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PRIVACY-POLICY PRIVACY-POLICY

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EFFECTIVE DEC 1 2021


EFFECTIVE JULY 2014


SYNCHRONY CARES ABOUT YOU AND YOUR PRIVACY.
WE NEVER SELL YOUR PERSONAL INFORMATION TO THIRD PARTIES.


ONLINE PRIVACY POLICY


EFFECTIVE AS OF DECEMBER 1, 2021

Synchrony Bank and each of its affiliate companies (collectively, “Synchrony,”
“we” or “us”) is committed to protecting your privacy. Please read this Privacy
Policy (the “Privacy Policy”) carefully before using this website (the “Site”).
This site is not directed to or intended for individuals under 18 years of age.

This Privacy Policy describes the types of information we may collect from
visitors to the Site, what we do with this information, and how visitors can
update and control the use of the information they provide on the Site. This
Privacy Policy applies solely to information collected through this Site. The
Privacy Policy does not apply to other information we may collect, including
data collected on other websites, such as separate sites operated by our
affiliates or business partners, or other information visitors may provide to us
through other means.

 * INFORMATION COLLECTED
 * HOW WE USE COLLECTED INFORMATION
 * HOW WE SHARE INFORMATION
 * SECURITY
 * CHOICES ABOUT YOUR INFORMATION
 * THIRD PARTY LINKS
 * CALIFORNIA PRIVACY RIGHTS
 * INTERNATIONAL USERS
 * EUROPEAN USERS
 * CHANGES TO THIS ONLINE PRIVACY POLICY
 * CONTACT

INFORMATION COLLECTED

Through the use of or access to our Site for online inquiry regarding the
products and services we offer (“Services”) or otherwise, we may collect
personal information about you, which is information that identifies you as an
individual, relates to you as an individual, or that, along with other
information, could identify you (“Personal Information”). We collect the
following types of Personal Information:

Information provided by you

We collect Personal Information from you when you:

 * Create an account. When you create an account with us, you will provide
   Synchrony your contact information.
 * Access our Site. For some products, to be able to access the Site, you must
   provide your telephone number and the last four digits of your Social
   Security number.
 * Interact with our Site or Services. When you send us any feedback, questions,
   comments, or suggestions, participate in one of our surveys, or interact with
   Synchrony in any way, you may provide us with Personal Information, such as
   your name, telephone number, address, and email address.

Information collected automatically

We may automatically collect the following Personal Information as you use our
Site or Services:

 * Usage Information. Which pages on our Site you access, the frequency of
   access, what you click on while on the Site, how long you access the Site,
   and when you accessed the Site
 * Location Information. Information about your location, which may be
   determined through your IP address or mobile device.
 * Device Information. Information about the device you are using, such as
   hardware model, operating system, browser, and IP address.
 * Mobile Device Information. Mobile network information, such as the unique
   identifier assigned to the device, mobile carrier, operating system, and
   other device attributes.

Information obtained from third parties

We may obtain Personal Information about you from third parties, such as credit
bureaus and demographic firms, when you use our Site or Services. We may also
obtain information about you from Payfone, the vendor that assists us in
verifying and authenticating your identity via mobile device.

Cookies and other tracking technologies

Cookies. “Cookies” are small pieces of information that are stored by your web
browser software on your computer’s hard drive or temporarily in your computer’s
memory. We seek to place and store Internet cookies on your hard drive. Cookies
can save any of the types of information noted above. Cookies enable us to
personalize your viewing experience and allow us to track statistical
information about navigation to and throughout certain areas of the Site and to
promotions on other sites. We also utilize third parties that may place and
store Internet cookies on your hard drive for web analytics. These third-party
cookies collect information about our Site traffic by tracking users across
websites and across time and generating reports for us to better understand our
Site users and to create audiences for our advertisements based on such
understanding. Third-party ad network providers that help us present ads on the
Site may also place cookies on your device to service you with ads or other
content personalized to your interests.

Adobe Analytics. We use a tool called “Adobe Analytics” for analytics and
advertising services. We use the information we get from Adobe Analytics to
improve the Services and to improve our ad performance. Adobe’s ability to use
and share information collected by Adobe Analytics about your use of the
Services or visits to the Site or to another application which partners with
Adobe, is restricted by Adobe Analytics Terms of Use and the Adobe Privacy
Policy available at: https://www.adobe.com/privacy/marketing-cloud.html.

Google Analytics. We use a tool called “Google Analytics” to collect some
information we listed above about your use of the Site and Services. We use the
information we get from Google Analytics to improve the Services. In order to
collect this information, Google Analytics may set cookies on your browser or
mobile device, or read cookies that are already there. Google Analytics may also
receive information about you from apps you have downloaded, that partner with
Google. We do not combine the information collected through the use of Google
Analytics with personally identifiable information. Google’s ability to use and
share information collected by Google Analytics about your use of the Services
or visits to the Site or to another application which partners with Google is
restricted by the Google Analytics Terms of Use and the Google Privacy Policy
available at: http://www.google.com/policies/privacy.

Social Media Widgets. Our Site includes social media features, such as Facebook,
LinkedIn, and Twitter. These features may collect information about your IP
address and which page you are visiting on our Site, and they may set a cookie
to ensure the feature functions properly. These features 2 may also provide you
with personalized ad content. Social media features and widgets are either
hosted by a third party or hosted directly on our Site. Your interactions with
those features and platforms are governed by the privacy policies of the
companies that provide them.

HOW WE USE COLLECTED INFORMATION

We use the Personal Information we collect to provide the Services to you, to
improve our Site and Services, and to protect our legal rights. Specifically, we
use the Personal Information we collect to:

 * Provide you with the Services
 * Validate cell phone use.
 * Communicate with you. To communicate with you about our Site or Services, to
   send you updates, or to inform you of any changes to the Site or Services.
 * Provide customer support. To provide you support or other services you
   request.
 * To communicate about new features. We will send you notifications about new
   features or information available on our Services or third-party products
   that we feel might be of interest to you.
 * Maintain and improve our Site and Services. We analyze how our users interact
   with the Site in order to maintain and improve the Site and Services.
 * Benchmarking. We aggregate your information in order to gain insights into
   our Services.
 * Prevent fraud and abuse.
 * Comply with applicable law.

HOW WE SHARE INFORMATION

We share your Personal Information with our service providers, among our
entities, in connection with the provision of the Services, a corporate
restructuring, to prevent harm, to comply with the law, and to protect our legal
rights. The legal basis for this is our legitimate interest in providing our
Services, complying with the law, and protecting our rights and those of others.

 * Service Providers. We share Personal Information with service providers that
   help us perform Site functions and provide you with the Services, such as
   Adobe and Google Analytics.
 * Advertising and Marketing. We may share your Personal Information with third
   parties so that they may provide you with information about products or
   services that may be of interest to you. We also share certain Personal
   Information with LiveRamp, our marketing service provider, to improve our
   marketing services. Personal Information gathered through the SMS (Short
   Message Service/Text Message) Program will not be shared with third parties.
 * Corporate Structure. We may share your Personal Information if we are
   involved or intend to be involved in a merger, acquisition, consolidation,
   change of control, or sale of all or a portion of our assets or in connection
   with bankruptcy or liquidation proceedings.
 * To Prevent Harm. We may share your Personal Information if we believe it is
   necessary in order to detect, investigate, prevent, or take action against
   illegal activities, fraud, or situations involving potential threats to the
   rights, property, or personal safety of any person.
 * To Protect Our Rights and As Required by Law. We will share Personal
   Information where we are legally required to do so, such as in response to
   court orders or legal process, to exercise our legal rights, to defend
   against legal claims or demands, or to comply with the requirements of any
   mandatory applicable law. We will also share Personal Information as
   necessary to enforce any other terms that you have agreed to, including to
   protect the rights, property, interest, or safety of Synchrony, its users, or
   any other person, or the copyright-protected content of the Services.
 * With Your Consent. We will request your permission to use or share your
   Personal Information for a specific purpose that is not compatible with the
   purposes listed here. We will notify you and request consent before we
   provide the Personal Information or before the Personal Information you have
   already provided is shared for such purpose.

SECURITY

At Synchrony, our goal is to protect your Personal Information submitted to us
through this Site. We maintain reasonable physical, electronic, and procedural
safeguards designed to protect and limit access to your Personal Information.
However, no method of transmission over the Internet or electronic storage
technology is 100% secure.

Therefore, while we strive to use commercially acceptable means to protect your
Personal Information, we cannot guarantee its absolute security. You are
responsible for maintaining the confidentiality of your account username and
password.We recommend that you choose a unique password for your account and
that you do not use any password that you also use for any other accounts which
may contain your sensitive information, such as financial accounts or email
accounts. You agree to immediately notify Synchrony of any unauthorized use of
your password or account or any other breach of security. We will not be
responsible or liable for any loss or damage arising from your failure to comply
with this provision.

If you access our Site from a public or shared computer, it may be possible for
other users to review your online history. For this reason, you should always
close your browser window after you finish any online banking session, including
visiting our Site. If you access our Site from a shared computer, you should
never set the Internet options to remember or store user IDs or passwords. Also,
you should never go to websites or follow web links that are unfamiliar or seem
suspicious to you.

CHOICES ABOUT YOUR INFORMATION

 * Access, Correct, or View Your Personal Information. You may use your account
   to view, access, or correct certain Personal Information you provided to us
   and which is associated with your account.
 * Do Not Track. We take no action in response to “Do Not Track” requests
   received from user’s web browsing software.
 * Cookies. If you would like to opt out of accepting cookies altogether, you
   can generally set your browser to not accept cookies or to notify you when
   you are sent a cookie, giving you the chance to decide whether or not to
   accept it. However, certain features of our Site or other services may not
   work if you delete or disable cookies.
 * Google Analytics. To prevent your data from being used by Google Analytics,
   you can download the Google Analytics opt-out browser add-on for Google
   Analytics which can be found here: https://tools.google.com/dlpage/gaoptout.
 * Adobe Analytics. To prevent your data from being used by Adobe Analytics, you
   can download the Adobe Analytics opt-out browser add-on for Adobe Analytics,
   which can be found here:
   https://www.adobe.com/privacy/opt-out.html#customeruse.
 * Third-Party Advertising and Marketing. If you do not wish for us to share
   your information with third parties for advertising or marketing purposes,
   you may choose to opt-out at any time by directing such request to
   1-844-894-3960
 * Online Advertising. To opt out of Internet-based advertising or to learn more
   about the use of this information by our service providers you can visit the
   Network Advertising Initiative website https://thenai.org/opt-out/ or the
   Digital Advertising Alliance website http://www.aboutads.info/choices/, or if
   you are in the EU, the EDAA http://www.youronlinechoices.eu/. If you choose
   to opt out, we will place an “opt-out cookie” on your computer. The “opt-out
   cookie” is browser specific and device specific and only lasts until cookies
   are cleared from your browser or device. The opt-out cookie will not work for
   some cookies that are important to how our websites and mobile apps work. If
   the cookie is removed or deleted, if you upgrade your browser or if you visit
   us from a different computer, you will need to return to the applicable
   website to re-select your preferences.

THIRD PARTY LINKS

This Privacy Policy only applies to the use and disclosure of Personal
Information we collect from visitors and customers online through our Site. Once
you leave our Site, either by a link or by entering a new Internet address in
your browser’s address window, we no longer have control over information
security, and we are not responsible for the content, privacy practices or your
use of other websites. We encourage you to review the privacy statements of
those other sites.

CALIFORNIA PRIVACY RIGHTS

If you are a California user of our Services (“California Consumer”), you have
certain rights with respect to the collection, use, transfer, and processing of
your Personal Information, as defined by the California Consumer Privacy Act
(CCPA). We reserve the right to limit these rights where permitted under
applicable law, including where your identity cannot be reasonably verified or
to the extent your rights adversely affect the rights and freedoms of others. To
exercise any of the rights below, please contact us via the contact information
below. Only you or a person registered with the California Secretary of State
that you authorize to act on your behalf, may make a verifiable consumer request
related to your Personal Information.

Collection of Personal Information

When California Consumers access our Site, we collect the following Personal
Information:

Personal Identifiers

 * Name
 * Address
 * Email address
 * Telephone number
 * Date of birth
 * Social Security number

Internet or Other Electronic Network Activity Information

 * The Internet Protocol address that relates to the machine or device used to
   access our Site
 * The type of browser and operating system used
 * The date and time when the Site is visited
 * Device ID if you are on a mobile device
 * Web pages displayed

The foregoing pieces of information have been collected about our consumers in
the past 12 months.

Sources from which Personal Information is Collected

We collect your identifiers from you directly. We collect your Internet or other
electronic network activity information from your interactions with our Site.

Business or Commercial Purposes for which Personal Information is Collected

Your Personal Information is used for the following purposes:

 * Provide you with the Services.
 * Validate cell phone use.
 * Communicate with you. To communicate with you about our Site or Services, to
   send you updates, or to inform you of any changes to the Site or Services.
 * Provide customer support. To provide you support or other services you
   request.
 * To communicate about new features. We will send you notifications about new
   features or information available on our Services or third-party products
   that we feel might be of interest to you.
 * Maintain and improve our Site and Services. We analyze how our users interact
   with the Site in order to maintain and improve the Site and Services.
 * Benchmarking. We aggregate your information in order to gain insights into
   our Services.
 * Prevent fraud and other illegal activities.
 * Comply with applicable law.
 * Defend our legal rights.

Third Parties with Whom Personal Information is Shared

Synchrony shares your Personal Information with analytics and service providers,
advertisers, business partners and law enforcement (if necessary).

In the preceding 12 months, we have not sold Personal Information about
consumers.

In the preceding 12 months, we have not sold Personal Information about minors.

In the preceding 12 months, we have disclosed the following Personal Information
about consumers for business purposes:

 * Identifiers, Other Personal Information (Financial Information), Employment
   Information, and Commercial Information. We share this information with our
   service providers to allow them to perform services on behalf of Synchrony.
   We may also share this information with our business partners so that they
   may provide you with information about products or services that may be of
   interest to you.
 * Internet or Other Electronic Network Activity Information. We share with or
   allow third parties to utilize cookies for marketing or advertising
   customized to your apparent interests or needs (more information located in
   the “Information Collected Automatically” section above).

Individual Rights

Right for You to Access Personal Information Collected, Disclosed, or Sold

You have the right to request that Synchrony disclose the Personal Information
it collects, uses, and discloses about you to third parties:

1. If you make a Right to Access request, you will receive the following
information about you:

 1. Categories of personal information collected;
 2. Categories of sources from which personal information are collected;
 3. Specific pieces of personal information collected about you;
 4. Business purpose for collecting or selling; and
 5. Categories of third parties with whom sold.

Synchrony does not sell any Personal Information of California Consumers. This
information will be provided to you free of charge, unless Synchrony determines
that your request is manifestly unfounded or excessive. You may request this
information twice in a 12-month period. This Right to Access is subject to
certain restrictions and is not available to consumers who have requested
information about, applied for, or maintain business credit through Synchrony.
Synchrony employees and employees of Synchrony business partners and service
providers also do not have a Right to Access under the CCPA.

Right of Erasure

You have the right to request that Synchrony and our service providers erase any
Personal Information about yourself which Synchrony has collected from you upon
receipt of a verifiable request. This right is subject to the same exceptions as
for Right to Access requests.

Submitting Requests

You can submit your request by calling us at 1-844-894-3960 or visiting our
request website at https://www.synchronycredit.com/ccpa/.

Verifying Requests

Synchrony provides California Consumers with an online webform to submit
requests. The webform is accessible at https://www.synchronycredit.com/ccpa/. As
stated in the webform, Synchrony must verify that the person requesting
information or deletion is the California Consumer about whom the request
relates in order to process the request. To verify a California Consumer’s
identity, we may request up to three pieces of Personal Information about you
when you make a request to compare against our records. We cannot respond to
your request or provide you with Personal Information if we cannot verify your
identity. Making a verifiable consumer request does not require you to create an
account with us. We will only use Personal Information provided in your request
to verify your identity. Synchrony reserves the right to take additional steps
as necessary to verify the identity of California Consumers where we have reason
to believe a request is fraudulent.

Right to Equal Service

Synchrony will not discriminate against you because you exercised any of your
rights, including, but not limited to, by:

 * Denying goods or services to you.
 * Charging different prices or rates for goods or services, including through
   the use of discounts or other benefits or imposing penalties.
 * Providing a different level or quality of goods or services to you.
 * Suggesting that you will receive a different price or rate for goods or
   services or a different level or quality of goods or services.

Annual Metrics

The following information is provided in accordance with the requirements of the
CCPA: Click here to access the Annual Metrics

INTERNATIONAL USERS

This is a United States-based website that is subject to United States law. This
Site is controlled, operated and administered by Synchrony from its offices
within the United States. This Privacy Policy is provided in accordance with and
subject to applicable U.S. law. If you are accessing this Site using a computer
that is located outside the United States, you are responsible to ensure that
your Internet connection is secure and is not monitored, legally or otherwise,
by any third party or jurisdiction. If you are unsure of the security of your
international Internet access, you should refrain from accessing this Site until
you have confirmed that your access is secure and not monitored. If you decide
to continue to access this Site from your location outside the United States,
you hereby agree that your use of this Site is subject to this Privacy Policy
and U.S. law and that you are responsible for complying with applicable laws in
all jurisdictions that govern your use and access of this Site.

EUROPEAN USERS

This section of our Policy provides certain required information to persons
located in the European Union (“EU”), a European Economic Area (“EEA”) member
state, or Switzerland. Before Synchrony collects any Personal Information from
you, you are entitled under the EU General Data Protection Regulation (“GDPR”),
to the information in this section of our Policy.

Purposes and Legal Basis for Processing Personal Information

Synchrony will only process your Personal Information for lawful purposes under
the GDPR related to Synchrony’s business purposes arising from your relationship
with Synchrony. Synchrony will ordinarily collect and process your Personal
Information because it is necessary for the performance of a contract to which
you are a party or because Synchrony has another legitimate interest in doing
so. When Synchrony cannot rely on either of such legal grounds, it will seek
your prior consent.

Rights of Residents of the European Union (EU)

If you use the Site and reside in the EU, EEA, or Switzerland, you are entitled
by law to access, correct, amend, or delete Personal Information about you that
we hold. A list of these rights is below. Please note that these rights are not
absolute and certain exemptions apply.

 * The right to access. You have the right to ask us for copies of your Personal
   Information. This right has some exemptions, which means you may not always
   receive all the Personal Information we collect and process. When making a
   request, please provide an accurate description of the Personal Information
   you want access to.
 * The right to rectification. You have the right to ask us to rectify
   information you think is inaccurate. You also have the right to ask us to
   complete information you think is incomplete.
 * The right to erasure. You have the right to ask us to erase your Personal
   Information in certain circumstances, including: (i) when your Personal
   Information is no longer necessary for the purposes for which it was
   collected or processed, or (ii) your Personal Information must be erased to
   comply with a legal obligation in EU Union or Member State law.
 * The right to restrict processing. You have the right to ask us to restrict
   the processing of your Personal Information in certain circumstances,
   including: (i) when the accuracy of the Personal Information is brought into
   question, or (ii) when we no longer need the Personal Information for
   purposes of the processing but you require such Personal Information for the
   establishment, exercise, or defense of a legal claim.
 * The right to object to processing. You have the right to object to processing
   of your Personal Information.
 * The right to data portability. You have the right to ask that we transfer the
   Personal Information you gave us from one organization to another, or give it
   to you.
 * The right to lodge a complaint with the supervisory authority. If you believe
   your rights under the GDPR have been violated, the GDPR gives you the right
   to file a complaint with the supervisory authority. A list of Supervisory
   Authorities is available here:
   http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm .

To exercise these rights please email us at privacyoffice@syf.com. For your
protection, we may need to verify your identity before responding to your
request. In the event that we refuse a request under rights of access, we will
provide you a reason as to why.

Right to Withdraw Consent

If Synchrony obtains your written consent to collect and process your Personal
Information, you can subsequently withdraw such consent as to any further
processing of information by emailing us at privacyoffice@syf.com.

Cross-Border Transfers of Personal Information

Personal Information that you provide while in the EU, an EEA member state, or
Switzerland will be transferred to the United States. The GDPR permits such
transfer when necessary for the performance of a contract between you and
Synchrony, if Synchrony obtains your explicit consent to such transfer, or if it
is in Synchrony’s legitimate interest to transfer the Personal Information. The
laws in the United States may not be as protective of your privacy as those in
your location. However, when transferring Personal Information to and processing
Personal Information in the United States, Synchrony will implement appropriate
safeguards and process the Personal Information in accordance with the terms of
this Privacy Policy. By using our Site, you agree to the transfer and processing
of your Personal Information to the United States.

Retention of Your Personal Information

We will retain your Personal Information until the Personal Information is no
longer necessary to accomplish the purpose for which it was provided. We may
retain your Personal Information for longer periods for specific purposes to the
extent that we are obliged to do so in accordance with applicable laws and
regulations, to protect you, other people, and us from fraud, abuse, and
unauthorized access, as necessary to protect our legal rights, or for certain
business requirements.

CHANGES TO THIS ONLINE PRIVACY POLICY

We reserve the right to modify or supplement this Privacy Policy at any time and
without prior notice. If we make any material change to the Privacy Policy, we
will update our Site to include such changes. We recommend that you review this
Privacy Policy regularly for changes.

CONTACT

If you have any questions or concerns about this Privacy Policy, you can contact
us at privacyoffice@syf.com.

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