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

1. Acquisition of Information. We do not acquire more information about consumers than is required by law or is otherwise necessary to provide a high level of service in an efficient and secure manner.
2. Our Employees and Privacy. We train all employees on the importance of privacy. Access to consumer information is limited to those employees who require it to perform their job responsibilities.
3. Security Measures. Access to privacy-sensitive information is subject to rigorous procedural and technological controls, consistent with legal requirements and the needs of customer service.
4. Disclosure to Third Parties. We will provide individually identifiable consumer information to third parties only when we are required to do so by a duly authorized governmental authority, when we have the consumer’s express permission, or when 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 share only the consumer information necessary for those purposes and will make reasonable efforts, by contract or otherwise, to ensure that such partners use the information in a manner consistent with this Privacy Policy.

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