Thank you for visiting the Spectrum Merchant Services web site. Spectrum Merchant Services has designed its Privacy Policy to inform you about our current data collection and how we use your personal information. From time to time, Spectrum Merchant Services LLC may, without notice, modify or eliminate all or a portion of this Privacy Policy.

The Privacy Policy is available from any page of the Spectrum Merchant Services website. From time to time, you may click to other Spectrum web sites or pages that have different privacy policies. When this happens, you may review the privacy policies that relate to those pages or sites.

We obtain personal information that is needed to provide you with our goods and services.

When Spectrum Merchant Services collects information directly from you, we obtain this personal information in order to provide you with our goods or services, to provide customer service and to fulfill any legal or regulatory requirements. We also obtain personal information as a result of consumers' financial transactions with Spectrum or with Spectrum merchants. When we obtain information about consumers and merchants from third parties, we use sources that we believe are reputable, including public repositories. The only personal information we collect is information you provide us.

The only information we collect about you is information that you provide us.

This information may include, for example, your name, mailing address, e-mail address and telephone number. If you supply us with personal data and request information from us, we will contact you to provide you with the information you requested. We may also contact you to follow up on your job opportunity inquiries, or we may send you other information about Spectrum Merchant Services and its products or services that we believe you would find interesting or helpful.

We are committed to protecting the confidentiality of your personal information.

Spectrum Merchant Services' policies limit access to the personal information we collect to those Spectrum employees and Spectrum business relationships that need the information to fulfill their business responsibilities. We require our employees to adhere to Spectrum Merchant Services' Privacy Policy. Employees who violate the Spectrum Privacy Policy are subject to disciplinary action, up to and including dismissal.

When Spectrum collects personal information about you, we handle this information in accordance with the terms and conditions in our applicable merchant agreement. When Spectrum Merchant Services engages vendors and other outside contractors, they are subject to our contractual requirements. For purposes of credit reporting, verification and risk management, we may share information about you with third parties. We also will disclose information in response to a request issued by a court, government agency or regulatory authority.

We will inform you about the general uses of the information we collect about you.

When we have a direct customer relationship with you, we will strive to make information available to you about the general uses of the information we collect. This information is made available at the point of sale, through privacy notices on our Web sites, in other formats that are publicly available or through other means specified by applicable state and federal laws. In addition, when Spectrum obtains personal information about consumers indirectly through our merchants, we require our merchants to provide these consumers with their own timely and complete privacy notice.

We strive to give you choices about how your information will be used.

When we obtain personal information as part of our direct relationship with you, we will not share this information with nonaffiliated third parties, except in the following circumstances:

• In accordance with the Spectrum Merchant Services Privacy Policy
• To facilitate and complete merchant-initiated or authorized transactions
• To comply with federal, state and local laws, including credit reporting laws and card association rules
• To combat fraud
• To offer products and services that Spectrum Merchant Services believes may be of interest to you.

We maintain procedures to assure the quality of information we collect and, in some instances, we inform you how you can access your information and make corrections, if necessary.

Spectrum employs appropriate measures to assure the quality of information that we collect directly from you. In some instances, where Spectrum collects information directly from you, Spectrum informs you how to correct any erroneous or out-of-date information stored in our database. These requirements and procedures may vary by each Spectrum business activity. As you visit our various Web pages, please be sure to review the privacy policies applicable to those sites. We abide by applicable laws related to such information.

We use appropriate security safeguards.

At Spectrum Merchant Services, security is important. Spectrum employs appropriate measures, including advanced technology, to protect personal information collected against unauthorized access, disclosure, alteration or destruction. These measures may include, among others, encryption, physical access security and other appropriate technologies. Spectrum continually reviews and enhances its security systems, as necessary.

Spectrum Merchant Services' web sites may be linked to other web sites.

Spectrum may create links to third-party web sites. Spectrum is not responsible for the content or privacy practices employed by third-party Web sites that are linked to our web site. Neither does Spectrum control or warrant the utility, merchantability or workmanship of the products or services offered at third-party web sites.

Your privacy is important to us. By participating in the Council of Better Business Bureau's BBBOnLine Privacy Program we have made a commitment to meet the programs' strict requirements regarding how we treat your information and have it verified by BBBOnLine. Further information about this program is available at www.bbbonline.org.

Use of Cookies

To ensure we are publishing content customers need and want, SBS collects aggregated site-visitation statistics using cookies. When someone visits the site, a cookie is placed on the customer's machine (if the customer accepts cookies) or is read if the customer has visited the site previously. If you choose to not have your browser accept cookies from SBS's Web site, you will need to re-enter your personal information each time that you attempt to access premium information.

We strive to maintain our privacy standards.

Spectrum strives to meet our privacy program standards. In doing so, we do the following:

• Employee privacy training and employee compliance related to the Privacy Policy
• Periodic assessments of Spectrum Merchant Services' compliance with this Privacy Policy
• Periodic management review to ensure that Spectrum actively participates in appropriate privacy activities, including self-regulatory initiatives

The examples contained in this Privacy Policy are illustrations only, and they are not intended to be all-inclusive. If you decide to close your merchant account or become an inactive customer, or if we close or suspend your account, our Privacy Policy, as it may exist from time to time, will continue to apply. We may amend this Privacy Policy at any time, and we will inform you of changes as required by law. You may have other privacy protections under state laws, and we will comply with applicable state laws when we disclose information about you. This Privacy Policy applies to all accounts you may have with us, and it replaces all our previous disclosures to you about our information practices.

If you have any questions or comments about the Spectrum Merchant Services Privacy Policy, please contact:

Spectrum Merchant Services
3 Hutton Centre
Suite #450
Santa Ana, CA 92707

This Spectrum Merchant Services Privacy Policy is currently applicable only to Spectrum Merchant Services' United States customers and visitors to our web site. Cross-border transactions may have their own rules and practices.