A Guide to How We Use
and Protect Customer Information
Our Pledge To You
We value the trust you have placed in us . . .and we intend to continue to earn your trust each day. That's why we welcome this opportunity to describe our privacy policies and the steps we take to protect your customer information. In this brochure, you’ll find details about these policies and procedures, as well as the opportunity to choose how your customer information may be shared. You'll also receive updates in the future, so you can continue to stay informed about this important issue.
In this brochure, 'we', 'our' and 'us' refers to your lender. Refer to the Creditor section of your Truth-in-Lending disclosure to determine your lender.
The practices and policies contained in this disclosure are subject to change, but we will communicate any material changes to you when required by applicable laws. The practices and policies contained in this disclosure replace all previous notices or statements with respect to the same subject matter.
This Is Our Pledge To You.
We are committed to protecting your privacy at all times.
We do not share customer information with outside companies for purposes of selling their products and services to you, unless you have been given the opportunity in advance to decline this option.
We do not share medical information provided as part of insurance applications or claims, except for the purposes you have authorized.
We are committed to bringing you the services you need to succeed financially. If we do not offer a financial service, such as some insurance products, we may establish a joint marketing program with an outside company to offer that service to you. These programs include confidentiality agreements to protect customer information.
We maintain security standards and procedures designed to protect customer information. We will continue to test and update our technology to improve the protection of our information about you.
Behind this pledge is a simple idea. We want you to know that you can count on us – to protect the privacy and security of your customer information, and to provide you with the responsive, professional service you deserve.
Our Policies Regarding The Collection, Use and Disclosure of Customer Information
Our goal is to provide you with all the services you will need to succeed financially. Along the way, we are committed to providing you with responsive, personalized service, and keeping you informed about new services that may be of i mmediate interest to you, or new benefits that can help you derive the greatest value from your relationship with us. Customer information is at the heart of our ability to provide superior service to you. In the sections that follow, we describe the types of information that are collected, and how and why that information may be shared with others.
Please refer to the Glossary for the definitions of some important terms we use throughout this brochure.
The primary reason that we collect and maintain customer information is to serve you and administer your customer relationship. This information may be collected from a variety of sources, such as the following:
Information you provide to us on applications or forms, like your income and accounts;
Information we receive from an outside company, such as a credit bureau, providing your credit history or employment verification; or
Information about your transactions or experiences with companies affiliated with us.
Information Use and Disclosure With Affiliated Companies.
We use and share customer information with our affiliated companies for a variety of reasons, including the following:
To protect you. The information we maintain about your customer relationship helps us identify you and helps prevent unauthorized persons from accessing your information, or your accounts or services.
To provide superior service. Your customer information allows us to respond quickly and efficiently to your needs – from obtaining cash through ATMs, to fast approval of your loan application.
To tell you about new or enhanced financial services. By understanding your relationship, we can better meet your needs and determine your eligibility for other services that could be of value to you. For example, if we know that you own your own home, we might offer you a home equity loan rather than an i nstallment loan because of the potential tax benefits.
To improve and develop our products and services. Every product or service we offer is designed to reflect the ways our customers actually use their accounts. This is the reason why we collect and analyze information about customer activity and history, and how we tailor new types of loans, checking, and other accounts to meet your needs. We may share the customer information we collect (described in the Information Collection section) with:
Affiliated companies providing financial and other services, such as consumer bankers, mortgage lenders, consumer lenders, securities broker-dealers, insurance agencies, and real estate brokerage companies; and
Administrative and service units that perform functions such as servicing your accounts or preparing your account statements.
In addition, information about trust accounts (where an affiliated bank or company is acting as a trustee or fiduciary) is subject to special protection – even within our affiliated family of banks and companies. This information is considered extremely confidential and is not shared for marketing or solicitation purposes without your specific consent.
With Outside Companies or Parties.
When it comes to sharing information with outside companies or parties, we do so only for specific purposes. We may disclose customer information to the following types of outside companies or parties:
Financial service providers such as insurance companies or institutions that extend credit under a joint program with us, and which typically offer financial services that are different than t hose we provide to you. You may choose to opt out of this type of sharing by replying as instructed in this brochure;
Non-financial companies, including companies that perform services on our behalf, such as check printers, companies that prepare account statements, or companies that help us market our own products to you; and
Independent contractors, such as technical system consultants who program our software to help us administer our products or market our own products to you.
We do not share customer information with outside companies for the purpose of marketing non-financial products or services of those companies, unless you have been given the opportunity in advance to decline this option.
Some state laws impose separate requirements before we can disclose particular types of information about customers in those states to outside parties for certain marketing programs or other purposes.
Information Disclosed to Outside Financial Service Providers.
As we stated in our Pledge to you, we do not share information with outside companies for the purpose of selling their products and services to you without giving you the opportunity in advance to decline this option (that is, to “opt out” of this type of sharing). As permitted by law, we arrange programs with outside financial service providers to offer you the benefits of “one-stop shopping” or other conveniences. In these cases, unless you exercise your choice to opt out of this type of sharing, we sometimes disclose the following categories of limited customer information with outside financial institutions with which we have joint marketing agreements:
Information we receive from you on applications or forms, which may include information such as your name, address, and social security number;
Information about your transactions or experiences with affiliated banks and companies, which may include information such as your account balance, payment history, parties to transactions, and credit card usage.
We disclose information only when we believe that this information is important for the offer, or necessary to provide you with a premium or rate quote. Our joint agreements with these companies are subject to confidentiality provisions and restrictions on using the information for any other purpose.
Information Disclosed to Outside Non-financial Companiesand Independent Contractors
When outside parties perform services on our behalf, in some instances we may disclose some or all of the information that we collect, as described in the Information Collection section. This information may be provided to certain non-financial companies and independent contractors for the purposes of servicing your account or to perform marketing or similar services on our behalf with respect to products or services we provide. These companies and contractors are subject to confidentiality provisions and restrictions that prohibit using the information beyond the performance of the specified services on our behalf. We also disclose certain customer information to government agencies, consumer reporting agencies, and other outside parties as permitted or required by the Federal Privacy Act and other applicable laws. These disclosures are made for specific, limited purposes, such as to verify individuals’ identities (reducing fraud and identity theft), to meet customer service expectations (connecting to national ATM networks for ATM card access), to verify information for prompt credit approvals (meeting customers’ immediate financial needs), or to make certain information a matter of public record (recording mortgages to let prospective buyers, title insurers, and others know about property liens).
Our Policies Regarding the Collection, Use andDisclosure of Information about Former Customers
Our policies and practices regarding the collection and disclosure of information about former customers are the same as those regarding the collection and disclosure about existing customers (see the section titled Our Policies Regarding the Collection, Use and Disclosure of Customer Information ) for a period of time after a customer relationship ends. Our information about former customers, however, is used less and less over time after the relationship ends and eventually is removed from our records.
Information Confidentiality and Security
Information Confidentiality and Protection Practices.
As we described in our Pledge to you, we are committed to preventing others from unauthorized access to your customer information, and we maintain procedures and technology designed for this purpose. We take several steps to protect the customer information we have about you, including the following:
We update and test our technology on a regular basis in order to improve the protection of customer information.
We require outside companies and independent contractors to whom we provide customer information for marketing, servicing or processing purposes to enter into a confidentiality agreement that restricts the use of the information to those purposes and prohibits independent use of the information.
We have internal procedures that limit access to customer information, such as procedures that require an employee to have a business need to access customer information. We maintain policies about the proper physical security of workplaces and records. Our physical, electronic, and procedural safeguards comply with federal regulations regarding the protection of customer information.
Information Integrity Measures
We work hard to ensure that the customer information we maintain is complete and accurate. We have procedures and processes for updating our customer information as well as removing old information. We protect the integrity of customer information about you through measures such as maintaining backup copies of account data in the event of power outages or other business interruptions, using computer virus detection and eradication software on systems containing customer data, installing computer hardware and software, and employing other technical means (known as “firewalls”) to protect against unauthorized computer entry into systems containing customer information.
1. “We,” “us” and “our” means your lender as disclosed in the Creditor section of your Truth-in-Lending statement.
2. “Federal Privacy Act” means the privacy provisions in Title V of the Gramm-Leach-Bliley Act and also includes the applicable federal privacy regulations issued under that Act.
3. “Customer Information” means our personally identifiable financial information about a consumer that is considered “nonpublic personal information” within the meaning of the Federal Privacy Act.
4. “Affiliated Companies” means the financial institutions, companies, and other entities that are considered our affiliates within the meaning of the Federal Privacy Act.
5. “Outside Parties” or “Outside Companies” means third parties that are not affiliated companies, except for joint employees and others who are defined as nonaffiliated third parties under the Federal Privacy Act.
6. “Financial Products and Services” means those products and services defined as a financial product or service under the Federal Privacy Act and applicable regulations and i nterpretations issued under that Act.
7. “Consumer” means an individual who obtains or has obtained a financial product or service from us that is to be used primarily for personal, family, or household purposes (or that individual’s legal representative) within the meaning of the Federal Privacy Act.
Customer Choices Regarding Information Sharing
As described in this brochure, we are committed to protecting customer information, and to using or sharing it in ways that will improve or expand upon the services we provide to you. We also want you to know that – as our customer – you have choices about how your customer information may be shared.
Please be assured that you may exercise these choices at any time. In addition, if you have opted out of information sharing previously, it is not necessary to do so again.
With Outside Companies (Option 1)
As described earlier, we may share limited customer information under special agreements with outside financial service providers in order to offer you financial products that we typically do not offer ourselves. Some of this information helps to ensure that you will receive those communications that are most likely to match your needs or situation. If you prefer that we not share this information about you with these outside financial service providers for these purposes, you may choose to opt out. This means that you may direct us at any time not to disclose this information to these outside providers for marketing purposes. If you wish to opt out of this type of sharing, simply notify us as described and your request will be honored.
With Our Affiliated Companies (Option 2)
As we have described, we share some information about you with our Affiliated Companies to determine your eligibility for products and services to be offered to you. This helps us meet your financial needs and offer the right products and services to you. If you prefer that we don’t share your personal and credit-related information with our affiliated banks and companies for these purposes, you may choose to opt out. You may direct us not to disclose this information to other affiliated financial institutions to determine your eligibility for their products and services. If you wish to opt out of this type of sharing, simply notify us as described in this brochure at any time and we will honor your request by not sharing your information with our affiliated banks and companies. In accordance with the Fair Credit Reporting Act, whether or not you have opted out, we may share identifying information and information about your transactions and experiences with affiliated banks and companies.
Additional Information About These Choices
We are committed to meeting your financial needs. We want you to know that, regardless of any opt out choice you make, there may be occasions when we will ask you if you wish your information to be shared. For example, if we are unable to offer you a particular product that you applied for, we may offer you the opportunity to have us forward your application and related information to another financial institution for a similar product.
How To Notify Us
If you decide to opt out, please indicate your choice(s) as described and write in your name, address, and Social Security Number or individual Tax Identification Number. Then detach this response form and mail it to us at the following address:
Operations Center, P.O. Box 5277, Sioux Falls, SD 57117-5277.
You may also call us at 1-888-528-8460.
Account holder A
State __________________________Zip ___________________
Social Security Number/
Tax Identification Number ______________________________
(Required to Process)
Account holder B
State __________________________Zip ___________________
Social Security Number/
Tax Identification Number ______________________________
(Required to Process)
If you have a joint account, each account holder may select either or both options by checking the box(es) below. Any account holder can opt out on behalf of the other joint account holders. If you previously have communicated an opt out choice to us, you do not have to provide it again.
? ? Option 1: Please do not share information with
outside companies for marketing purposes as
described in this brochure. I understand that I will
not receive information, available through special
agreements with outside companies about finanical
services that are not available through my lender.
? ? Option 2: Please do not share information with affiliated
companies, as described in this brochure.
I understand that I won’t receive information about
new services or special offers for which I may be eligible.
Tips to Help You Protect Your Customer Information
Assistance to Victims of Identity Theft
If you suspect that someone has had unauthorized access to your account with us, or access to your personal identifying information s uch as your Social Security number or credit card information, please notify your service representative immediately so we can take action t o protect you. In addition, you should also report the crime to your local law enforcement agency and to the Federal Trade Commission (FTC). To speak with a trained FTC telephone counselor, call toll-free at 1-877-IDTHEFT (1-877-438-4338). Or to enter information about your complaint into a secure FTC online database, sign onto http://www.consumer.gov/idtheft . The site also provides links to numerous consumer education materials.
Ways to Limit Direct Marketing
You May Receive From Outside Sources
Please be assured that we will honor your opt out choice as described above. However, there are outside agencies and companies, including national consumer credit reporting agencies, which are in the business of compiling mailing lists for purchase by marketers. You may wish to have your name removed from many of these lists by following the procedures outlined below:
Direct Marketing Association and Member Companies
To remove your name from direct mail or telemarketing lists of members of the Direct Marketing Association, send a written request with your name, address, and Social Security number (if it was included in the mailing you received) to the Direct Marketing Association. The Direct Marketing Association is responsible for notifying its members (i.e., the agencies and companies that compile mailing lists) that you want your name removed from the lists they sell. Your name and address remains in their consumer exclusion files for five years.
You must register your own name and address with these organizations because they cannot process any requests from us. Be sure to include any variations of your name, address and other information that have appeared in mailings or telephone calls that you have received.
Mail Preference Service Assoc. c/o Direct Marketing Association
P.O. Box 9008 Farmingdale, NY 11735-9008
Telephone Preference Service c/o Direct Marketing Association
P.O. Box 9014 Farmingdale, NY 11735-9014
National Consumer Credit Reporting Agencies (Credit Bureaus)
In addition to sharing information with member companies for credit verification and fraud control purposes, national consumer credit reporting agencies may also sell or share your name and certain other information to various outside companies for marketing purposes. You may direct these agencies not to sell or share this information about you for marketing purposes – but your financial institution may not make that request on your behalf. If you wish to direct these agencies not to sell or share this information about you for these marketing purposes, call their toll-free telephone number at 1-800-353-0809 to communicate your request.
© 2000 Wells Fargo & Co. All rights reserved.