Futuretrust

COLLEGE SAVINGS PROGRAM PRIVACY POLICY

Overview : Information Collection : Information Use : Information Sharing : Information Security : Accessing and Updating Your Profile : Contacting Futuretrust

Overview

This Privacy Policy covers the collection, use, sharing, storage, safeguarding and disposal of personal information of members of the Futuretrust college savings program by and on behalf of Mothers Work, Inc. (doing business as Futuretrust) and those persons to whom it delegates the administration of the program from time to time. To administer the program, Futuretrust will collect, use and share certain personal information of program members. By participating in the program, members expressly consent to this Privacy Policy.

Each Futuretrust member may or may not be a Barclays Bank cardholder. Futuretrust and Barclays Bank maintain separate and distinct databases, with separate and distinct privacy policies, of Futuretrust program member information and Barclays Bank cardholder information. This Privacy Policy relates to Futuretrust program member information. Barclays Bank maintains a separate privacy policy for cardholder information, which may be viewed at www.juniper.com/app/ccsite/legal/privacyPopUp.jsp.

Futuretrust reserves the right to update this Privacy Policy from time to time. Any changes will only be effective prospectively, and we will alert all existing program members, and provide them with notice of the options available to them, before we implement any changes.

Information Collection

Futuretrust collects information regarding program members in a variety of ways from a variety of sources. Futuretrust initially collects information from Barclays Bank when each cardholder account is opened to let us know that the cardholder has joined the program. We also collect information on the transactions Barclays Bank cardholders make with their Futuretrust credit cards and online through the www.Futuretrust.com web site. This information enables us to track the benefits to which members are entitled under the program, including amounts to be contributed to their 529 plans.

We will also afford members an opportunity to provide us with specific additional information when they enroll on the Futuretrust web site and complete their profile. This information helps us better serve members and includes their preferences and choices on various options, such as choice of a 529 plan provider and whether they want to receive optional offers from partner vendors.

We work with each members' 529 plan provider, as well as Barclays Bank, to automatically deposit their earned contributions into their 529 account, and we therefore collect the account information necessary to allow us to make these deposits on behalf of members.

Futuretrust also collects and uses information by installing small computer files (known as cookies) on the hard drive of each computer used to visit www.Futuretrust.com. Cookies are an important element of your experience on our web site. They allow us to welcome you each time you visit and customize our information to your past web site experiences. Cookies also help us detect and stop fraud. Some computer browsers permit you to disable or uninstall cookies, and you may do so by following the instructions provided by your hardware and software vendors. However, disabling or uninstalling these cookies will adversely impact the user experience on the Futuretrust web site and may prevent you from accessing and using certain features of the web site.

Futuretrust and other affiliates of Mothers Work, Inc. feature an extensive online shopping area. In order to offer you special 529 earnings through your purchases on program partners' web sites, Futuretrust uses certain pixel .gif or other files to track your movement from our site to partners' web sites. These web navigation trackers allow us to track your online purchases back to your Futuretrust account. The trackers are necessary to offer you these online shopping benefits. The tracking mechanism is based on a number assigned to you by Futuretrust This number is intended to allow us to track your online purchases without sharing your personal information with our online partners. If you wish not to be tracked in this manner, then we recommend that you do not use our online shopping mall.

Information Use

Futuretrust uses each member's personal information to administer the Futuretrust program and may also use such information to make the member aware of special offers and incentives that may be available from time to time. Among other uses, Futuretrust uses the information to identify an individual as a program member, to track and verify the contributions earned by the member through the use of his or her Barclays Bank credit card, to track and verify the contributions earned by the member through qualifying purchases from Futuretrust partners, to verify receipt of those amounts from Barclays Bank and/or other program partners, to pay those amounts into the member's designated 529 plan account, and to report these transactions to the member.

Information Sharing

Futuretrust may share a member's personal information with entities with whom it contracts to assist in administering the program from time to time. Currently, Futuretrust has contracted with SHCDirect, L.L.C. and Mall Networks for this purpose. Additional parties also administer aspects of the program, including (i) AXA Advisors, LLC, A.P. Lubrano & Company, Inc. and (ii) Teachers Insurance and Annuity Association of America. The services that they provide may include providing you advisory services in the choice of a 529 plan.

We may also share a member's personal information with business partners to offer you goods, services and other incentives relating to the program. Among other partners, Futuretrust has entered into separate arrangements with (i) AXA Advisors, LLC, A.P. Lubrano & Company, Inc. and (ii) Teachers Insurance and Annuity Association of America under which they will be provided with contact and other information on members who have not opted out to enable them to offer certain benefits or offers, which may include insurance and securities. In setting up and updating your member profile, we offer you the opportunity to opt out of receiving such offers. Opting out of receiving such offers does not opt you out of the administrative services that may be provided to you in connection with the program.

As a participant in Futuretrust, you may or may not be a Barclays Bank cardholder. From time to time, Futuretrust and Barclays Bank may share and/or compare certain information in the Futuretrust member database and the Barclays Bank cardholder database to ensure accuracy and completeness in their respective databases and to assist each other in administering program accounts and cardholder accounts. Barclays Bank maintains a separate privacy policy for cardholder information at www.juniper.com/app/ccsite/legal/privacyPopUp.jsp.

Information Security

Futuretrust restricts access to member information to those who need to know that information to accomplish the purposes for which it is collected, used and shared.

Futuretrust will keep your member information as long as we believe we may need it, including storage for auditing and archival purposes. When we believe we no longer need such information, we will destroy or otherwise dispose of it in a manner intended to preserve your privacy and security. We endeavor to use best industry practices in the storage and destruction of your personal information to protect its security and integrity. If we discover that the security or integrity of your personal information has been compromised, then we will take appropriate steps to respond to the incident including, if appropriate, notifying you of the incident so you can in turn take whatever steps may be appropriate to protect yourself.

OPTING-OUT

IF YOU WANT TO OPT-OUT OF INFORMATION SHARING BY FUTURETRUST WITH BUSINESS PARTNERS AND THIRD PARTIES FOR NON-PROGRAM ADMINISTRATION, YOU CAN CONTACT 1-888-TRUST-68 (1-888-878-7868) AND ASK THE FUTURETRUST REPRESENTATIVE TO CHANGE YOUR PRIVACY SETTING SO THAT YOUR PERSONAL INFORMATION IS NOT SHARED WITH BUSINESS PARTNERS OR THIRD PARTIES EXCEPT FOR PROGRAM ADMINISTRATION.

Accessing and Updating Your Profile

You may contact us and ask to see your member profile and choices, and you may advise us of any changes or inaccuracies in such profile and choices and we will update or correct as appropriate. You may also view and update your member profile online from time to time by visiting www.Futuretrust.com.