Nelnet Business Solutions / FACTS Management Co.

For more than a quarter of a century, UniLink Data Systems (Company), also doing business as FACTS Management, has served educational institutions, their students, and families. Our policies, procedures, and internal controls are annually tested through the rigours of a third-party administered Payment Card Industry (PCI) audits. In addition, we disclose our policies to you, our valued client, so that you are clear and can trust that we maintain a high level of discipline in our operations.

Privacy Statement

Our privacy statement is available on our website (www.factsmgt.com.au). Our privacy statement makes clear that the use of information we collect from individuals through our services is governed by the educational institution’s privacy policy. To protect nonpublic personal information from access by unauthorised parties, the Company maintains physical, procedural, and electronic safeguards.

Processing of Payments

Payments are processed via credit cards and debit cards. Successfully processed funds (Custodial Funds) are deposited in a Custodial Account or a Credit Card Settlement Account. The Company complies with payment processing rules established by the banking system and credit card associations. Consumers are protected by these payment processing rules, and the Company observes these rules when interacting with Consumers on the behalf of the institution.

Insurance Coverage

The following policies govern the insurance of the Company:

Public liability insurance coverage will be maintained at not less than $20,000,000.
Professional indemnity insurance will be maintained at not less than $10,000,000.
Audits

Nelnet, Inc. will engage a reputable firm to conduct an annual audit of its financial statements. Included in the audit will be a review of subsidiaries, including the Company.

Disaster Recovery and Contingency Planning

The Company stores and retains financial data on separate mirrored computer systems located in geographically dispersed locations. The purpose of this arrangement is to maintain, in a commercially reasonable manner, a backup of all data in the event that a disaster impacts our primary database. The locations also provide emergency power and dedicated, redundant Internet links.

Financial and Regulatory Compliance

The following policies govern the compliance program at the Company:

The Company will make every effort to comply with applicable federal and state laws and regulations, and credit card regulations regarding financial privacy and the protection of financial data.

The Company reviews its information and data security standards on a regular basis, including but not limited to qualified third-party reviews of its information and data security systems and compliance with credit card policies and procedures.

The security of funds is of paramount importance to the Company. We would be pleased to provide interested parties detailed information with respect to our banking relationships, insurance coverage, and our most recent audits of accounts or controls. Please contact the Company office at 1300FACTS1. You may also e-mail us at Marketing@FACTSmgt.com.au or visit our websites.

All policies are reviewed annually by the Company.