INTRODUCTION

CarePlus Financial has adopted the following Privacy Policy, which we are posting on our Web site to help you understand how we handle the nonpublic personal information that we collect from you and may disclose to others. The provisions of this Policy apply only to those clients who have enrolled in CarePlus Financial’s programs, and apply only to information provided to us in connection with participation in those programs.

WHAT IS “NONPUBLIC PERSONAL INFORMATION”?

“Nonpublic personal information” is personally identifiable financial information (a) provided by a consumer to a financial institution; (b) resulting from any transaction with the consumer or any service performed for the consumer; or (c) otherwise obtained by the financial institution, except information obtained wholly through public sources.

WE COLLECT YOUR NONPUBLIC PERSONAL INFORMATION FROM SEVERAL SOURCES

We collect nonpublic personal information about you from the following sources:

• Applications or other forms taken over the phone or that you complete and send to us.
• Communications with creditors, which you have authorized us to initiate or receive;
• Consumer reporting agencies, such as your credit bureau reports, that furnish us with information relating to your creditworthiness; and
• Communications that we receive directly from you, such as telephone conversations, e-mails, faxes, letters, etc.

WE WILL SHARE YOUR NONPUBLIC PERSONAL INFORMATION WITH YOUR CREDITORS

We will share nonpublic personal information that you have provided to us with the creditors whom you have authorized us to negotiate with. Under the Gramm-Leach-Bliley Act, we need not give you the opportunity to “opt out” of sharing that information if you have given us permission to do so. In addition, we need to share your information with your creditors in order to administer your account and effect settlements on your behalf. We do not disclose your nonpublic personal information with any other third parties, except to the extent permitted or required by law, and/or as described below.

TYPES OF INFORMATION WE MAY DISCLOSE

The information we will share with your creditors includes:

• Information we receive from you on applications or other forms, such as your name, address, phone number, social security number, e-mail address, assets, debts, and income.
• Information we receive directly from you via telephone conversations, e-mails, faxes, letters, etc.
• Information about your transactions with us, our affiliates, or others such as your account balances, payment history, parties to transactions, and credit card usage.
• Information we receive from a consumer reporting agency, such as your credit bureau reports and other information relating to your creditworthines

IN ADDITION TO SHARING YOUR INFORMATION WITH CREDITORS, WE MAY SHARE YOUR INFORMATION WITH CERTAIN NON-AFFILIATED THIRD PARTIES

The Gramm-Leach-Bliley Act permits us to share your nonpublic personal information with certain nonaffiliated third parties without permitting you to “opt-out.” Those parties include service providers and joint marketers, which include companies that perform marketing services on our behalf, and auditors, examiners, or companies contracted to conduct auditing services for us. The information we would share with these third parties includes:

• Information we receive from you on applications or other forms, such as your name, address, phone number, social security number, e-mail address, assets, debts, and income.
• Information we receive directly from you via telephone conversations, e-mails, faxes, letters, etc.
• Information about your transactions with us, our affiliates, or others such as your account balances, payment history, parties to transactions, and credit card usage.
• Information we receive from a consumer reporting agency, such as your credit bureau reports and other information relating to your creditworthiness; and

Our agreements with these third parties would require the third parties to protect the confidentiality of your information.

Further, we may provide your information to government authorities when required or permitted to by law or regulation. We may disclose information as necessary to comply with a subpoena or court order, or to protect our rights, or for any other reason permitted by law. We may make all of the foregoing types of disclosures about former clients as well as current clients.

WE DO NOT SHARE YOUR INFORMATION WITH OTHER NONAFFILIATED THIRD PARTIES

We do not, at this time, share our clients’ information with nonaffiliated third parties not included above.

WE MAY SHARE YOUR INFORMATION WITH OUR AFFILIATES

We may disclose some or all of your nonpublic personal information to our affiliates, which are companies sharing common ownership with CarePlus Financial, Inc.

OUR PRIVACY POLICY MAY CHANGE IN THE FUTURE

Our Privacy Policy may change in the future. For example, we may decide at some point to share our clients’ information with nonaffiliated third parties not mentioned in Section 6. Such parties might include independent marketers, retailers, or financial institutions. You may opt out of sharing your information with those third parties. If we decide to share information with those parties, we will notify our former and current clients of that change via the address we have in your personal file. You will have thirty days from the mailing of such notice to opt out of any new disclosures we propose to make. We will give you a reasonable method for opting out, such as calling a toll-free number, or informing us via e-mail. We will also post the change on our Web site.

SECURITY OF OUR PRIVACY PROCEDURES

We restrict access to nonpublic personal information about you to those employees who need to know that information in order to provide products or services to you. We have implemented physical, electronic, and procedural safeguards to maintain the confidentiality and integrity of the personal information in our possession and to guard against unauthorized access. These include processes for controlling access to customer files, implementing security programs, and information technology security measures such as encryption and firewalls, and virus and use detection software.

WHAT ABOUT INTERNET PROTOCOL (IP) ADDRESSES AND COOKIES?

CarePlus Financial logs IP addresses and browser types, but we do not link IP addresses to personally identifiable information. This means that, although a client’s session is tracked, the identity of that client remains anonymous. We also use these IP addresses to analyze trends, administer the site, and gather broad demographic information for aggregate use.

Cookies are used for the same reasons. Cookies are small pieces of information stored on your computer’s hard drive. Cookies enable us to monitor the number of people who visit our site, how many people return to our site for another visit, and which pages are viewed. By better understanding how you and others are using CarePlus Financial’s site, we can develop tools and customize content to personalize and improve everyone’s experience. We also use cookies to remember your password for you so that you don’t have to keep re-entering it each time you come back to the site. Your privacy and security are not compromised when you accept a cookie from CarePlus Financial because we do not use cookies to collect personal information.

Of course, you can choose not to accept the cookies by adjusting your browser settings but, if you choose to do so, you may not be able to take full advantage of our sites.