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Affirm Privacy Policy

LAST UPDATED NOVEMBER 8, 2022


AFFIRM PRIVACY POLICY

PLEASE READ THIS PRIVACY POLICY CAREFULLY. THIS POLICY DESCRIBES THE WAYS
Affirm, INC. and its affiliate Affirm Loan Services, LLC ("Affirm", "we", "us",
"our") OR OUR VENDORS COLLECT, PROTECT, USE AND STORE YOUR PERSONAL INFORMATION.
YOU ACCEPT THIS PRIVACY POLICY BY USING OUR PRODUCTS AND SERVICES ON OUR WEBSITE
OR THROUGH ANY OTHER MEANS (COLLECTIVELY THE "SERVICES"). We may amend this
Privacy Policy at any time by posting a revised version on our website. We will
attempt to give a reasonable notice period upon making any changes; however,
unless otherwise stated, the revised version will be effective at the time we
post it.


1. HOW AFFIRM COLLECTS YOUR INFORMATION

1.1. INFORMATION YOU GIVE AFFIRM

If you open an account or use the Affirm Services, either directly or through a
merchant partner or a third-party platform, we may collect the following types
of information:

 * Personal information - your name, date of birth, Social Security number,
   address, phone, email, third-party application IDs, and other similar
   information.
 * Financial information - bank account online login information, bank account
   numbers, bank account details including transaction history, routing numbers
   and/or debit card numbers and credit card numbers that you link to your
   Affirm account or you give us when you use the Services. Before permitting
   you to use the Services, we may require you to provide certain information,
   including but not limited to your date of birth, social security number. We
   may use this information or other information you provide to verify your
   identity.

1.2. INFORMATION AFFIRM LEARNS FROM YOUR USE

When you visit the Affirm website or use the Services, we may collect
information sent to us by your computer, mobile phone or any other device. This
information may include your IP address, device information including but not
limited to identifier, name and type, operating system, location, mobile network
information and standard web log information, such as your browser type, traffic
to and from our site, the pages you accessed on our website, and any other
available information. We may also collect information about your use and
interaction with our website, application or the Services. For example, we may
evaluate your computer, mobile phone or other access device to identify any
malicious software or activity that may affect the availability of the Services.
When you use the Services, we may also store information based on your usage
history. This includes, but is not limited to, details of your purchases,
content you viewed, event information, click stream information, and cookies
that may uniquely identify your browser or your account. We may also collect
information about you from any contact you have with any of our services or
employees, such as, with our customer support team, in surveys, or through
interactions with our affiliates.

1.3. COOKIES AND OTHER TRACKING TECHNOLOGIES

We use various technologies to collect and store information when you use the
Services, and this may include sending one or more cookies or device
identifiers. We also use these tracking technologies when you interact with the
services we offer to our partners, such as advertising services or Affirm
features that may appear on other sites and in any other manner that we deem
necessary for our business purposes, such as:

 * Site operations: Enabling features that are necessary for providing you the
   Services on our site, such as identifying you as being signed in, tracking
   content views, remembering your preferences, and the number of times you have
   been shown an advertisement.
 * Analytics: Allowing us to understand how our Services are being used, track
   site performance, and make improvements.
 * Personalized advertising: Delivering tailored advertising based on your
   preferences or interests across services and devices, and measuring the
   effectiveness of advertisements.

You can learn more about ad-serving companies and the options available to limit
their collection and use of your information by visiting the websites for the
Network Advertising Initiative, the Digital Advertising Alliance, and the
European Interactive Digital Advertising Initiative. Similarly, you can learn
about your options to opt out of mobile app tracking by certain advertising
networks through your device settings and by resetting the advertiser ID on your
Apple or Android device.

Please note that opting out of advertising networks services does not mean that
you will not receive advertising while using our Services or on other websites,
nor will it prevent the receipt of interest- based advertising from other
companies that do not participate in these programs. It will, however, exclude
you from interest-based advertising conducted through participating networks, as
provided by their policies and choice mechanisms. Note that if you delete your
cookies, you may also delete your opt-out preferences

1.4. INFORMATION OBTAINED FROM THIRD PARTIES

We may also obtain information about you from third parties such as credit
bureaus and identity verification services. If you apply for a loan or line of
credit with Affirm, we will obtain consumer reports from consumer reporting
agencies related to you at the time of your collection and periodically
throughout the term of your loan or line of credit, as well as in connection
with the use of any other services that we offer or that you may obtain from us
(including financial management services, credit profile tools, and the Affirm
marketplace).

You may choose to provide us with access to certain personal information stored
by third parties such as social media sites (such as Facebook and Twitter). The
information we have access to varies by site and is controlled by your privacy
settings on that site and your authorization. By associating an account managed
by a third party with your Affirm account and authorizing Affirm to have access
to this information, you agree that Affirm may collect, store and use this
information in accordance with this Privacy Policy.


2. HOW AFFIRM PROTECTS YOUR INFORMATION

2.1. SAFETY POLICIES

Affirm stores and processes your information maintaining physical, electronic
and procedural safeguards. We maintain physical security measures to guard
against unauthorized access to systems and use safeguards such as firewalls and
data encryption. We enforce physical access controls to our buildings, and we
authorize access to personal information only for those employees or agents who
require it to fulfill the responsibilities of their jobs.


3. HOW AFFIRM USES YOUR INFORMATION

3.1. TO IMPROVE OUR SERVICE

Affirm uses information to perform and improve our services, contact you,
conduct research, and provide anonymous reporting for clients. For example, we
may use information to provide customer service and support, process
transactions, resolve disputes, collect payments, prevent illegal activities,
customize the Services, reduce risk to all parties involved in our transactions,
and verify the accuracy of information.

3.2. TO SERVE RELEVANT MARKETING TO YOU

We may use information to deliver targeted marketing, service update notices,
and promotional offers based on your communication preferences. We may combine
your information with information we collect from other companies and use it to
improve and personalize the Services, content, and advertising.


4. HOW AFFIRM SHARES YOUR INFORMATION.

4.1. FOR OUR EVERYDAY BUSINESS PURPOSES

We share your personal information with employees, affiliates, vendors,
partners, merchant partners, marketing providers, and third parties as required
to offer the Affirm Services. This includes, but is not limited to, processing
transactions, maintaining your account, offering or servicing loans or lines of
credit, offering other financial services, responding to court orders and legal
investigations, litigation purposes, complying with audits or other
investigations, and reporting to credit bureaus. We also engage the following
types of service providers to perform functions on our behalf: marketing
providers, billing and collection providers, auditing and accounting firms,
professional services consultants, providers of analytics services, security
vendors, and IT vendors. Occasionally, these service providers may also collect
data directly from you and their privacy policies may also apply. Affirm will
not share your financial information collected under Section 1.1 of this Privacy
Policy with any third party unless required by law or valid court order.

4.2. WHEN REQUIRED BY LAW

We will share your information with any party when required by law or by a
government request to do so or to combat fraud or criminal activity.

4.3. WITH OUR MERCHANT PARTNERS TO PROVIDE PERSONALIZED OFFERS

We may share your information with merchants you interact with using Affirm for
marketing, if you consent or as permitted by law. For accounts created on or
after 11/30/17: By creating an Affirm account, you consent to Affirm sharing
your information with merchants you use the Affirm Services with, for those
merchants to market to you. We do this to help merchants personalize services
and offers, so you can have a better experience. You're able to revoke your
consent at any time by following the steps below. If you choose to do so, we
will stop sharing your information with merchants from that point onward, except
as necessary to complete transactions you initiate. To revoke your consent to
information sharing with merchants for marketing, you can log into your Affirm
account at www.affirm.com/u/ and edit your Personalized Services preferences.


5. WHAT ARE YOUR OPTIONS?

5.1 NOTIFICATIONS

If you no longer wish to receive notifications about our Services, you may
change your notification preferences by emailing help@affirm.com. Alternatively,
you may be able to indicate your preference by logging into your account and
adjusting your preferences or by following the directions provided with the
communication. Affirm reserves the right to close or limit access to your
account should you opt out of the crucial notices that are required to perform
the Affirm Service. You are still responsible for any amounts due to Affirm even
if we close or limit access to your account.

5.2 SMS MESSAGING

You can opt out of receiving SMS messages by emailing help@affirm.com.
Alternatively, you may be able to indicate your preference by logging into your
account and adjusting your preferences or by following the directions provided
with the communication. Again, Affirm reserves the right to close or limit
access to your account should you opt out of the crucial notices that are
required to perform the Affirm Service. You are still responsible for any
amounts due to Affirm even if we close or limit access to your account.

5.3 ACCESS YOUR INFORMATION

You can review and edit your personal information at any time by logging in to
your account or by contacting us at help@affirm.com. You can also request to
close your account if you do not have an active loan by contacting us at
help@affirm.com. If you close your Affirm account, we will mark your account in
our database as "Closed," but will keep your account information in our database
to comply with our legal obligations. This is necessary in order to deter fraud,
by ensuring that persons who try to commit fraud will not be able to avoid
detection simply by closing their account and opening a new account. If you
close your account, your personally identifiable information will not be used by
us for any further purposes, nor sold or shared with third parties, except as
necessary to prevent fraud and assist law enforcement, as required by law or in
accordance with this Privacy Policy.


6. CALIFORNIA CONSUMERS

6.1 YOUR CALIFORNIA PRIVACY RIGHTS

Persons with disabilities may obtain this notice in alternative format upon
request by contacting us at privacy@affirm.com or by calling Customer Care at
(855) 423-3729.
California Shine the Light: Residents of the State of California have the right
to request information from Affirm regarding other companies to whom the company
has disclosed certain categories of information during the preceding year for
the other companies' direct marketing purposes. If you are a California resident
and would like to make such a request, please click HERE or email
privacy@affirm.com.
California Consumer Privacy Act: The California Consumer Privacy Act ("CCPA")
provides California residents with the right to receive certain disclosures
regarding the collection, use, and sharing of "Personal Information," as well as
the right to know/access, delete, and limit sharing of Personal Information. The
CCPA defines "Personal Information" to mean "information that identifies,
relates to, describes, is reasonably capable of being associated with, or could
reasonably be linked, directly or indirectly, with a particular consumer or
household." Certain information we collect may be exempt from the CCPA because
it is considered public information (e.g., it is made available by a government
entity) or covered by a specific federal privacy law, such as the
Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act,
or the Fair Credit Reporting Act.

To the extent that we collect Personal Information that is subject to the CCPA,
that information, our practices, and your rights are described below.

Right to notice at collection regarding the categories of personal information
collected

You have the right to receive notice of the categories of Personal Information
we collect, and the purposes for which those categories of Personal Information
will be used. This notice should be provided at or before the time of
collection. The categories we use to describe the information are those
enumerated in the CCPA.

 * Personal identifiers:
   
   * We collect your name, phone number, and email address and contact address
     when you create an account or complete a transaction. If you choose to
     create an account, you will also be asked to create a username, and we will
     assign one or more unique identifiers to your profile. We use this
     information to provide the Services, respond to your requests, and send
     information and advertisements to you.
   
   * We collect payment information when you provide it to us, which may be your
     credit card number or a bank account, when you complete a transaction. You
     have the option to store this information to your account or set up a
     recurring transaction. We use this information to streamline and facilitate
     payments and transactions.
   
   * We may collect your Social Security number or Driver's License number. We
     use this information to identify you, authenticate and collate information
     about you, prevent fraud, and conduct background checks or other screening
     activities.
   
   * We collect your IP address automatically when you use our Services. We use
     this information to identify you, gauge online activity on our website,
     measure the effectiveness of online services, applications, and tools, and
     to serve targeted advertisements based on your online activities.
   
   * We collect your Device ID automatically when you use our Services. We use
     this information to monitor your use, and the effectiveness of, our
     Services, to identify you, and to provide you with targeted information and
     offers.

 * Protected classifications: We collect your age in order to comply with laws
   that restrict collection and disclosure of personal information belonging to
   minors.

 * Commercial information: When you engage in transactions with us, we create
   records of goods or services purchased or considered, as well as purchasing
   or consuming histories or tendencies. We use this information to measure the
   effectiveness of our Services and to provide you with targeted information,
   advertisements, and offers.

 * Biometric information: We collect information about your physiological,
   biological, and behavioral characteristics. We use this information to verify
   your identity.

 * Internet or other electronic network activity information: We collect
   information about your browsing history, search history, interaction with
   websites, and applications or advertisements automatically when you utilize
   our Services. We use this information to gauge online activity on our
   website, measure the effectiveness of online services, applications, and
   tools, and to serve targeted advertisements based on your online activities.

 * Geolocation data: As described above, we collect your IP address
   automatically when you use our Services. We may be able to determine your
   general location based on your device's IP address. When you use the Services
   for the first time, we may ask for your permission to collect your precise
   location (i.e., your GPS coordinates). If you allow your device to provide us
   with this information, we use it to make improvements to our products and
   services, and to provide recommendations and deliver relevant advertising.

 * Audio, electronic, visual, or similar information: If you contact us via
   phone, we may record the call. We will notify you if a call is being recorded
   at the beginning of the call. We may collect your photographic or video
   image, or similar information. We use this information to monitor our
   customer service, maintain the security of our systems and physical
   locations, and train employees.

 * Professional or employment-related information: We collect information about
   your current employer and your employment history. We use this information to
   conduct background and other screening activities, and to promote our
   services to others.

 * Inferences drawn to create a profile about a consumer reflecting the
   consumer's preferences or characteristics: We may analyze your actual or
   likely preferences through a series of computer processes. On some occasions,
   we may add our observations to your internal profile. We use this information
   to gauge and develop our marketing activities, measure the appeal and
   effectiveness of our Services, applications, and tools, and to provide you
   with targeted information, advertisements, and offers.

We may use any of the categories of information listed above for other business
or operational purposes compatible with the context in which the Personal
Information was collected.

We may share any of the above-listed information with Service Providers, which
are companies that we engage for business purposes to conduct activities on our
behalf. Service Providers are restricted from using Personal Information for any
purpose that is not related to our engagement. The categories of Service
Providers with whom we share information and the services they provide are
described in this Privacy Policy.

Right to know about personal information collected, disclosed, or sold

You have the right to request that we disclose to you the Personal Information
we collect, use, disclose, or sell. In order to process your request to
know/access your Personal Information or delete your Personal Information we may
ask you to take additional steps to verify your request or identity.

Verification procedures

In order to process your request to know about or delete personal information we
collect, disclose, or sell, we must verify your request. We do this by:

 * Providing personal identifiers we can match against information we may have
   collected from you previously, and

 * Asking you to confirm your request using the email address or telephone
   account stated in the request.

If you have authorized someone else to make requests on your behalf, we will
require that you provide notarized statements confirming the identity and
authority of that person. Such notarized statements can be obtained by emailing
privacy@affirm.com

Right to know/access information

You have the right to request access to Personal Information collected about you
and information regarding the source of that information, the purposes for which
we collect it, and the third parties and service providers with whom we share
it. To protect our customers' Personal Information, we are required to verify
your identify before we can act on your request.

Right to request deletion of information

You have the right to request in certain circumstances that we delete any
Personal Information that we have collected directly from you. To protect our
customers' Personal Information, we are required to verify your identity before
we can act on your request. We may have a reason under the law why we do not
have to comply with your request, or why we may comply with it in a more limited
way than you anticipated. If we do, we will explain that to you in our response.

Right to information regarding participation in data sharing for financial
incentives

You have the right to be free from discrimination based on your exercise of your
CCPA rights. We may run promotions from time to time wherein we incentivize a
consumer to share certain pieces of information with us. Participation in these
incentives is voluntary, and you may opt out of the data sharing at any time.

Right to opt out of sale of personal information to third parties

Though Affirm does not sell Personal Information to third parties, California
law requires that we maintain a separate webpage that allows you to opt out of
the sale of your Personal Information in the future, which can be accessed by
visiting our "Do not sell my info" webpage or by calling us at (855) 423-3729.

Please note that your right to opt out does not apply to our sharing of Personal
Information with service providers, who are parties we engage to perform a
function on our behalf and are contractually obligated to use the Personal
Information only for that function.

We may also disclose information to other entities when required by law or to
protect Affirm or other persons, as described in our Privacy Policy.

How to submit a request

You may submit a request to exercise your rights through the following means:

 1. By visiting www.affirm.com/privacy, where you can request and download
    specific pieces of information we have collected. By signing in to your
    account to submit the request, you will be able to automatically verify your
    identity, which will result in faster processing of your request.

 2. By calling us at (855) 423-3729.

Authorized agent

You may authorize another individual or a business registered with the
California Secretary of State, called an authorized agent, to make requests on
your behalf. We require that you and the individual complete notarized
affidavits in order to verify the identity of the authorized agent and confirm
that you have authorized them to act on your behalf.


7. NEVADA RESIDENTS

7.1 SPECIAL INFORMATION FOR NEVADA RESIDENTS

Residents of the State of Nevada have the right to opt out of the sale of
certain pieces of their information to other companies who will sell or license
their information to others. Affirm does not sell the Personal Information of
its customers. However, if you are a Nevada resident and would like to make such
a request, please email privacy@affirm.com.


8. CONTACT AFFIRM

8.1 CONTACT AFFIRM

If you have questions or concerns regarding this Privacy Policy, you should
contact us at help@affirm.com.

REV. 11/2022


AFFIRM PRIVACY NOTICE



FactsWhat does Affirm, Inc. do with your personal information?Why? Financial
companies choose how they share your personal information. Federal law gives
consumers the right to limit some but not all sharing. Federal law also requires
us to tell you how we collect, share, and protect your personal information.
Please read this notice carefully to understand what we do. What? The types of
personal information we collect and share depend on the product or service you
have with us. This information can include:
- Social security number and payment history
- Transaction history and account transactions
- Credit scores and checking account information
When you are no longer our customer, we continue to share your information as
described in this notice. How? All financial companies need to share customers'
personal information to run their everyday business. In the section below, we
list the reasons financial companies can share their customers' personal
information; the reasons Affirm, Inc. chooses to share; and whether you can
limit this sharing.

Reasons we can share your personal informationDoes Affirm, Inc. share?Can you
limit this sharing?For our everyday business purposes--
such as to process your transactions, maintain your account(s), offer or service
loans or lines of credit, offer other financial services, respond to court
orders and legal investigations, or report to credit bureaus YesNoFor our
marketing purposes--
to offer our products and services to you YesNoFor joint marketing with other
financial companiesYesNoFor our affiliates' everyday business purposes--
information about your transactions and experiences YesNoFor our affiliates'
everyday business purposes--
information about your creditworthiness YesYes For our affiliates to market to
you YesYes For nonaffiliates to market to you YesYes

To Limit Our Sharing You may limit our sharing by logging into your Affirm
account at www.affirm.com/u/ and editing your Personalized Services preferences.

You may also call 855-423-3729 or email help@affirm.com.


Please note:
If you are a new customer, we can begin sharing your information 30 days from
the date we sent this notice, or earlier if you consent or as permitted by law.
When you are no longer our customer, we continue to share your information as
described in this notice.

However, you can contact us at any time to limit our sharing.



Questions?Call 855-423-3729 or email help@affirm.com

Who we areWho is providing this notice? Affirm, Inc. What we doHow does Affirm,
Inc. protect my personal information? To protect your personal information from
unauthorized access and use, we use security measures that comply with federal
law. These measures include computer safeguards and secured files and buildings.
How does Affirm, Inc. collect my personal information? We collect your personal
information, for example, when you
- Apply for a loan or open an account
- Provide account information or pay your bills
- Use your credit or debit card
We also collect your personal information from others, such as credit bureaus,
affiliates, or other companies. Why can't I limit all sharing? Federal law gives
you the right to limit only
- sharing for affiliates' everyday business purposes--information about your
creditworthiness
- affiliates from using your information to market to you
- sharing for nonaffiliates to market to you
State laws and individual companies may give you additional rights to limit
sharing. See below for more on your rights under state law.
DefinitionsAffiliates Companies related by common ownership or control. They can
be financial and nonfinancial companies.

Our affiliates include companies with an Affirm name, as well as nonfinancial
companies, such as Returnly Holdings, LLC. Nonaffiliates Companies not related
by common ownership or control. They can be financial and nonfinancial
companies.
- Nonaffiliates we can share with include our merchant partners, third-party
platforms, and marketing service providers. Joint marketing A formal agreement
between nonaffiliated financial companies that together market financial
products or services to you.

Our joint marketing partners include bank and merchant partners. Other important
informationSpecial Notice For State Residents

For California Residents. We will not share personal information with affiliates
or nonaffiliates except as permitted by California law, such as to process your
transaction or with your consent.

For Vermont Residents. We will not share personal information with affiliates or
nonaffiliates except as permitted by Vermont law, such as to process your
transaction or with your consent.



REV. 4/2020


CROSS RIVER BANK PRIVACY NOTICE



FactsWhat does Cross River Bank do with your personal information?Why? Financial
companies choose how they share your personal information. Federal law gives
consumers the right to limit some but not all sharing. Federal law also requires
us to tell you how we collect, share and protect your personal information.
Please read this notice carefully to understand what we do. What? The types of
personal information we collect and share depend on the product or service you
have with us. This information can include:
- Social Security number and Account balances
- Payment history and Transaction history
- Account transactions and Wire transfer instructions
When you are no longer our customer, we continue to share your information as
described in this notice. How? All financial companies need to share customers'
personal information to run their everyday business. In the section below, we
list the reasons financial companies can share their customers' personal
information; the reasons Cross River Bank chooses to share; and whether you can
limit this sharing.

Reasons we can share your personal informationDoes Cross River Bank share?Can
you limit this sharing?For our everyday business purposes-
such as to process your transactions, maintain your accounts, offer loans or
lines of credit, offer other financial services, respond to court orders and
legal investigations, or report to credit bureaus YesNoFor our marketing
purposes-
to offer our products and services to you YesNoFor joint marketing with other
financial companiesYesNoFor our affiliates' everyday business purposes-
information about your transactions and experiences NoWe don't shareFor our
affiliates' everyday business purposes-
information about your creditworthiness NoWe don't share For nonaffiliates to
market to you NoWe don't share

Questions?Call toll-free 1-877-55CRB55 or go to www.crossriverbank.com

What we doHow does Cross River Bank protect my personal information? To protect
your personal information from unauthorized access and use, we use security
measures that comply with federal law. These measures include computer
safeguards and secured files and buildings.
We also maintain other physical, electronic and procedural safeguards to protect
this information and we limit access to information to those employees for whom
access is appropriate. How does Cross River Bank collect my personal
information? We collect your personal information, for example, when you
- Open an account or Apply for a loan
- Make deposits or withdrawals from your account or Provide employment
information
- Give us your contact information
We also collect your personal information from others, such as credit bureaus,
affiliates, or other companies. Why can't I limit all sharing? Federal law gives
you the right to limit only
- sharing for affiliates' everyday business purposes-information about your
creditworthiness
- affiliates from using your information to market to you
- sharing for nonaffiliates to market to you
State laws and individual companies may give you additional rights to limit
sharing. See below for more on your rights under state law.
DefinitionsAffiliates Companies related by common ownership or control. They can
be financial and nonfinancial companies.
- Cross River Bank does not share with our affiliates.Nonaffiliates Companies
not related by common ownership or control. They can be financial and
nonfinancial companies.
- Nonaffiliates we share with can include loan finance companies.Joint marketing
A formal agreement between nonaffiliated financial companies that together
market financial products or services to you.
- Our joint marketing partner(s) include loan finance companies.Other important
informationSpecial Notice For State Residents

For Alaska, Illinois, Maryland and North Dakota Customers. We will not share
personal information with nonaffiliates either for them to market to you or for
joint marketing-without your authorization.

For California Customers. We will not share personal information with
nonaffiliates either for them to market to you or for joint marketing-without
your authorization. We will also limit our sharing of personal information about
you with our affiliates to comply with all California privacy laws that apply to
us.

For Massachusetts, Mississippi and New Jersey Customers. We will not share
personal information from deposit or share relationships with nonaffiliates
either for them to market to you or for joint marketing-without your
authorization.

For Vermont Customers. We will not disclose information about your
creditworthiness to our affiliates and will not disclose your personal
information, financial information, credit report, or health information to
nonaffiliated third parties to market to you, other than as permitted by Vermont
law, unless you authorize us to make those disclosures. Additional information
concerning our privacy policies can be found at www.crossriverbank.com or call
1-877-55CRB55.



REV. 4/2020


CELTIC BANK PRIVACY NOTICE



FactsWhat does Celtic Bank do with your personal information?Why? Financial
companies choose how they share your personal information. Federal law gives
consumers the right to limit some but not all sharing. Federal law also requires
us to tell you how we collect, share and protect your personal information.
Please read this notice carefully to understand what we do. What? The types of
personal information we collect and share depend on the product or service you
have with us. This information can include:
- Social Security number and income
- Account balances and payment history
- Credit history and credit scores
When you are no longer our customer, we continue to share your information as
described in this notice. How? All financial companies need to share customers'
personal information to run their everyday business. In the section below, we
list the reasons financial companies can share their customers' personal
information; the reasons Celtic Bank chooses to share; and whether you can limit
this sharing.

Reasons we can share your personal informationDoes Celtic Bank share?Can you
limit this sharing?For our everyday business purposes-
such as to process your transactions, maintain your accounts, offer loans or
lines of credit, offer other financial services, respond to court orders and
legal investigations, or report to credit bureaus YesNoFor our marketing
purposes-
to offer our products and services to you NoWe don't shareFor joint marketing
with other financial companiesNoWe don't shareFor our affiliates' everyday
business purposes-
information about your transactions and experiences NoWe don't shareFor our
affiliates' everyday business purposes-
information about your creditworthiness NoWe don't share For our affiliates to
market to you NoWe don't share For nonaffiliates to market to you NoWe don't
share

Questions?Call 800.854.7848 or go to www.celticbank.com

Who we areWho is providing this notice? Celtic Bank

What we doHow does Celtic Bank protect my personal information? To protect your
personal information from unauthorized access and use, we use security measures
that comply with federal law. These measures include computer safeguards and
secured files and buildings. How does Celtic Bank collect my personal
information? We collect your personal information, for example, when you
- Open an account
- Apply for a loan
We also collect your personal information from others, such as credit bureaus,
affiliates, or other companies. Why can't I limit all sharing? Federal law gives
you the right to limit only
- Sharing for affiliates' everyday business purposes-information about your
creditworthiness
- Affiliates from using your information to market to you
- Sharing for nonaffiliates to market to you
State laws and individual companies may give you additional rights to limit
sharing. See below for more on your rights under state law.
DefinitionsAffiliates Companies related by common ownership or control. They can
be financial and nonfinancial companies.
- Celtic Bank does not share with our affiliate.Nonaffiliates Companies not
related by common ownership or control. They can be financial and nonfinancial
companies.
- Celtic Bank does not share with nonaffiliates so they can market to you.Joint
marketing A formal agreement between nonaffiliated financial companies that
together market financial products or services to you.
- Celtic Bank does not jointly market.Other important information




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