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HEALTH CREDIT SERVICES, LLC (HCS) PRIVACY POLICY



At HCS protecting our customer's private information is of great importance to us. We recognize that in using our services you provide us with important identification and financial information about yourself and are entitled to security in providing that information to us. The following summary explains our practices in regards to the protection of your private information.

We collect information about you in the following ways :

  • From you when you create a HCS profile or apply for a loan.
  • From you any time you update your profile information.
  • From outside sources such as credit bureaus necessary in facilitating the services you request from HCS.

We share your information on a limited "as necessary" basis :

  • Only with third parties involved in the process of providing services you request, such as credit agencies, collection agencies, and companies that facilitate payments of your loans, such as ACH providers.
  • Without using any of your personal identification information, we will use information you have provided us to prepare aggregate reports of HCS's users.
  • As permitted or required by law.
  • HCS will never sell or rent your information to third parties for marketing purposes.

We protect your information :

  • Using state of the art encryption technology to protect your personal information that you submit to HCS.
  • By limiting third party access to your personal information to only those instances when necessary to provide you with a loan (for example, credit bureaus), or in preparing the aggregate reports that will never include your personal identification information.

The following is a more detailed explanation of HCS's privacy policies.

We collect information about you:

HCS collects personal information as part of the loan application process. This information includes identification information, such as your name, contact information, and social security number. This information also includes financial information relevant to your loan application.

As a HCS loan applicant or financial literacy user, you will set up a personal profile that can be accessed with a user name and password you select. Your personal information will not be provided to any other individuals other than the following limited circumstances:

1. We will use your name, Social Security number, and other identification information to request a credit report. We use information from your credit bureau file to verify your identity, protect against fraud, and to determine your credit history in evaluating your loan application.

2. We use your information to review your loan application and contact you or appropriate third parties to facilitate the loan. This may include:

  • Obtaining credit information in order to evaluate your application;
  • Communicating with financial service companies to facilitate automatic payments or other services related to your loan application;
  • Contacting you if we have trouble processing a transaction, to discuss a problem with your account, or to maintain regular communication with you concerning transactions you initiate, such as requesting information or assistance, submitting a loan request, making payments, transferring funds, etc.
  • Implementing collection activities if needed.

We share your information on a very limited "as necessary" basis:

HCS has relationships with other trusted third parties that perform services on our behalf. We share information with these service providers in order to complete the transactions that you request and to communicate effectively with you. All service providers are bound by contract to maintain the confidentiality of your personal information.

We may share your information with law enforcement or other government agencies as required by law.

HCS will never sell or rent your personal information to third parties for marketing purposes.

HCS reserves the right to disclose information that does not directly identify you, for example, aggregated or anonymized data, for educational, informational or promotional purposes. HCS may also collect information about your computer and your visits to the Company's websites, such as your IP address, geographical location, browser type, referral source, length of visit, and page views through the use of log files. HCS may use this aggregated information for the administration of our web site to improve its usability and/or to evaluate the success of HCS's product and marketing. HCS will only use non-identifying and aggregated information for these purposes.

You will have the ability to view the loan agreements and other documentation regarding your use of HCS's services. You can also use this account to view or modify any personal information provided to HCS.

From time to time you will receive disclosures, notices, documents and information based on your account information, status or activity from HCS (for example, confirmations of loans you have made, communications regarding status or payment of your loans, or inquiries regarding the status of or activity in your account). By creating an account with HCS, you agree that all communications from HCS relating to your use of HCS's services may be provided or made available to you electronically by e-mail or through the mail. By creating a HCS profile, you acknowledge that you can access all electronic communications from HCS and you consent to having all communications provided or made available to you in electronic form. You cannot opt out of receiving messages needed to carry out transactions you request or to maintain your account, such as those regarding fund transfer activity with your accounts, notifications regarding upcoming payments, certain changes to legal agreements, and required loan and privacy disclosures. If you cannot receive electronic communications from HCS, you cannot participate in HCSs services.

The information we collect from you when you apply for HCS's services is kept securely in our database. We retain this information to satisfy legal requirements such as recordkeeping and tax and credit reporting requirements, as well as for purposes of fraud prevention, audit and data integrity.

We protect your information

At HCS we maintain safeguards that are put in place to satisfy all legal requirements for a financial company that retains its client's personal and financial information.

We protect your personal account information by storing it in encrypted form. We control access to this information via secure web pages, and limit access to your information to only those companies or individuals who need the information to facilitate the services you request from HCS.

Firewalls and other security technologies protect our servers from external attack. We enable our servers with Secure Socket Layer (SSL) technology to establish a secure connection between your computer and our servers.

More than anything else, the security of your account depends on the protection of your HCS login information. You should not share this information with anyone. As part of the HCS Terms and Conditions, you have agreed not to share your user information with anyone.

HCS reserves the right to retain your personal information for a period of seven years or more to satisfy legal requirements such as recordkeeping and tax and credit reporting requirements, as well as for purposes of fraud prevention, audit and data integrity. In addition, HCS reserves the right to retain, as well as to use and disclose as permitted pursuant to this Privacy Policy, your personal information for such period of time as reasonably needed by HCS to facilitate activities and transactions related to your transactions with HCS. HCS also reserves the right to retain information that does not directly identify you, for example, aggregated or anonymized data.

Other Aspects of Our Privacy Policy:

HCS may post links to third party web sites that are not subject to our privacy policy. If you visit these web sites, we encourage you to read their privacy policies before providing them with any personal information.

You may have privacy rights under applicable state law in addition to those outlined in our privacy policy.

We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served HCS.

To accommodate changes to our web site, changing technology, and possible legal requirements, HCS may change its privacy policy at any time. We will promptly post any policy changes to this page and notify you directly with notice of any material changes.

Our loans are originated by Cross River Bank, which has its own Privacy Policy summarized below:

FACTS

WHAT DOES CROSS RIVER BANK DO WITH YOUR PERSONAL INFORMATION? Rev. 11/2015

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:
- Social Security number and Account balances
- Payment history and Transaction history
- Account transactions and Wire transfer instructions

How?

All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons Cross River Bank chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information

Does Cross River Bank share?

Can you limit this sharing?

For our everyday business purposes--
such as to process your transactions, maintain your account(s), respond
to court orders and legal investigations, or report to credit bureaus

Yes

No

For our marketing purposes--
to offer our products and services to you

No

We don't share

For joint marketing with other financial companies

Yes

No

For our affiliates' everyday business purposes--
information about your transactions and experiences

No

We don't share

For our affiliates' everyday business purposes--
information about your creditworthiness

No

We don't share

For nonaffiliates to market to you

Yes

Yes

To limit our sharing

- Call toll-free 1-877-55CRB55 - our menu will prompt you through your choice(s)
Please note:
If you are a new customer, we can begin sharing your information 30 days from the date we provided or sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.

Questions?

Call toll-free 1-877-55CRB55 or go to www.crossriverbank.com




What we do

How does Cross River Bank protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

We also maintain other physical, electronic and procedural safeguards to protect this information and we limit access to information to those employees for whom access is appropriate.

How does Cross River Bank collect my personal information?

We collect your personal information, for example, when you
- Open an account or Apply for a loan
- Make deposits or withdrawals from your account or Provide employment information
- Give us your contact information
We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Why can't I limit all sharing?

Federal law gives you the right to limit only
- sharing for affiliates' everyday business purposes--information about your creditworthiness
- affiliates from using your information to market to you
- sharing for nonaffiliates to market to you
State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

What happens when I limit sharing for an account I hold jointly with someone else?

Your choices will apply to everyone on your account

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.
- Cross River Bank does not share with our affiliate. Our affiliates include CRB Group, Inc., CRB Investment Company, Inc., CRB RET Inc. LLC.

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.
- Nonaffiliates we share with can include loan finance companies

Joint marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
- Our joint marketing partner(s) include loan finance companies.

Other important information

Special Notice For State Residents

For Alaska, Illinois, Maryland and North Dakota Customers. We will not share personal information with nonaffiliates either for them to
market to you or for joint marketing-without your authorization.

For California Customers. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing
-without your authorization. We will also limit our sharing of personal information about you with our affiliates to comply with all California privacy laws that apply to us.

For Massachusetts, Mississippi and New Jersey Customers. We will not share personal information from deposit or share relationships with nonaffiliates either for them to market to you or for joint marketing-without your authorization.

For Vermont Customers. We will not share personal information with nonaffiliates either for them to market to you or for joint
marketing without your authorization, and we will not share personal information with affiliates about your creditworthiness without your authorization.