Consumer Privacy Policy

LAST UPDATED ON JANUARY 14, 2015

This privacy policy covers personal information about customers who obtain consumer products from Commercial Leasing & Financing Bank of Cardiff, Inc. (CFLBC) for personal, family, or household purposes. This policy is provided to you as required by federal law. Although this notice does not apply to business and commercial accounts, safeguarding our business and commercial customers' information is very important and we take steps to protect such information. This privacy notice does not apply to any credit card account relationship you may have with us. If you have a consumer credit card account relationship with us, you will receive a separate notice applicable to that account. Except as described below or as permitted by law, we do not disclose personal information about our customers or former customers.

OPT-OUT

There is no need to opt-out of information sharing as a result of receiving this privacy policy. Because we have limited the circumstances in which your personal information can be disclosed, there is no further action you need to take.

COLLECTING PERSONAL INFORMATION

We collect personal information about you from the following sources:


Information You Provide to Us: Personal information that you provide to us on applications and through other correspondence, such as your name, address, social security number and personal financial statements.


Transactions and Experiences: Personal information about your Transactions and Experiences with us and our affiliates, such as your account balance, payment history and debit card usage.


Information We Receive from Third Parties: Personal information that non-affiliated third parties provide to us about you, such as credit report information, information about your accounts with third parties, and data from public records.

DISCLOSURE TO AFFILIATES

We may disclose personal information about your Transactions and Experiences with us to our affiliates. For example, if you apply for a loan or a credit card at an affiliated bank or loan company we may disclose your account balance and your payment history to them to aid in the credit approval process.

DISCLOSURE TO NON-AFFILIATES AND THIRD PARTIES

We may disclose personal information about you to non-affiliated third parties as permitted by law. This may include all of the personal information we collect about you. For example, we may disclose information to payment processors, other financial institutions, and appraisal companies to complete transactions that you request.


Additionally, personal information may be disclosed in connection with a subpoena or similar legal requirement, in connection with audits, to process a transaction you requested, and to prevent fraud or unauthorized use.


We may disclose all of the personal information we collect, as described above, to companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements. These nonaffiliated third parties are responsible for treating your personal information as confidential.

SECURITY

We maintain physical, electronic, and procedural safeguards to protect your personal information. Our employees are authorized to use personal information only for business purposes and are subject to a Code of Ethics that requires them to treat personal information as confidential.

BUSINESS PRIVACY POLICY

CFLBC is dedicated to providing your business with quality products and services. As a part of that mission, we recognize that your business information is important. We take steps to protect the business information we collect in connection with providing you business products and services. This privacy policy explains the steps we take to protect your business information, it does not apply to any consumer accounts you may have with us.

INFORMATION WE COLLECT

We may collect information about your business in connection with offering or providing a business product or service to you.

UPDATE OR CORRECT COLLECTED INFORMATION

You may update or correct any information collected by CFLBC at any time by contacting us in writing at P.O. Box 2562, Del Mar, CA 92014-2562.

INFORMATION WE MAY SHARE

We know it is important to protect your business information in today's competitive market. We may share business information when we believe it is necessary or appropriate to do so in order to offer you a product or service, to effect, administer or enforce a transaction you request or to service the accounts, products and services that we make available to you. We may also share information if you have authorized or requested us to do so, if we are legally required or permitted to disclose the information, or if we otherwise determine the disclosures to be appropriate (for example, disclosures to attorneys, accountants, auditors, affiliates, rating agencies, credit bureaus, service providers, loan participants, and others, and disclosures that are necessary or appropriate for security, fraud protection, risk mitigation and other lawful purposes).

SECURITY

We maintain physical, electronic, and procedural safeguards to protect your business information. Our employees are authorized to use business information only for business purposes and are subject to a Code of Ethics that requires them to treat business information as confidential.

CHANGES TO OUR PRIVACY POLICY

If CFLBC changes this policy in the future, we will post the changes here and indicate the date of the changes at the top of the policy.

PROBLEMS OR COMPLAINTS WITH OUR PRIVACY POLICY

If you have a complaint about CFLBC compliance with this privacy policy, you may contact us in writing at P.O. Box 2562, Del Mar, CA 92014-2562.