The notice explains the following:
- Protecting the Confidentiality and Security of Consumer Information.
- The Types of Information We Have About You and Where it Comes From.
- Sharing Information with Affiliated Companies.
- Sharing Information for Legal, Business and Joint Marketing Purposes.
PROTECTING CONFIDENTIALITY AND SECURITY OF CONSUMER INFORMATION
We take seriously our responsibilities to respect the confidentiality and security of nonpublic personal information – called “Consumer Information” in this notice. Our policy calls for safeguards to protect Consumer Information from unauthorized access, alteration, and destruction. For example, our policies authorize access to Consumer Information only by those who need access to do their work. The same holds true for our affiliated companies, which are companies that, now or in the future, we own (or control), or are owned (or controlled) by, or are under common ownership (or control) with. We also may maintain, as required by applicable federal regulations, physical, electronic, and procedural safeguards to guard your nonpublic personal information.
INFORMATION WE COLLECT
We collect and use information about you from various sources. The amount and nature of the information collected and used varies from transaction to transaction, but the information can include the information described in the following five types:
- Information from you. Information you provide to us on applications, other forms, and by other means, such as your name, address, social security number, assets, income, and debt;
- Information from our experience and our affiliated companies’ experiences. Information about your transactions and account experience with us or our affiliated companies, such as parties to transactions, contract or lease balances, payment history, and communications and correspondence;
- Information from the experience of other parties. Information from outside sources regarding their employment, credit or other relationships, account experience, or transactions with you, or verifying representations made by you, such as your employment history, credit balances, or your property or liability insurance coverage. Information from credit reports. Information supplied by consumer reporting agencies, such as information regarding your creditworthiness or credit history.
- Other general information. Other general information we obtain about you (such as demographic information) that is not assembled for the purpose of determining your eligibility for credit, insurance, employment, or other products or services.
SHARING INFORMATION WITH AFFILIATED COMPANIES
We may disclose to our affiliated companies all of the information we collect about you as described in each of the five categories above. Our affiliated companies can be financial service providers such as leasing companies, insurance companies, and payment processing companies, as well as nonfinancial companies such as automotive repair facilities and data-processing companies. This sharing permits us to give you superior service, make a wider range of products available, and operate our business more effectively. We do not share information with nonaffiliated third parties, other than described below under “Sharing Information for Legal and Routine Business Reasons and for Joint Marketing.” Where they apply, we observe limits and restrictions set by law as to sharing certain kinds of information with our affiliates. For example, unless you authorize the sharing, we do not disclose creditworthiness information about you from credit reports.
SHARING INFORMATION FOR LEGAL AND GENERAL BUSINESS REASONS AND FOR JOINT MARKETING
We may disclose any of the above five types of Consumer Information to credit bureaus and similar organizations, and otherwise when permitted by law. For example, this may include a disclosure in connection with a subpoena or similar legal process, a fraud investigation, recording motor vehicle registration and other documents in public records, an audit or examination, or the sale of your account to another financial institution. We may also share any of the above five types of Consumer Information outside of our affiliated companies if we have your consent, such as when you’ve requested to be contacted by other companies we work with.
We may also share all five types of Consumer Information above with companies that work for us, possibly including some of our own affiliated companies, to perform services for us or functions on our behalf. These companies may include financial service providers such as banks, finance companies, insurance companies, and payment processing companies; nonfinancial companies such as automobile manufacturers and data-processing companies; and other organizations, such as nonprofit organizations that might provide education, training, or certification services to businesses such as ours. We may share any of the five types of Consumer Information above with companies that work for us to provide marketing and other services or with financial institutions with whom we have joint marketing agreements, such as banks or financing divisions of motor vehicle manufacturers. These companies act on our behalf and, within the time required by law, are required by our policy to be contractually obligated to keep the information that we provide to them confidential and to use the information only to provide the services we’ve asked them to perform for you or us.