College Source 101 is a college resource service provided by Virtumundo, Inc. through www.collegesource101.com (the "Website"). Virtumundo values the privacy and security of the information that you share with us. It is important that you understand how we collect, use, and maintain your information. This Privacy Statement explains our information practices, choices you may make about how we collect, share, and use your information, and ways to contact us.

We may change this Privacy Statement from time to time. Changes to this Privacy Statement are effective upon posting. Please check back periodically for updates.

This Privacy Statement applies only to the practices of Virtumundo and its employees for the Personal Information that we collect on this Website and from third party websites. We will not apply the provisions of this Privacy Statement to Business Contact Information or Aggregated Information.

Definitions

"Personal Information" includes your name, address information, personal e-mail address, telephone number, Social Security number, education status or history, financial information, as well as other similar information.

"Website Use Personal Information" consists of information about you including, without limitation, your Internet service provider, browser type, domain name, the website that referred you to us, the web pages you request, the date and time of those requests, and entry and exit points.

"Business Contact Information" includes the name, title, business address, or telephone number of an employee in an organization, along with departmental e-mail addresses that contain no individually identifiable information. Business Contact Information is not Personal Information.

"Aggregated Information" is information about more than one individual where the individual identities are unknown and cannot be inferred from the information. Aggregated Information is not Personal Information.

Collection of Personal Information

We may collect Personal Information from you, but only if you provide it to us voluntarily by completing a registration page, survey, request form, or similar document. We also collect Personal Information that you provide to other Virtumundo websites or that we obtain lawfully from third party websites. We may combine Personal Information that we have about you from different sources. You may have to provide Personal Information in the form of unique identifiers (username, password) to enter certain parts of our Website.

Collection and Use of Website Use Information

During your use of our Website, we will collect certain Website Use Information to enhance the functionality of the Website and to make your access more convenient and efficient. We use cookies, web beacons, and other technology to gather Website Use Information. Among other uses, these technologies allow us to deliver content specific to your interests and to save you from re-entering your registration data at each connection. We may change or use additional or new technology from time to time. We retain Website Use Information and use it to establish Website activity trends, monitor Website performance, improve Website design and functionality, inform current and potential customers about our services, and for other business purposes.

Children (under age 13)

We do not knowingly collect, disclose, maintain, or use Personal Information from children under age 13. We will delete the Personal Information of a child under age 13 if we learn that we have received the information inadvertently. If you are under age 13, do not share Personal Information with us. If you are under age 18 but at least 13, please use this Website only under the supervision of a parent or legal guardian who has viewed this Privacy Statement.

Use of Personal Information

We may use and disclose Personal Information as described in this document. In addition to the uses described in this document, we may use Personal Information for purposes that include administration, maintaining and improving the Website, and communicating with you about our services. We may also use your Personal Information to send promotional offers or other marketing communications to you, on behalf of other organizations, but only if you already agreed to receive these communications. We do not share Personal Information with these other organizations unless you consent to that sharing.

We only collect, use, and disclose Personal Information for purposes that are reasonable in the circumstances. We use only fair and lawful means to collect Personal Information. We reserve the right to use or disclose Aggregated Information and Business Contact Information in ways that we think are appropriate.

Agents

We disclose Personal Information to other companies and individuals to perform functions for us under confidentiality agreements. These types of agents include mailing and delivery companies, marketing service providers, database managers, customer service representatives, and other agents who perform functions for or on our behalf. These agents may perform functions such as analyzing data, supplying marketing assistance, delivering packages, sending postal mail and e-mail, removing repetitive information from customer lists, and providing customer service. Where we disclose Personal Information to organizations that perform services on our behalf, we will require those organizations to use this information solely to provide services to us and to protect the Personal Information with appropriate safeguards.

Schools and Related Organizations

We disclose Personal Information to schools and to related organizations like student lenders, scholarship providers, educational advisers, and test preparation companies. We have confidentiality agreements with these schools and related organizations. We share your Personal Information with them so that they can provide you with school, academic or career planning, college application, financial aid, scholarship, or other information.

Business Transfers

In the case of a sale, merger, or other transfer of all or a portion of our business, Personal Information might be transferred, but it remains subject to the promises made in any pre-existing Privacy Statement, unless an individual consents otherwise.

Consent

We will obtain your consent to the collection, use, and disclosure of Personal Information that you provide to us through this Website. Third party websites that provide Personal Information to us also obtain your consent. You may withdraw your consent at any time, subject to reasonable notice and legal or contractual obligations. To withdraw your consent, simply tell us of the Personal Information that you no longer wish us to collect, use, or disclose through the Contact Information listed below. However, we are unable to offer some services, like providing your information to schools and related organizations, without Personal Information.

To unsubscribe from a particular e-mail offer, just follow the instructions at the end of each e-mail message. You may unsubscribe from all of our e-mail offers at http://privacy.virtumundo.com/optout/global.html.

Legal Exceptions

We may use or disclose Personal Information without your consent in certain circumstances:

• If we are required by law or by an order or requirement of a court, administrative agency, or other government entity, or by court rules concerning the production of records;
• If we have reasonable grounds to believe that use or disclosure is necessary to protect the rights, privacy, property, or safety of our users or others;
• If we have reasonable grounds to believe that the information relates to breach of an agreement or violation of the law that has been, is being, or is about to be committed;
• If it is necessary for fraud protection, risk reduction, or the establishment or collection of funds owed to us;
• If it is necessary to enforce or apply our Terms and Conditions and other agreements, to pursue remedies, or to limit damages to Virtumundo;
• If the information is public;
• For other reasons allowed or required by law.

When we are required or permitted to disclose information without consent, we will not disclose more information than is necessary to fulfill the disclosure purpose.

Retention and Access

We will take reasonable steps to keep your Personal Information accurate, complete, current, and relevant to its intended use. We keep your Personal Information only as long as we need it for the reasons it was collected. When your Personal Information is no longer required for our purposes, we have procedures to destroy, delete, or erase it or to convert it to an anonymous form.

Any Personal Information that we collect will be used, stored, or processed, in whole or in part, in the United States. The principal places in which we hold Personal Information are Kansas City, Kansas and Chicago, Illinois.

At your request, we will provide you with reasonable access to your Personal Information, so that you can review what we have stored and request corrections to it. You may request access by writing to us at the address listed in the Contact Information below. We will provide the Personal Information that you request as soon as practically possible and generally no later than thirty days following the request. If you wish to correct your Personal Information, please send us a written explanation of the particular information that you believe should be corrected. Where information will not or cannot be disclosed, we will tell you the reasons for non-disclosure.

Security

We combine technical and physical safeguards with employee policies and procedures to protect your information. We will use commercially reasonable efforts to protect your information, continue to assess new technology for protecting information, and when appropriate, upgrade our information security systems.

Further, we permit only authorized Virtumundo employees and third parties to access any Personal Information that you supply to us. If an employee misuses Personal Information, we will take disciplinary action, up to and including termination of employment. If any third party individual or organization misuses Personal Information, we will take action, up to and including termination of any agreement between Virtumundo and that individual or organization.

Links to Other Websites

When you click on a link on this Website that takes you to a website operated by another company, you will be subject to that company's website privacy policies.

Dispute Resolution

Please direct any questions or concerns regarding the use or disclosure of Personal Information to us by using the Contact Information given below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Privacy Statement. For complaints that cannot be resolved, we will make available to you an independent dispute resolution process.

Contact Information

In the event of questions about this Privacy Statement, access to your Personal Information, or our handling of Personal Information, contact us at:

privacy@virtumundo.com

Privacy Officer
Virtumundo, Inc.
8400 West 110th St., Ste. 330
Overland Park, KS 66210
USA

(866) 356-8636, Monday-Friday, 9:00 AM to 5:00 PM (Central Time)

Effective Date

This Privacy Statement is effective as of August 14, 2006.

VERSION 1.0