We believe that privacy is a cornerstone of our customer relationship. In operating our business, we strive to find methods to guard personal identity and information by promoting the use of fair information practices. We have created this privacy policy to demonstrate our firm commitment to privacy and to inform you of our practices concerning the collection and use of the information that you provide to us. We may amend this policy from time to time. If we make any substantial changes in the way we use your personal information, we will post an announcement on our web site.

Collection of Information
We may collect and use personal information to respond to requests for our services or to provide information about our services that may be of value. Certain personal information our company collects may be publicly available via government records, telephone books, or other widely available media however we treat all information provided as non-public. Our company collects personal information from a variety of sources, including:

1. Application Information (Information provided from loan applications and other forms such as names, addresses, telephone numbers, birthday, social security numbers, level of family income, employer's name, and employer's address);
2. Credit Reports (Information from consumer reporting agencies);
3. Correspondence (Information provided when communicating in writing, online or by phone with our customer service representatives); and
4. Marketing partners and publicly available databases (We receive information from our marketing partners, e.g., financial institutions, auto dealerships and other businesses and public databases which we use to help us serve our customers).

We use information that we obtain to evaluate auto loan applications, locate an appropriate auto dealer and/or lender for you, in order to provide high quality service, prevent fraud and, with the customer's consent, inform customers of offers of other company services offered by third parties. We may also use this information to confirm a customer's identity when they call us to inquire about their account.

Technical Information
Our company uses technology to:

• Gather technical information from Web browsers (IP address, operating system).
• Set cookies on your computer. "Cookies" are small computer files which are automatically placed on your computer's hard drive when you are connected to a website or remote server so that the website can recognize you upon your return to the website and tailor your experience based on your earlier use of the site.
  uses a cookie for each computer that visits its site. The cookie is integral to the customer experience and is necessary in order to use our online services. It allows our company to customize the website presentation based on your accounts. While cookies can be disabled, if you choose to disable our cookie you will not be able to use some of our websites. We do not use cookies to collect information from hard drives or to collect personal identifiable information; rather, it allows us to recognize you and know how you navigated through our site. It is also part of our effort to detect and stop fraud.
• Keep track of loan application statuses through the use of "Action tags" (also known as Web Beacons, Trackers, or Bugs), which are invisible pixel.gif files placed on web pages that are used to track web navigation to those pages.

Security Safeguard Procedures
Our company uses a variety of security safeguards to protect information from loss, misuse, alteration or destruction. For example, customers are only able to access information in their account by submitting their user name and password they created during registration. We provide access to personal information to our employees and other authorized parties on a "need to know" basis. In addition, we require that all employees attend a privacy training program and sign a Confidentiality Agreement that indicates that they are aware of our privacy policy regarding the use and disclosure of information.
We also use Secure Sockets Layer (SSL) technology supporting up to 128-bit encryption to prevent unauthorized parties from viewing any personal information transmitted to or from our company . We maintain up-to-date firewalls and use anti-virus software that updates automatically.

Sharing of Information with Third Parties
We may disclose personal information to the following types of third parties: Our partners (auto dealerships that meet customer's criteria and financial institutions), Credit Bureaus and Service Companies (companies that provide services to our company in order to process auto loan applications). Personal information is disclosed to the foregoing entities solely for the purpose of locating a vehicle that meet the customer's criteria and to obtain credit for the purchase of such vehicle. Outlined below is the information we share with each type of third party.
Our company offers its services in conjunction with auto dealerships, financial institutions and other businesses (collectively, our company Partners). When a customer completes a credit application with our company for the purpose of locating a vehicle that meets their criteria and obtains credit for the purchase of such vehicle, the customer may agree to the sharing of information with that partner. The customer agrees that our company and/or its auto dealers or lending partners may forward their application to other auto dealers or lenders for consideration. The customer authorizes any auto dealer or lender who receives their application to retain it, to rely on it and to obtain such other information as require, including credit reports, to complete the processing of their request for credit. The customer further authorizes that any auto dealer or lender who receives this application to inform our company and its lending partners of their credit decision. These relationships are clearly stated in the application and by completing the application the customer agrees to permit our company to share their information, which may include the applicant's name, address, phone number, e-mail address, and other personal financial information with our partners. In addition, since we do not service auto loan applications, we will sell loan applications to auto dealerships. The customer will be notified of the auto dealership that will be servicing their auto loan application.

• Credit Reporting Agencies - Companies involved in the loan process are a necessary part of the auto loan process. When a customer applies for credit, he/she agrees that we may request consumer credit reports from one or more credit reporting agencies in connection with their application and administration of the application. The customer may also authorize us to exchange credit information concerning their account with (and answer questions and requests from) others, such as merchants, other lenders and credit reporting agencies.
• Service Companies -- In order to provide quality service, our company contracts with service providers for the essential role of processing loan applications. We may disclose some or all of the information we collect to these service providers but only in order to obtain credit for the customer. All of our company service providers have entered into a contract with our company that forbids them from using information provided by our company for any purpose other than providing the service for our companies customers. These service companies are required by law to adhere to federal and state privacy regulations. Our company takes security precautions to monitor the use of the information and prevent the use of the information for any other purpose. When we contract with organizations to provide services to our customers, we will require them to conform to our privacy standards and to allow us to audit them for compliance.
• Merchants -- Our company does not share any information with external merchants for the purpose of extending offers of goods and services without the customer's consent. Our company does NOT use third party advertising companies to provide advertisements or allow third party advertisers to track web browsing activities on its web sites.
• In addition, our company does not knowingly offer its services to minors. Similarly, our company does not collect information from children. Our application approval process is designed to identify applications submitted by children and to prevent their use of our websites.

Exercising the Right to Opt-Out of Information Sharing
Our company provides its customers with the opportunity to opt-out of information sharing with affiliates and partners. A customer must make their opt-out decision before completing the auto loan application process. Customers can opt-out by clicking on the link at the bottom of the auto loan application screen.

Storing of Information
We maintain electronic loan application information and hard copy data. We also protect all personal information by storing the information on tapes at an off site facility in our Data Warehouse. The Data Warehouse is disconnected from the production environment and the information is used internally for reporting purposes.

Privacy Related Issues
Our company is committed to customer service and privacy. If you have any questions, comments or concerns regarding our Privacy Policy and its implementation, or you would like to report any known or suspected privacy or security breaches, please do not hesitate to contact our Security Compliance Officer at EMAIL