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Table of Contents

Privacy Policy Overview
Who is covered by this policy?
What are your security practices for safeguarding my information?
What information do you collect?
What information do you disclose and how can I prevent such disclosure?
What can I do to protect myself against identity theft?
Protecting Children
How will I know if your Privacy Policy changes?
How do I contact ClearCard?

Privacy Policy

Protecting your privacy is of the utmost importance to us. We want you to understand what information we collect and how we use it. We use technology to manage and maintain client information to provide our clients with a broad range of superior financial products and services as effectively and conveniently as possible.

ClearCard is a financial entity that conducts business primarily on the Internet. We are dedicated to providing Internet clients with the best online financial products and services loaded with features that Internet users really want.

To maintain the security of your information throughout the application and transaction process, ClearCard uses the SSL (Secure Sockets Layer) protocol that is built into most web browsers. When you enter private information, your information is encrypted as it travels between your computer and our servers. ClearCard encourages the use of browsers that use 128-bit encryption.

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Who is covered by this policy

This Privacy Policy is provided to you by ClearCard, Inc. ("ClearCard") and their subsidiaries and affiliates. As used in this Privacy Policy, "we," "us," "our," or "ours" refers to ClearCard, Inc. and their subsidiaries and affiliates. "You," "your," and "yours" refers to each individual who is one of our clients or former clients and other individuals who obtain or request a financial product or service from us.

If you decide to close your account(s) or become an inactive client, we will continue to adhere to the privacy policies and practices described in this notice.

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Security Practices and the Safeguarding of Information

ClearCard takes client data security very seriously. We have designed one of the safest and most error-free systems on the Internet. As part of our commitment to providing the highest level of security, we engage expert, third party vendors to conduct regular reviews of our security systems, and to ensure that our standards are not compromised.

We also take steps to safeguard client information. We restrict access to your personal and account information to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

Please see our Security Policy for greater detail regarding our security measures.

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Information We Collect

As part of providing superior processing service to our clients and still upholding the rules and regulations we are bound to from entities such as Visa and MasterCard we must understand your business profile and may collect "nonpublic business related information" about you and your company, including:

Information we receive from you on applications, surveys, online registrations or other forms, whether in writing, by telephone, electronically or by any other means. This information may include your name, address, employment information, income and credit references.

Information about your transactions with us, our affiliates, or others. This information may include your account balances, payment history, and account usage.

Information we receive from credit reporting agencies, such as information relating to your creditworthiness, your company credit history, and credit usage and from third parties to verify information you have given us.
"Nonpublic personal information" is nonpublic information about you that we obtain in connection with providing a financial product or service to you. For example, nonpublic personal information includes information regarding your account balance and payment history.

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Information We Disclose
Affiliates to whom we may disclose personal information about you are in the financial services business. We may share categories of nonpublic information described above under "Information We Collect" with our affiliates to carry out your transactions or to inform you of services or products that might be of interest to you. Under the Fair Credit Reporting Act, you have the right to prevent the sharing of certain information among our affiliates. You can prevent the sharing of information by following the "opt out" provision in your ClearCard Account Agreement.

We are permitted under law to disclose nonpublic personal information about you to "nonaffiliated third parties" in certain circumstances. We may disclose nonpublic personal information about you of the types described above under "Information We Collect" to the following types of nonaffiliated third parties:

Financial services providers, such as companies engaged in banking, credit cards and consumer finance.

Non-financial companies, such as companies engaged in direct marketing and the selling of consumer products and services.

Service providers who perform marketing services for us.
Financial institutions with which we may have joint marketing arrangements

For example, we may disclose nonpublic personal information about you to third parties to assist us in servicing your account, to provide you with products and services you have requested, to credit reporting agencies and as required by law. We may also disclose nonpublic personal information about you to nonaffiliated third parties as permitted by law.

We may also provide information about you to our service providers to help us perform marketing services (including the marketing of our products and services and the products and services of nonaffiliated companies). The information provided to these service providers may include the categories of information described above under "Information we collect" and is limited to only that which we deem appropriate for these service providers to carry out their services. These nonaffiliated companies are not permitted to use this information for other purposes.

To provide you superior client service, to offer you access to our services and to make a wider range of products and services available to you, we reserve the right to disclose all nonpublic personal information about you to nonaffiliated third parties. If you prefer that we not disclose nonpublic personal information about you to such nonaffiliated third parties, you may opt out of this disclosure, that is, you may direct us not to make those disclosures (other than permitted by law). You may opt out or opt back in for this nonaffiliated third party information disclosure at any time by one of the following methods:

When notifying us not to disclose your account information, please provide us with your name and street address. Do not provide your account number in this email as this email is not secured. Your "opt out" preference will apply to accounts on which you are the primary client and will also apply to the authorized user on the account. If the authorized user has separate accounts, your "opt out" will not apply to those separate accounts. Please allow 30 days for your preference to take effect.

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Helping Us Maintain Your Privacy and Protecting You from Identity Theft

You are the most effective safeguard against fraud. There are many steps you can take to ensure that your personal information remains safe and secure.
Tips for safeguarding your personal information:

Don't give your personal credit information, especially your Social Security Number, over the phone unless you initiate the call.

Destroy all receipts, bank statements and unused credit card offers before throwing them away.

Watch closely for any missing mail.
Only mail your bills from secure mailboxes that can't be opened by anyone other than U.S. Postal personnel.
Keep a close eye on your account statements for any unauthorized charges.
Review your credit report once a year to confirm its accuracy.
Make sure you only do business with companies you know to be reputable, especially when doing business online.
When doing business online, make sure a padlock or key icon is active on your browser.
Use virus detection software, and don't open email from unknown sources.
Keep your PIN numbers secret, and don't carry them in your wallet. Protect your passwords by using letters and numbers in combination, and change them regularly.
If you suspect fraud, report it to your bank and our customer service office immediately.

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Protecting Children

We do not knowingly solicit data from nor knowingly market to children. Our website is directed to adult clients and potential clients. The application process is designed to screen out applications submitted by children under the age of 18 so that a child will not open an account.

Parents can use various readily available software packages to prevent their children from accessing websites that they deem to be inappropriate. Parents can choose to utilize this and other methods to limit the websites to which their children have access.

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Changes to our Privacy Policy

From time to time, we may modify our privacy policy. A copy of this policy will be provided at the time of account opening and annually for as long as you maintain a client relationship with us. If a change is made we will notify you via email of the relevant changes. We also recommend that you review this policy occasionally at our website, www.ClearCard.com.

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Contacting Us

If you have questions about this privacy statement or the business practices of this website, you can email us at privacy@ClearCard.com. We remind you to not provide your account number or other sensitive data in this email.