We collect only customer information that is
needed, and we tell customers how we use it.
limit the collection of information about our customers to what we
need to know to administer their accounts, to provide customer
services, to offer new products and services, and to fulfill any
legal and regulatory requirements. We tell our customers about the
general uses of information we collect about them, and we will
provide additional explanation if customers request it.
We give customers choices about how their data
will be used. On
a regular basis, we give our customers the option to decide
whether or not they wish to have their names added or removed from
lists used for mail, telephone and online marketing. These opt-in
and opt-out choices include product and service offers from
SpinTrue and those made in conjunction with our business partners.
We ensure information quality.
use advanced technology and well-defined employee practices to
help ensure that customer data is processed promptly, accurately
and completely. We require high standards of quality from the
consumer reporting agencies and others who provide us with
information about prospective customers.
We use information security safeguards.
to customer data is limited to those who specifically need it to
conduct their business responsibilities. We use security
techniques designed to protect our customer data -- especially
when certain data is used by employees and business partners to
fulfill customer services.
We limit the release of customer information.
addition to providing customers with the opportunity to op- out of
marketing offers, we release information only with the customers'
consent or request, or when required to do so by law or other
regulatory authority. When a court order or subpoena requires us
to release information, we notify the customer promptly to give
the customer an opportunity to exercise his or her legal rights.
The only exceptions to this policy are when we are prohibited by
court order or law from notifying the customer, or cases in which
fraud and/or criminal activity is suspected.
We are responsive to customers' requests for
we deny an application for our services or end a customer's
relationship with us, to the extent permitted by applicable laws,
we provide an explanation, if requested. We state the reasons for
the action taken and the information upon which the decision was
based, unless the issue involves potential criminal activity.
We extend these privacy principles to our
We expect the companies we select as our business
partners to honor our privacy principles in the handling of
customer information. These include companies that (a) assist us
in providing services to our customers; (b) supply us with
information for identifying or evaluating prospective customers;
or (c) are given the opportunity to send mailings to approved
SpinTrue customer lists. In selecting business partners, SpinTrue
considers the accuracy and quality of the data they provide, how
they respond to consumer complaints and whether or not they
provide opt-out choices for those whose information they process.
We also participate actively in industry associations to support
strong and effective privacy guidelines and practices.
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