Financial Privacy Policy

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rev. 04/13

FACTS

WHAT DOES COMENITY 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

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 Comenity chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information Does Comenity share? Can you limit this sharing?
For our everyday business purposes-such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus Yes No
For our marketing purposes-to offer our products and services to you Yes No
For joint marketing with other financial companies Yes No
For our affiliates' everyday business purposes-information about your transactions and experiences Yes No
For our affiliates' everyday business purposes-information about your creditworthiness Yes Yes
For our affiliates to market to you Yes Yes
For nonaffiliates to market to you Yes Yes

To limit our sharing

Please note:
If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. 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? Go to comenity.net/privacy or call 1-866-423-1097

Who we are
Who is providing this notice? This privacy notice is provided by the Comenity family of companies, including Comenity Bank and Comenity Capital Bank.

What we do
How does Comenity 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 Comenity collect my personal information? We collect your personal information, for example, when you
  • open an account or provide account information
  • give us your income information
  • use your credit or show your driver's license
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.
What happens when I limit sharing for an account I hold jointly with someone else? Your choices will apply to everyone on your account.

Definitions
Affiliates Companies related by common ownership or control. They can be financial and nonfinancial companies.
  • Our affiliates include companies with a Comenity name; financial companies such as Comenity Capital Bank and Comenity Bank, other Comenity entities; nonfinancial companies such as Epsilon, Alliance Data, and LoyaltyOne.
Nonaffiliates Companies not related by common ownership or control. They can be financial and nonfinancial companies.
  • Nonaffiliates we share with can include financial service providers, retailers, direct marketers, publishers and nonprofit organizations.
Joint marketing A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
  • Our joint marketing partners include lenders and insurance companies.

Other important information
We also will comply with more restrictive state laws to the extent that they apply. For example, if your billing address is in Vermont or California, we will automatically opt you out of sharing your information with nonaffiliates for marketing purposes.

We will contact you regarding your account via text message or telephone, including the use of pre-recorded or auto-dialed calls on any cell, landline or text number you provide or use to contact us. Standard mobile, message, or data rates may apply.