The EquiFirst Privacy Pledge to Customers

EquiFirst Corporation (“EquiFirst”) is a member of Barclays Bank PLC and its family of affiliated companies that offer a wide-range of banking, mortgage, brokerage and other financial services to consumers.

In today's world, safeguarding the personal financial information you entrust to us is not only more important than ever – it is also the right thing to do.

So is telling you about it. The EquiFirst Privacy Pledge is our way of communicating the types of personal financial information we collect, how we protect the confidentiality of that information, and how we use it.

We are committed to core values of soundness, quality and integrity. As we work together to provide the broad range of products and services you want and need, we also remain focused on doing the right thing.

You can rest assured that we do not sell customer information or customer lists to outside marketers.

Information We Collect

The information that we collect is limited to what we believe is necessary or useful to conduct our business; to administer your records, accounts and funds; to comply with laws and regulations; and to help us design or improve products and services.

We collect this information from the following sources:

• Information we receive from you on applications or other forms, such as your assets, income and other debt.
• Information we receive from a consumer report, such as information regarding your creditworthiness or credit history.
• Information we receive from public records and market research, such as demographic information.
• Information we obtain from outside sources relating to their employment, credit or other relationships with you, such as a verification of employment history, loan or credit card balance or insurance coverage.
• Information we have obtained at your request, such as aggregated information from multiple financial service providers.

Information We Share

We do not share information about our customers or former customers, except as described in the EquiFirst Privacy Pledge.

Sharing Among Our Affiliated Companies

In the course of our business, we may share some or all of the information described above among our affiliates. This gives us a more complete knowledge of your total relationship with us and helps us to provide you with important benefits.

Some of the benefits to you may include:

• Prevention of unauthorized transactions or fraud.
• Enhanced customer service and responsiveness.

Sharing with Companies that Work with Us

In order to conduct company business, and to offer products or services that may complement your relationship with us, we may share some or all of the information we collect, as described above, with the following companies (including our affiliates):

• Companies that perform services for us or on our behalf, such as vendors we hire to prepare account statements or to provide support for one or more of our products and services.
• Companies that perform marketing services on our behalf or other financial institutions with whom we have joint marketing agreements, such as insurance companies and credit card issuers.
• These companies act on our behalf, and are contractually obligated to keep the information we provide them confidential and to use the information only for the purposes authorized.

Sharing in Other Situations

We may share some or all of the information we collect, as described above, as otherwise authorized or required under applicable law. This includes, for example, disclosures to credit reporting agencies; disclosures to process and service your requested or authorized transactions; disclosures in connection with recording deeds of trust, mortgages and other security instruments in public records; disclosures in connection with subpoenas or other legal processes; disclosures as part of fraud investigations; disclosures in connection with audits and examinations; disclosures in connection with the sale of accounts to another financial institution; and disclosures pursuant to your authorization or consent.

Protecting Information About You

We restrict access to information about you to those employees who need to know that information as part of their job responsibilities. We also educate our employees about the importance of confidentiality and customer privacy through standard operating procedures, special training programs, and our Code of Conduct. We take appropriate disciplinary measures to enforce employee privacy responsibilities.

EquiFirst also maintains physical, electronic, and procedural safeguards to guard your information. We will continue to test and update our technology to improve the protection of your information.

Protecting Information About Former Customers

The EquiFirst Privacy Pledge regarding the collection, use and disclosure of information about former customers is the same as our pledge to current customers.

Other Helpful Privacy Information

We Want To Maintain Accurate Customer Information. We have established procedures to keep your information current and complete. These procedures include responding to requests to correct inaccurate information in a timely manner. If you believe our customer records contain incorrect information about you, write to us at EquiFirst Corporation, 500 Forest Point Circle, Charlotte, NC 28273 (attention Servicing Dept.) or call us at (866) 306-2298, or visit our Web site at equifirst.com to send us a secure email.

You Can Limit Pre-Approved Credit Solicitations

To request that your name be removed from pre-approved credit solicitations developed through credit reporting agencies; you can call (888) 567-8688 or write to the agencies listed below. Include your name, address and Social Security number.

Experian
Consumer Opt-Out
901 West Bond
Lincoln, NE 68521

Equifax, Inc.
Options
P.O. Box 740123
Atlanta, GA 30374-0123

TransUnion LLC
Name Removal Option
P.O. Box 97328
Jackson, MS 39288-7328

You Can Limit Other Solicitations

If you wish to have your name removed from solicitation lists created by companies other than EquiFirst, you can contact the following agencies:

To limit mail solicitations, visit:
www.the-dma.org/consumers/offmailinglist.html
or write to:
Mail Preference Service
c/o Direct Marketing Association
P.O. Box 9008
Farmingdale, NY 11735-9008

To limit telephone solicitations, visit:
www.the-dma.org/consumers/offtelephonelist.html
or write to:
Telephone Preference Service
c/o Direct Marketing Association
P.O. Box 9014
Farmingdale, NY 11735-9014

To limit E-mail solicitations, visit:
www.dmaconsumers.org/emps.html

Include complete information about each name, address, telephone number and e-mail address to be excluded from these lists.

Questions About Our Privacy Pledge

If you have questions about the EquiFirst Privacy Pledge or about the privacy of your information, please call us at (866) 306-2298 between 8 a.m. and 5 p.m. (ET) Monday through Friday.

Keeping Up-To-Date With Our Privacy Pledge

The EquiFirst Privacy Pledge is subject to change. You can always review the current EquiFirst Privacy Pledge on our Web site at equifirst.com, or call us at (866) 306-2298, between 8 a.m. and 5 p.m. (ET) Monday through Friday and request a copy. We will notify you annually about the EquiFirst Privacy Pledge as long as you maintain an ongoing relationship with us.

Miscellaneous Information

The EquiFirst Privacy Pledge applies to individuals who obtain or have obtained from us a financial product or service that is used primarily for personal, family or household purposes. The laws of some states may impose separate or additional requirements before particular types of information about customers in those states can be disclosed. The EquiFirst Privacy Pledge is provided in compliance with applicable law and replaces all other notices, statements or agreements with respect to the same subject matter.

Special Privacy Notice for Vermont Residents

Vermont law places additional limits on disclosing information about Vermont residents so long as they remain residents of Vermont. In accordance with Vermont law, we will not disclose information we collect about Vermont residents to companies outside of EquiFirst and will not disclose application and third party credit-related information about Vermont residents to other companies within EquiFirst except as follows: as permitted by law; to companies that perform marketing or other services on our behalf; name, contact and transaction and experience information to other financial institutions with which we have joint marketing agreements; or with the authorization or consent of the Vermont resident.