Privacy Policy

Any changes to the University Towers Electronic Bill Payment and Presentment Website Customer Information Privacy Policy and the Electronic Bill Payment and Presentment Consumer Information Privacy Principles, will be posted on or before the effective date of such changes. You will be able to determine the date of the last change by noting the effective date of the policies.

Electronic Bill Payment and Presentment Website Customer Information Privacy Policy

University Towers respects the privacy of our customers and are committed to protecting their information on our Web sites with the same care we utilize for our own transactions.

Our Electronic Bill Payment and Presentment (EBPP) system does not automatically collect personal information from visitors to its Web sites. It is possible that the EBPP system will use tools, such as cookies or click stream auditing, for our own internal uses, such as recommending products and services and gathering Web analytics. Cookies are small pieces of information that a Web site stores on a visitor's Web browser to remind the site about the visitor the next time they visit the site. We will not store confidential or sensitive information in cookies. University Towers will use cookies to enhance our customers' online bill payment session by making navigation easier and providing important security features. For certain applications, cookies are a requirement because they help protect the privacy of a customer's transactions by, for example, automatically terminating the online session if the customer forgets to log out.

Cookies cannot be used to capture your e-mail address, obtain data from your hard drive or gain confidential or sensitive information about you. Additionally, cookies cannot be read by a Web site other than the one that set the cookie. Some Web sites, however, use cookies to obtain information from your browser. In order to prevent this, you can set your browser to notify you before accepting a cookie, so that you can control whether you accept or reject a cookie.

Click stream auditing includes information such as a web surfer's IP address, web pages which have been viewed or acted upon by a web surfer, date and time, domain type, and when a web surfer has responded to an advertisement. University Towers may occasionally combine this information with individual information on an aggregate level to determine the effectiveness of our advertising.

This version of the Electronic Bill Payment and Presentment Website Customer Information Privacy Policy is effective 02/08/2008.

Electronic Bill Payment and Presentment Consumer Information Privacy Principles

Introduction
University Towers is committed to treating and using personal financial information about you responsibly. These Privacy Principles explain what personal information we collect, why we collect it, how we protect personal information, and how and why in certain cases we may share such information with select other parties. These principles are effective 02/08/2008, and may be amended from time to time.

University Towers’ Electronic Bill Payment and Presentment Consumer Information Privacy Principles apply to personal information collected or used when you use our online bill payment system.

We Collect Information As Needed to Identify You and Serve You as a Customer
We collect information from and about you in order to identify you as our customer, establish and manage customer accounts, complete customer transactions, and to comply with legal and regulatory requirements.

Information we receive from you:

Contact Information (such as name, address, e-mail address, and telephone number). We use contact information, for example, to identify you, send you information about our products and services, and to contact you about your accounts.

Account Information (such as bank account numbers, bank routing numbers, and credit card numbers). We use the account information you provide us in order to complete your payment requests.

Policies and Procedures
University Towers’ EBPP service utilizes advanced technology and information management techniques to implement security, audit and control programs designed to protect the confidentiality and security of the information we collect. UniversityTowers limits employee access to customer information provided on our EBPP site to those employees we believe have a legitimate business need for the information.

We May Share Information With Other Companies
It is our policy not to sell, rent or otherwise provide customer information collected on XYZ’s EBPP site to outside companies so they can market their non-financial products or services.

The section below describe the types of companies and third parties with whom, and the situations when, we may share customer information outside the University Towers family:

· University Towers will share personally identifiable information that you provide us on our EBPP site with third parties that help us process the transactions you request;

· When we respond to your service requests;

· When we share information with consumer reporting agencies;

· When we offer account benefits;

· When we transfer information in connection with a proposed or actual sale of accounts, or a proposed or actual sale of all or part of a business unit;

· When we suspect fraud or for risk management purposes;

· When we are required by a federal, state, or local law or regulation to do so;

· When we receive a subpoena or are ordered by a court to do so;

· As otherwise permitted by federal or state law.

We may also disclose personally identifiable information to other financial service providers with which we have marketing agreements. Generally, we provide market researchers only with customer contact information, such as name, address, and telephone number. Under no circumstances, will University Towers disclose bank account numbers, credit card numbers or access codes provided to us via our EBPP website to third parties for telemarketing or direct marketing purposes.

Before we disclose customer information to any of our service providers or suppliers, we require them to agree to keep our customer information confidential and secure and to use it only as authorized by us.

Former Customers
We do not disclose information about former customers to outside companies except as may be permitted or required by law. Some examples of when we may share information about former customers, such as when we receive a subpoena, are listed above.

State Privacy Laws
We will also comply with state privacy laws to the extent they apply.

Online Information Policies
We respect the privacy of our customers and are committed to protecting their information on our websites with the same care we utilize for our own transactions.