Privacy Policy 

This policy covers Customer Information, which means personally identifiable information about a consumer or a consumer's current or former customer relationship with Fintura. It is Fintura’s policy that all Customer Information, especially Non Public Personal Information, will be stored with Acxiom or in a secured environment with our partners. We will validate that these providers have their own Privacy Policy to guard against the access or accidental release of such information to non-authorized personnel or parties.

1. Making the security of information a priority
Keeping financial information secure is one of our most important responsibilities. We maintain physical, electronic and procedural safeguards to protect Customer Information. Appropriate employees are authorized to access Customer Information for business purposes only. Our employees are bound by a code of ethics that requires confidential treatment of Customer Information and are subject to disciplinary action if they fail to follow this code.

A. Collecting information
We collect and use various types of information about you and your accounts to service your accounts, save you time and money, better respond to your needs and manage our business and risks. Customer Information is categorized in the following six ways: 1. Identification Information - information that identifies you, such as name, address, telephone number and Social Security number. 2. Application Information - information you provide to us on applications and through other means that will help us determine if you are eligible for products you request. Examples include assets, income and debt. 3. Transaction and Experience Information - information about transactions and account experience, as well as information about our communications with you. Examples include account balances, payment history, account usage and your inquiries and our responses. 4. Consumer Report Information - information from a consumer report. Examples include credit score and credit history. 5. Information from Outside Sources - information from outside sources regarding employment, credit, and other relationships that will help us determine if you are eligible for products you request. Examples include employment history, loan balances, credit card balances, properly insurance coverage and other verifications. 6. Other General Information - information from outside sources, such as data from public records, that is not assembled or used for the purpose of determining eligibility for a product or service. As required by the USA PATRIOT Act, we also collect information and take actions necessary to verify your identification.

B. Managing information within Fintura
Currently, Fintura is a single company with no subsidiaries. Fintura may share any of the categories of Customer Information among our companies. For example, sharing information allows us to use information about your credit card, home equity or student loan transactions to identify any unusual activity and then contact you to determine if your card has been lost or stolen or if your account number has been obtained by an unauthorized individual(s).

C. Managing information with companies that work for us
We may share any of the categories of Customer Information with companies that work for us, including-companies located outside the United States. All nonaffiliated companies that act on our behalf and receive Customer Information from us are contractually obligated to keep the information we provide to them confidential, and to use the Customer Information we share only to provide the services we ask them to perform. These companies may include financial service providers, such as payment processing companies, and non-financial companies, such as check printing and data processing companies. In addition, we may share any of the categories of Customer Information with companies that work for us in order to provide marketing support and other services, such as a service provider that distributes marketing materials. These companies may help us to market our own products and services or other products and services that we believe may be of interest to you.

2. Disclosing information in other situations
We also may disclose any of the categories of Customer Information to credit bureaus and similar organizations and when required or permitted by law. For example, Customer Information may be disclosed in connection with a subpoena or similar legal process, fraud prevention or investigation, risk management and security and recording of deeds of trust and mortgages in public records. Customer Information may also be disclosed to companies that process your requests for products or services or in connection with the sale of your account to another financial institution. We also may share any of the categories of Customer Information outside Fintura companies when we have your consent, such as when you request a specific insurance rate quote from a third-party insurer.

3. Making sure information is accurate
Keeping your account information accurate and up to date is very important. You have access to your account information, which includes your contact information, account balances and transactions and similar information which we provide to you through various means, such as account statements, telephone banking, Online Banking, and in response to specific requests. If your account information is incomplete, inaccurate or not current, please call or write to us at the telephone number or appropriate address for such changes listed on your account statement, bank records or other account materials. We or our partners will promptly update or correct any erroneous information.

4. Respecting your preferences
You have choices when it comes to how Fintura or its partners shares and uses information.

A. Sharing-among Fintura companies
You may request that Application Information, Consumer Report Information and Information from Outside Sources not be shared among-Fintura companies. Information is shared among Fintura companies and its partners to complete applications for new products or services that you request, thereby saving you time, and to manage our business and risks. During the normal course of doing business, we will continue to share Identification information, Transaction and Experience Information, as well as Other General Information among our companies. Vermont residents — see additional information at the end of this policy. For sharing among Fintura companies, each customer may tell us his or her preferences individually, or you may tell us the preferences for any other customers who are joint account owners with you.

B. Direct marketing
You may choose not to receive direct marketing offers — sent by postal mail, telephone and/or e-mail —from Fintura or its partners acting on Fintura’s behalf. These preferences apply to all marketing offers from us and from companies working for us. To minimize the amount of telephone solicitation our customers receive, Fintura and its partners do not offer non-financial products and services through outbound telephone solicitations. Direct marketing offers from us or our partners may include information about products and services we believe may be of interest to you. If you choose not to hear from us, you may not learn about beneficial offers. If you elect not to receive direct marketing offers by postal mail, telephone and/or e-mail, please note that we may continue to contact you as necessary to service your account and for other non-marketing purposes. You may also be contacted by your client relationship manager or assigned account representative, if applicable. Fintura and its partners may also continue to provide marketing information in your regular account mailings and statements, including online and ATM communications. Each customer may opt out of each direct marketing option individually. Since marketing programs may already be in progress, it may take up to 12 weeks in some situations for your opt-out to be fully effective. When you opt out of direct marketing by postal mail or telephone, your opt-out will last for five (5) years. After that, you may choose to renew your opt-out for another five-year period.

5. Actions you can take
You may contact the following agencies if you want to reduce the amount of advertising you receive from companies outside of Fintura and its partners:

A. Credit Reporting Industry
To have your name taken off all pre-approved credit solicitations, you may call the credit reporting industry Prescreening Opt-Out Number at 1.888.5optout (1.888.387.8888).

B. National Do Not Call Registry
Fintura supports the National Do Not Call Registry. To have your phone number added to the National Do Not Call Registry, you may call 1.888.382.1222 or register at donotcall.gov. While this will stop most calls, you may still receive calls from businesses where you are a customer.

6. Guarding your own information
Fintura recommends that you take the following precautions to guard against the disclosure and unauthorized use of your account and personal information:

1. Renew your credit report, at least once every year. Make sure all information is up to date and accurate, and have information relating to fraudulent transactions deleted. For a free copy of your credit bureau report, contact www.annualereditreport.com or call 1.877.322.8228.

2. If you think you have been a victim of identity theft or fraud, contact one of the three major credit bureaus to place a fraud alert on your account. You may also contact the Federal Trade Commission (FTC) to report any incidents of identity theft and to receive additional guidance on steps you can take to protect yourself. You may contact the FTC at www.consumer.go or call 1.877.438.4338 v/idtheft

3. Review your monthly account statements thoroughly and report any suspicious activity to us immediately.

4. Do not preprint your driver's license or Social Security number on checks.

5. Report lost or stolen checks, credit or debit cards immediately.

6. Safeguard ATM, credit, and debit cards. Memorize PINs (personal identification numbers) and refrain from writing PINs, Social Security numbers or credit card numbers where they could be found.

7. Tear up or shred any pre-approved credit, offers to which you do not respond.

8. Keeping up to date with Privacy Policies

As required by law, Fintura or its partners will provide notice of their Privacy Policy annually as long as you maintain an ongoing relationship with us. To receive the most up-to-date Privacy Policy, you can visit our Web site at: Fintura.com/privacy or call us at 404-419-2650. We may make changes to this policy at any time and will inform you of changes, as required by law. This policy applies to consumer customer relationships established in the United States and is effective March 1, 2007. This notice constitutes the Fintura Do Not Call Policy under the Telephone Consumer Protection Act for all consumers and is pursuant to state law. You may have other privacy protections under state laws, such as Vermont and California. To the extent these state laws apply, we will comply with them with regard to our information practices.

For Nevada residents only: Nevada law requires that we also provide you with the following contact information:

Bureau of Consumer Protection, Office of the Nevada Attorney General, 5;15 East Washington Street, Suite 3900, Las Vegas, NV 80101: Phone number: 1.702.486.3132; e-mail: BCPINFO@ag.state.nv.us.

For Vermont and California residents only: The information-sharing practices described above are in accordance with federal law, Vermont and California law place additional limits on sharing information about Vermont and California, residents so long as they remain residents of those states.

Vermont: In accordance with Vermont law, Fintura will not share information we collect about Vermont residents with companies outside of Fintura, except as permitted by law, such as with the consent of the customer, to service the customer's accounts or to other financial institutions with which we have joint marketing agreements. Fintura will not share Application Information, Customer Report Information and Information from Outside Sources about Vermont residents among-the Fintura companies except with the authorization or consent of the Vermont resident.

California: In accordance with California law, Fintura will not share information we collect about California residents with companies outside of Fintura, except as permitted by law, such as with the consent of the customer, to service the customer's accounts, to fulfill on rewards or benefits and otherwise, as permitted. We will limit sharing among our companies to the extent required by applicable California law.