We are highly sensitive to the privacy interests of our members and believe that the protection of those interests is one of our most significant responsibilities. In acknowledgment of our obligations, we have adopted the following Privacy Policy applicable to information about our members that it acquires in the course of our business:

1. Acquisition of Information. We do not acquire any more information about our members than is required by law or is otherwise necessary to provide a high level of service efficiently and securely.

2. Our Employees and Privacy. We train all of our employees about the importance of privacy. We give access to information about our members only to those employees who require it to perform their jobs.

3. Security Measures. We make access to privacy-sensitive information subject to rigorous procedural and technological controls, consistent with legal requirements and the demands of customer service.

4. Disclosure to Third Parties. We will provide individually-identifiable information about our members to third parties only if we are compelled to do so by order of a duly-empowered governmental authority, we have the express permission of you, the member, or it is necessary to process transactions and provide our services.

5. Privacy and Our Business Partners. When we make our technology or services available to business partners, we will not share with them any more consumer information than is necessary, and we will make every reasonable effort to assure, by contract or otherwise, that they use our technology and services in a manner that is consistent with this Privacy Policy.