Privacy Policy V1 R03292016

Important Notice Regarding Your Privacy Rights

This privacy policy notice is designed to inform you of the types of
nonpublic personal information (“Personal Information”) Trading Financial
Credit, LLC (“TFC”) (the “Company”) may maintain or collect during the
course of our relationship with you. It also explains the safeguards that
TFC has in place to protect that information and the circumstances under
which TFC may share that information with other companies. This notice
applies to both current and former customers.

Why We Collect Personal Information

We collect Personal Information to identify you, confirm facts about
you, deliver financial products and services to you, to help us assess
requests for financial products and services, and as necessary to
service your loan.

Personal Information We Maintain or Collect

The following are examples of the types of nonpublic personal
information we maintain or collect:

• Information that you provide in connection with your loan,
  applications, other forms, or verbally, such as: name, address,
  telephone number, social security number, income, driver’s license
  number, and employment information.
• Information about your transactions with us, our affiliates, or
  other parties, such as: account balances and payment history.
• Information we receive from consumer reporting agencies, such as:
  credit history and credit worthiness.
• Information obtained from non-affiliated third parties about your
  transactions with them.

Sharing of Personal Information

We may share some or all of the Personal Information that is
described above as follows:

• With Non-Affiliated Financial Service Providers, such as banks,
  mortgage bankers, credit card issuers, insurance companies and
  insurance agents.
• With Non-Affiliated Non-Financial Companies, such as statement
  processors, repossession companies, collection agencies, or our
  attorneys.
• With Our Affiliated Companies for their everyday business purposes
  or to market their products to you.
• With Non-Affiliates for Joint Marketing – We may share your
  Personal Information with nonaffiliated financial companies with whom
  we have a formal agreement to market financial products or services to
  you.

Your Right to Limit Sharing/Opt-Out Right

You have the right to limit our sharing of your Personal Information,
except as permitted by law, by completing and returning the opt-out
notice that was provided to you via the US Postal Service titled “FACTS:
What Does Trading Financial Credit, LLC Do With Your Personal
Information?” (Customers located in California can also return the
opt-out notice titled “Important Privacy Choices for California
Consumers”).

You can download a new notice here: Download
Federal Notice
You can download a new notice for California
residents here: Download
California Notice

Protection of Information and Security Procedures

We restrict access to Personal Information about you as a current or
former customer to our employees or affiliates who need this information
to provide financial products or services to you and to otherwise
service your account(s) with us. We maintain physical, electronic and
procedural safeguards that comply with applicable federal and state
standards to guard your Personal Information. For example, we use Secure
Sockets Layer (SSL) technology supporting up to 128-bit encryption to
prevent unauthorized parties from viewing any nonpublic personal
information transmitted to or from us.

Privacy Notice – Online Supplement

This section describes our practices regarding information we receive
about you during visits to this web site. The amount and type of
information we receive depends on how you use this site.

Normal Web Site Usage

You can visit our web site to read product and company information,
or use our on-line tools without revealing any personal information. The
only information we collect and store during normal web site usage is
the name and address of your Internet service provider, the web site you
last visited, the pages you request, the date and time of those requests
and the number of visits you made to our website. We use this
information to generate statistics and measure website activity in order
to improve the usefulness of customer visits to our website. This same
information may be shared with third parties in order to provide these
services or to analyze, store, or aggregate the information. It may also
be shared with other third parties, working with us to improve our
services or our website. During normal web site usage, we do not collect
or store personally identifiable information such as name, mailing
address, email address, phone number or Social Security number.

On-Line Collection of Personally Identifiable Information

Occasionally, we will request personally identifiable information in
order to provide the web site visitor with a service or correspondence
(e.g., promotions and mailed brochures). This information, such as name,
mailing address, email address, type of request, and possibly additional
information, is collected and stored in a manner appropriate to the
nature of the request as determined by us and is used to fulfill your
request. Whenever we request such information, we will clearly explain
how it will be used. If you tell us that the information should not be
used as a basis for further contact, we will respect your request. The
information you provide is used by us to improve the services we provide
you. This information may also be provided to agencies for use on our
behalf in accordance with our Privacy Notice. However, it is never
provided or sold to any other company for that company’s independent
use.

Please note that our website may provide links to third party sites
not controlled by us. We suggest that you check the specific Privacy
Notices of any site before providing any personally identifiable
information.

Electronic Mail Sent to Us That Contains Personal Information

Internet users may decide to send us personally identifying
information, for example, in an electronic mail message containing
information about your account with us. We will only use this
information to identify the user as our customer and to determine how to
respond to the electronic mail. We will use this information for the
purpose identified in the email message and to enhance our understanding
of you in order to improve our services to you.

Internet Services

To use our Internet services, such as online account access, we
require a certain amount of personally identifying information (e.g.,
name, Social Security number, account number and other applicable
information) we can use to verify you as our customer. We use this to
identify and access data in the existing relationship we have with you
in order to provide you with the requested services. We request email
addresses as an alternate means of contacting you. Providing your email
address is optional, except when you request an Internet delivered
service, then it is necessary for us to have your email address in order
to honor your request. We may also use this information to enhance our
understanding of you and improve our services.

What Are Cookies

A “cookie” is a small line of text that is stored within your browser
when you visit a cookie-enabled website. As you browse the Web,
cookie-enabled sites will send cookies to your browser, along with
pages. Your browser probably has options that will let you control
whether the browser accepts cookies, rejects cookies, or notifies you
each time a cookie is sent to you.

If your browser is set to reject cookies, cookie-enabled websites
will not recognize you when you return. This provides you with
anonymity, but it also makes it very difficult to offer you customized
services. It is also less secure than using cookies, because all of your
specific data must be sent to the website each time you view a page.
Accepting cookies means your private data can stay at the Web server,
and the only information transmitted over the Internet is your ID
cookie.

If your browser is set to accept cookies, any cookies that are sent
to your browser are stored in your computer for a period of time. There
are a few different types of cookies. A “session” cookie is stored only
in your computer’s working memory (RAM) and only lasts for your browsing
session. When you close all of your browser’s windows, or when you shut
down your computer, the session cookie disappears forever. A “permanent”
cookie is stored on your computer’s hard drive until a specified date,
which could be tomorrow, next week, or 10 years from now. Permanent
cookies stay on your computer until either a) they expire, b) they are
overwritten with newer cookies, c) you manually remove them. We use
permanent cookies to supply visitors to our site with a customized
experience. These cookies do not involve personally identifiable
information. We also use session cookies to customize your experience
during a session, to aid in your navigation and use of the site, to
develop generic web site metrics and other similar uses.

Keeping Customer Information Accurate

If you believe our records are incomplete or inaccurate, you may
write to us at: 3055 Wilshire Blvd., Suite 300 Los Angeles, CA 90010 or
email us at complian[email protected].

Effective Date; Changes to Our Policy

We reserve the right to change our Privacy Policy and Privacy Notice.
A revised Privacy Policy or Privacy Notice applies only to data
collected subsequent to its effective date. If we make substantial
changes to our policy, we will post the changes on our website.

The Terms of Use (aka privacy policy) is designed to inform you of
the types of nonpublic personal information (“Personal Information”)
Trading Financial Credit, LLC (“Company”) may maintain or collect during
the course of our relationship with you. It also explains the safeguards
we have in place to protect that information and the circumstances under
which we may share that information with other companies. This notice
applies to both current and former customers.

Why We Collect Personal Information

We collect Personal Information to identify you, confirm facts about
you, deliver financial products and services to you, to help us assess
requests for financial products and services, and as necessary to
service your loan.

Personal Information We Maintain or Collect

The following are examples of the types of nonpublic personal
information we maintain or collect:

• Information that you provide in connection with your loan,
  applications, other forms, or verbally, such as: name, address,
  telephone number, social security number, income, assets, driver’s
  license number, and employment information.
• Information about your transactions with us, our affiliates, or
  other parties, such as: account balances and payment history.
• Information we receive from consumer reporting agencies, such as:
  credit worthiness and credit history.
• Information obtained from non-affiliated third parties about your
  transactions with them.

Sharing of Personal Information

We may share some or all of the Personal Information that is
described above as follows:

• With Non-Affiliated Financial Service Providers, such as banks,
  mortgage bankers, credit card issuers, insurance companies and
  insurance agents.
• With Non-Affiliated Non-Financial Companies, such as statement
  processors, repossession companies, collection agencies, or our
  attorneys.
• With Our Affiliated Companies for their everyday business purposes
  or to market their products to you.
• With Non-Affiliates for Joint Marketing – We may share your
  Personal Information with non-affiliated financial companies with whom
  we have a formal agreement to market financial products or services to
  you.
• We may also share, as may be required or permitted by law,
  information about your loan to credit reporting agencies or pursuant
  to legal process.

Protection of Information and Security Procedures

We restrict access to Personal Information about you as a current or
former customer to our employees or affiliates who need this information
to provide financial products or services to you and to otherwise
service your account(s) with us. We maintain physical, electronic and
procedural safeguards that comply with applicable federal and state
standards to guard your Personal Information.

Privacy Notice – Online Supplement

This section describes our practices regarding information we receive
about you during visits to this web site. The amount and type of
information we receive depends on how you use this site.

Privacy Notice – Online Supplement

This section describes our practices regarding information we receive
about you during visits to this web site. The amount and type of
information we receive depends on how you use this site.

Normal Web Site Usage

You can visit our web site to read product and company information,
or use our on-line tools without revealing any personal information. The
only information we collect and store during normal web site usage is
the name and address of your Internet service provider, the web site you
last visited, the pages you request, the date and time of those requests
and the number of visits you made to our website. We use this
information to generate statistics and measure website activity in order
to improve the usefulness of customer visits to our website. This same
information may be shared with third parties in order to provide these
services or to analyze, store, or aggregate the information. It may also
be shared with other third parties, working with us to improve our
services or our website. During normal web site usage, we do not collect
or store personally identifiable information such as name, mailing
address, email address, phone number, or Social Security number.

On-Line Collection of Personally Identifiable Information

Occasionally, we will request personally identifiable information in
order to provide the web site visitor with a service or correspondence
(e.g., promotions and mailed brochures). This information, such as name,
mailing address, email address, type of request, and possibly additional
information, is collected and stored in a manner appropriate to the
nature of the request as determined by us and is used to fulfill your
request. Whenever we request such information, we will clearly explain
how it will be used. If you tell us that the information should not be
used as a basis for further contact, we will respect your request. The
information you provide is used by us to improve the services we provide
you. This information may also be provided to agencies for use on our
behalf in accordance with our Privacy Notice. However, it is never
provided or sold to any other company for that company’s independent
use. Please note that our website may provide links to third party sites
not controlled by us. We suggest that you check the specific Privacy
Notices of any site before providing any personally identifiable
information.

Electronic Mail Sent to Us That Contains Personal Information

Internet users may decide to send us personally identifying
information, for example, in an electronic mail message containing
information about your account with us. We will only use this
information to identify the user as our customer and to determine how to
respond to the electronic mail. We will use this information for the
purpose identified in the email message and to enhance our understanding
of you in order to improve our services to you.

Internet Services

To use our Internet services, such as our online application, we
require a certain amount of personally identifying information (e.g.,
name, Social Security number, account number and other applicable
information) we can use to verify you as our customer. We use this to
identify and access data in the existing relationship we have with you
in order to provide you with the requested services. We request email
addresses as an alternate means of contacting you. Providing your email
address is optional, except when you request an Internet delivered
service, then it is necessary for us to have your email address in order
to honor your request. We may also use this information to enhance our
understanding of you and improve our services.

What Are Cookies?

A “cookie” is a small line of text that is stored within your browser
when you visit a cookie-enabled website. As you browse the Web,
cookie-enabled sites will send cookies to your browser, along with
pages. Your browser probably has options that will let you control
whether the browser accepts cookies, rejects cookies, or notifies you
each time a cookie is sent to you. If your browser is set to reject
cookies, cookie-enabled websites will not recognize you when you return.
This provides you with anonymity, but it also makes it very difficult to
offer you customized services. It is also less secure than using
cookies, because all of your specific data must be sent to the website
each time you view a page. Accepting cookies means your private data can
stay at the Web server, and the only information transmitted over the
Internet is your ID cookie. If your browser is set to accept cookies,
any cookies that are sent to your browser are stored in your computer
for a period of time. There are a few different types of cookies. A
“session” cookie is stored only in your computer’s working memory (RAM)
and only lasts for your browsing session. When you close all of your
browser’s windows, or when you shut down your computer, the session
cookie disappears forever. A “permanent” cookie is stored on your
computer’s hard drive until a specified date, which could be tomorrow,
next week, or 10 years from now. Permanent cookies stay on your computer
until either a) they expire, b) they are overwritten with newer cookies,
c) you manually remove them. We use permanent cookies to supply visitors
to our site with a customized experience. These cookies do not involve
personally identifiable information. We also use session cookies to
customize your experience during a session, to aid in your navigation
and use of the site, to develop generic web site metrics and other
similar uses.

Changes to Our Policy

We reserve the right to change our Privacy Policy and Privacy Notice.
A revised Privacy Policy or Privacy Notice applies only to data
collected subsequent to its effective date. If we make substantial
changes to our policy, we will post the changes on our website.