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First Advantage Membership Services, Inc. Privacy Policy

Privacy Policy FAQ's

OUR OBJECTIVE
Your Personal Information is important to our business and vital in serving your needs. We are committed to the responsible collection, management, disclosure, safekeeping, and use of such information. This Privacy Policy guides us in achieving that commitment and applies to all of our members and other customers in the United States. In order to remind you of our commitment, we will send you a copy of our Privacy Policy at least annually following our initial notice.

PERSONAL INFORMATION COVERED BY POLICY
By "Personal Information," we mean information we possess about you that identifies you personally and is not otherwise available to the public. This information may include general information (such as your name, address, phone number, birth date and Social Security number), transaction information (such as your service usage and products purchased through us) and financial information (such as income).

COLLECTION OF PERSONAL INFORMATION
We may obtain your Personal Information from you or from third parties. We may collect such information from applications or other forms submitted by you, from your transactions with us, our affiliates or other parties, or from other sources.

OUR USE OF PERSONAL INFORMATION
We use Personal Information to help us serve our members and other customers and to conduct our business. We use such information to perform business functions, such as servicing our members and other customers, paying claims and benefit amounts, advising our members and other customers of our existing products and services, and developing new products and services.

SHARING OF PERSONAL INFORMATION WITH AFFILIATES
We may provide Personal Information relating to your transactions with us or our experience with you to our affiliates (including those existing currently or in the future). Beginning October 1, 2008, we will not share any Personal Information with our affiliates for purposes of marketing their products and services unless we are otherwise permitted to do so by law.

SHARING OF PERSONAL INFORMATION WITH UNAFFILIATED PARTIES
We may also share Personal Information with (x) unaffiliated third parties, including marketing partners, printers, billing agents, insurance companies, administrators and service providers, that assist us in performing our business functions and marketing our products, and as otherwise permitted or required by law, and (y) unaffiliated financial institutions under joint marketing agreements with us; in any such case, we will require such third parties to maintain the confidentiality of Personal Information disclosed to them.

We may also share Personal Information with certain other unaffiliated third parties, including non-financial service providers (such as retailers, airlines, and publishers), so that they may offer you products or services that we believe may be of interest to you. You have the opportunity to direct that your Personal Information not be disclosed to these third parties by completing and returning the form presented below.

MAINTAINING THE SECURITY OF YOUR INFORMATION
We have implemented security procedures which use reasonable measures to ensure the security, confidentiality, and integrity of Personal Information in our possession and guard against unauthorized access or use. We maintain physical, electronic, and procedural safeguards that comply with federal standards to safeguard Personal Information. We grant access to Personal Information only to those employees who need to use it in performing their job related duties and as otherwise set forth herein. Employees who violate our security procedures will be subject to disciplinary action, which may include termination.

TREATMENT OF INFORMATION OF FORMER MEMBERS AND CUSTOMERS
We will continue to follow our Privacy Policy for your Personal Information even when you are no longer a member or other customer of our business.

CHANGES TO OUR PRIVACY POLICY
This Privacy Policy supersedes all privacy policies and other similar standards previously issued by us. This Privacy Policy is subject to updates and other changes from time to time. In the event of any such changes, we will notify all of our members and other customers of such changes in the manner and to the extent required by law.

SPECIAL NOTICE FOR VERMONT RESIDENTS
If you are a resident of Vermont, we will not share your Personal Information with unaffiliated third parties except as permitted by law. We may share your name, contact information, and information about your transactions with us and our experience with you with unaffiliated financial institutions with which we have joint marketing agreements. We may also share your Personal Information with your consent.

METHODS FOR OPTING OUT OF SHARING PERSONAL INFORMATION
If you do not want us to share your Personal Information with unaffiliated third parties (other than those disclosures required or permitted by law), please check the box below and print your name and address in the space provided. Alternatively, you may make this request by e-mail by sending this information to: glbpolicy@trilegiant.com. If you have opted out previously, you do not need to opt out again. Also, your opt-out will apply to all membership services of Trilegiant Corporation in which you enroll using the same name and address that you use to opt out.

SPECIAL NOTICE FOR CALIFORNIA RESIDENTS
If you have a California mailing address, we will not share your Personal Information with unaffiliated third parties that are not financial institutions (other than as required or permitted by California or federal law). In addition, you may request that we not share your Personal Information with unaffiliated financial institutions with which we have joint marketing agreements, except as required or permitted by California or federal law. If you do not want us to share your Personal Information with such parties, please check the box below and enter your name, address, and member number in the space provided. Alternatively, you may make this request by e-mail by sending this information to: glbpolicy@trilegiant.com

If you have checked any of the boxes above, please print your name, address, and member number in the space below and send it to us at Trilegiant Corporation, P.O. Box 40383, Nashville,TN 37204-0383.We ask that you mail your request in a stamped envelope that does not include any other correspondence. Once your request has been received and processed, it will remain in effect until you request a change.

Please allow 30 days from our receipt of your request for processing. To ensure your request is processed, please make sure to include all information with your submission.