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Privacy Policy
Effective September 2007

1.  Our Privacy Commitment. Finance Factors is committed to handling any personal information that you provide to us, responsibly and with care. We are committed to the safekeeping of your personal information and understand that your trust is of utmost importance to us.  In order to preserve that trust, we want you to understand what information we collect and how we use it. To provide you efficient and effective customer service, we need to use and at times provide your personal information to others, in order to properly maintain and/or service your account, to offer you the array of financial products and services you need to accomplish your financial goals, and to comply with various laws and regulations.  We also use technology to manage and maintain customer information. We want to assure you that when we do use or provide your personal information to others, we will take reasonable precautions to protect your personal information against misuse.

Please read this privacy notice that explains how we will handle any personal information that you entrust to us.   Please note that this Privacy Policy supersedes any prior policy that we have issued.

2.  Certain Terms Defined. The following terms used in this notice have the following meanings:

“You” and “your” means you.

“We”, “us” and “our” means Finance Factors, Limited.

“Consumer” means an individual who obtains or has obtained a financial product or service from us that is used primarily for personal, family or household purposes or that individual’s legal representative.

“Customer” means a consumer who has a continuing relationship with us because we provide one or more financial product or service that is primarily for personal, family or household purposes.

“Non-affiliate” means all companies that are not our affiliates, and also includes any “nonaffiliated third party” as defined in the Privacy Law.

 “Personal information” means “nonpublic personal information” as defined in the Privacy Law, and includes, for example, any information you provide to us in connection with your applying for or obtaining a financial product or service from us, or any information we obtain about you in connection with our providing a financial product or service to you. This term does not include information, that is publicly available, or any other information that is not included within the definition of “nonpublic personal information” under the Privacy Law.

3. Why We Collect, Retain, Use and Disclose Personal Information.

We collect, retain, use and disclose your personal information to

• Accurately identify you;
• Protect, administer and/or service your records and accounts;
• Comply with laws and regulations;
• Understand your financial needs;
• Design and provide you with products and services; and
• Save you time in applying for new products and services.

We collect information from:

• Applications and other forms you give us (i.e. name, address, Social Security number, assets, income and financial objectives);
• Transactions you’ve conducted (i.e., account balance and payment history);
• Third parties outside Finance Factors on transactions you’ve conducted (i.e., account balance, payment history, parties to transaction and credit card usage);
• Credit reporting agencies and market research companies (i.e., creditworthiness, credit history and demographic information); and
• Public sources, such as federal, state or local records (i.e., mortgage and lien information).

4.  Access Restricted. Within our company, only those employees with a need to know your personal information in the performance of their duties or in order to provide you with products or services, are authorized to access your personal information. All of our employees are informed of the importance of maintaining the confidentiality of customers’ personal information and are required to follow the principles stated in this notice and to comply with all applicable privacy laws. Any employee who violates any of these principles or any privacy law may be subject to disciplinary measures.

5.  Sharing and Using Information.  We reserve the right to share and/or use all information we collect as this Notice describes.  We do not share information about you with third parties outside of Finance Factors, except as permitted by law.  Finance Factors reports information about your account to credit bureaus; therefore, late payments, missed payments, or other defaults on this account may be reflected in your credit report.

We do not provide information about you to third parties outside of Finance Factors, except as permitted by law.  When we do disclose information about you to third parties as legally permitted, the third parties are required to treat the information they receive about you in strict confidence; to use it only for the purpose for which it was shared; and not to use the information for their own marketing purposes.

6. Opt-Out Exceptions.  It is important to understand that even if you opt out, in addition to those exceptions listed above; we are legally permitted to and may continue to share or use information about you for the following:

• To perform services (i.e., loan servicing, printing statements, bill payment, e-mail services and mail house services);
• To process your account or enforce your agreement with us;
• To protect the rights, property or safety of Finance Factors, our customers or others (i.e., to protect against fraud and to reduce credit risk);
• To comply with a legal requirement or process (i.e., subpoena or court order);
• To comply with federal, state, or local legal requirements;
• To comply with your request or authorization to share information;
• To furnish information to consumer reporting agencies; and
• To facilitate a securitization, secondary market sale (including sale of servicing rights), loan brokering or other similar transaction that involves your account.

f you end your relationship with us, we will still apply the practices in our Notice to information we maintain on you and will honor your opt-out and solicitation elections.

7.  Online Information Practices.  We use technology that encrypts (scrambles) online information so it transfers privately between you and our network.  Your unique User ID and Password help protect your information online while you complete an online mortgage application.  We also mask (hide) your private information you provide for the online mortgage application.

We have joined with certain third parties to deliver online products and services.  If you ask for information through our online website financefactors.com, we and these third parties may keep some information you provide in order to deliver these services, such as online tools and applications, e-mail, and cookies.

• We may keep information from online tools and calculators, online applications and forms, or business conducted online through Internet or wireless devices.
• E-mail – If you send us e-mail, we may keep the content of your e-mail.  Please be careful about the information you e-mail to us; information you give us may be used by us to send you e-mail messages that are of specific interest to you.
• Cookies – A “cookie” tells us our site was visited and which pages were viewed by you.  Cookies are used for security (identification) purposes when you conduct business online.  They are common on websites and our cookies do not harm your computer.  We use cookies that do NOT transmit any personal information about you.
• Information from children online – We do not market online products and services to children.  We take steps to block to the best of our ability children from sending us information online.

8.  Protection of Personal Information via Established Security Procedures. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your personal information. When feasible, we incorporate new technology for protecting your personal information.

9.  Disclosure of Personal Information for Marketing Purposes. We may use personal information for marketing purposes.  Information may be used to design and offer products or services that may benefit you based on your financial needs or preferences.  Employees are authorized to access information only on a “need to know” basis.

Even if you opt out of using information for marketing purposes, we are legally permitted to and may use information for the following purposes:

• To market to a customer who has a pre-existing business relationship;
• To market to a customer who has a business relationship within the past 18 months; and
• To respond to an application or inquiry about a product or service.

10.  Your Right to Opt Out of Disclosure of Personal Information to Non-Affiliates. If you prefer that we not disclose personal information about you to nonaffiliates (except as otherwise permitted or required by law), then you may direct us not to make such disclosures to non-affiliates, that is, you may “opt out” of those disclosures. If you elect to opt out of such disclosures to non-affiliates, your opt-out will apply to all financial products or services you obtain from us, such as all loans and deposit accounts with us. If you previously opted out and are still a customer with us and wish to continue your opt-out, you do not need to do anything.

If you and another party or parties jointly obtain or have jointly obtained a financial product or service from us, such as a loan or deposit account, then either you or any other party to the joint account may exercise the right to opt out separately or on behalf of all parties to the joint account. Any party to a joint account may exercise the right to opt out either on that party’s own behalf or on behalf of all parties to the joint account. If any party to a joint account exercises the right to opt out on behalf of itself and all other parties to the joint account, then the opt-out will apply to: (a) all accounts held by that party either individually or jointly with others; and (b) all accounts held by any of the other parties to the joint account, either individually or jointly with others.

If you wish to opt out of disclosures to non-affiliates, you may call us during our normal business hours: on Oahu at (808) 522-2000; or toll-free from the neighbor islands of Hawaii at 1-800-648-7136; or if you are calling from outside the State of Hawaii, please call us collect at (808) 522-2000. If you have any joint account(s) with us, please indicate if you are opting out on behalf of yourself only, or on behalf of all parties to the joint account(s). You may exercise the right to opt-out at any time by calling the above toll free numbers.

11.  Maintenance of Accurate Personal Information. In order to best serve you, we strive to maintain complete and accurate personal information about you and your accounts. Should you ever believe that our records contain inaccurate or incomplete personal information about you, please notify us. We will investigate your concerns and correct any inaccuracies. In accordance with the Fair and Accurate Credit Report Act of 2003, Finance Factors reports information about your account to credit bureaus; therefore, late payments, missed payments, or other details on this account may be reflected in your credit report.

12.  Customer Inquiries. We value our relationship with you and we recognize and respect your privacy expectations. We want you to understand our commitment to your privacy in our use of your information. As a result of this commitment we have established this Privacy Notice. If you have any questions about this Privacy Notice or the privacy of your information, you may call your local branch, or our Customer Service Center during our normal business hours: on Oahu at (808) 522-2000; or toll-free from the neighbor islands of Hawaii at 1-800-648-7136; or if you are calling from outside the State of Hawaii, please call us collect at (808) 522-2000; or e-mail us at info@financefactors.com.

13.  Identity Theft
Identity theft is a serious and growing problem. If someone has fraudulently used your identification to establish credit, report the incident as quickly as possible to each of the credit reporting agencies listed below and ask that a fraud report be placed on your file.

Experian 888-397-3742
Equifax  800-525-6285
TransUnion 800-680-7289
 
You may also check to see if any additional credit accounts have been opened without your consent or whether unauthorized charges were billed to your accounts. Contact these credit reporting agencies to obtain a copy of your credit report.

Experian 888-397-3742
Equifax  800-685-1111
TransUnion 800-916-8800

Please note that this contact information is being provided as a service to you. Finance Factors is not affiliated with any of these services and cannot guarantee their effectiveness.