScope to access secure areas of our Website. This process takes place when you log into your account, the two key components of which are your Login ID and Password.

With regards to passwords, we maintain strict rules to help prevent others from guessing your password. We also recommend that you change your password periodically. You are responsible for maintaining the security of your Login ID and Password. You may not provide these credentials to any third party. If you believe that they have been stolen or been made known to others, you must contact us immediately at support@brightscope.com to request a change. We are not responsible if someone else accesses your account through Registration Information they have obtained from you or through a violation by you of this Privacy Policy or BrightScope's Terms of Use.

If you have a security related concern, please contact us at support@brightscope.com. We will work closely with you to ensure a rapid and personal response to your concerns.

Back to Top17. We will notify you of any changes in this Privacy Policy

If we decide to change our privacy and security policy, we will update the date upon which this policy, including those changes became effective from at the top of this policy and post those changes to this policy, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this policy at any time, so please review it frequently.

Back to Top18. Former Customers

We treat the information of a former customer in the same manner that we treat information about our current customers.

Back to Top19. Partners

If you access the BrightScope.com website or BrightScope Service through one of our partners, we may share some of your registration information (such as email address) with our partner that you registred with for the BrightScope Service.

Back to Top20. Contact us if you have any questions or concerns

If you have questions, comments, concerns or feedback regarding this Privacy Policy, send an e-mail to support@brightscope.com.