Privacy Statement

PlanFirst Financial Services, Inc. (“PFFS”), together with its related and affiliated entities, (collectively “PFFS”, “we”, “our” or “us”) is committed to protecting the privacy of our online visitors. In compliance with Federal and State Law, industry standards and administrative regulations, this privacy policy discloses the privacy practices governing our collection and use of information submitted by you (“you”, “your” or the “user”) to PFFS through this web site. We want you to know that we take our legal and ethical responsibilities regarding your privacy seriously. Therefore, we abide the following privacy policy. This privacy policy is part of our overall compliance with state and federal mandates requiring us to deploy a Gramm, Leach, Bliley Safeguards Rule Information, Data and Privacy Security Program aimed at affording your non-public personal information administrative, physical and technological protections.

Information Collection & Use

Registration
We restrict access to nonpublic personal information about you to those employees and other parties who must use that information to provide products and services to you. Their right to further disclose and use the information is limited by our company policies, applicable law, and nondisclosure agreements where applicable. We also maintain physical, electronic, and procedural safeguards in compliance with applicable laws and regulations to guard your nonpublic personal information. In the event that we are compelled to involuntarily disclose any of your information, we will act on the advice of counsel should our records be subpoenaed or otherwise sought through legal means.

When using this web site, you may opt to complete our registration form either in writing, or by telephone and you may create a user name and password. This involves your disclosure of contact information (such as name and email address). We use this information as part of our security protocol and to contact you about the services on our site in which you have expressed interest.

If you do not want your nonpublic personal information disclosed to nonaffiliated third parties, you may “opt out” of those disclosures, meaning that you may tell us not to make those disclosures (other than those disclosures permitted by law even if you do opt out). If you opt out, we will not disclose this information to nonaffiliated third parties to independently market products or services to you, but we may include their offers in billing statements and other routine communications that we send you in connection with servicing your business relationship with us. To opt out, simply reply by electronic mail to ChiefPrivacyOfficer@pffs.com and type “opt out” in the subject line of the email. Once you opt out, there is no need to do so again for the same business relationship. You may also telephone us at 1-800-580-8116 to opt out.
You also have the option to provide demographic information (such as income level and gender) to us; we encourage you to submit this information so we can provide you a more personalized experience on our site. For example, by using this information we can provide you with newsletters, updates, and e-mails regarding matters which are relevant and useful to you.

We are the sole owner of the information collected on our site. We collect personally identifiable information from our users at several different points on our Web site.

Orders
If you purchase a product or service from us, we request certain personally identifiable information from you on our form. You must provide contact information (such as name, email, and shipping address) and financial information (such as credit card number, expiration date). We use this information for billing purposes and to fulfill your orders or provide services. If we have trouble processing an order, we will use this information to contact you. Additionally, if you so choose, you may receive updates from our site.

Application Forms
If you apply for any of our products or services or those of our affiliates or simply request information regarding products promoted on our site, we require that you provide certain personally identifiable information, including your name, address, phone number, credit card number and sometimes your Social Security number. This information is necessary to process your application and to contact you.

Social Security Numbers
Although we attempt to do so on a strictly necessary basis, we do, at times, require your social security number in furtherance of providing services. When you enter your social security number on our registration order form, application form, we encrypt it using secure socket layer technology (SSL).

Refer-A-Friend
If you choose to use our referral service to tell a friend about our site, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the site. We store this information for the sole purpose of sending this one-time email and tracking the success of our referral program. Our e-mail will contain an easy opportunity for your friend to contact us to request that we remove this information from our database.

How Collected Information is Used
Aside from the ways mentioned above, we sometimes use your personally identifiable information in many ways, including sending you promotional materials, and sharing your information with third parties so that these third parties can send you promotional materials. (By "promotional materials," we mean communications that directly promote the use of Web sites, or the purchase of products or services.). However, you may "opt-out" of certain uses of your personal information by simply contacting us as indicated below.

Communications from the Site

Special Offers and Updates
We will occasionally send you information on products, services, special deals, promotions. You can sign up for these types of emails from us on our registration page. Out of respect for your privacy, we present the option not to receive these types of communications. Please see the “Choice and Opt-out ” section for further details.

Newsletters/Promotional Updates
If you wish to subscribe to our newsletter(s) and promotional updates, we will use your name and email address to send the newsletter to you. Out of respect for your privacy, we provide you a way to unsubscribe. Please see the “Choice and Opt-out” section.

Service-related Announcements
We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account. You may opt-out of these communications. Please see “Choice and Opt-out. ”

Customer Service
Based upon the personally identifiable information you provide us, we may send you a welcoming email to verify your username and password. We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We will communicate with you by email or telephone, in accordance with your wishes.

Profile
We store information that we collect through cookies, log files, clear gifs, and/or third party sources to create a “profile” of your preferences. We tie your personally identifiable information, and your purchasing history, to information in the profile, in order to provide tailored promotions and marketing offers and to improve the content of the site for you. We sometimes share your profile with other third parties who, according to your history with us, may provide useful opportunities to you.

Supplementation of Information
In order to provide certain services to you, we may on occasion supplement the personal information you submitted to us with information from third party sources.

Enhancement of Profile Information
We purchase marketing data from third parties and add it to our existing user database, to better target our advertising and to provide pertinent offers in which we think you would be interested. To enrich our Profiles of individual customers, we tie this information to the personally identifiable information they have provided to us.

Information Sharing and Disclosure

Aggregate Information (non-personally identifiable)
We share aggregated demographic information about our user base with our partners and advertisers. This information does not identify individual users. We do not link aggregate user data with personally identifiable information.

Personally identifiable information
Although we do share demographic information for the purposes of assisting you meet your needs and interests, we do not share Personally Identifiable Information with Third Parties. We provide opt out opportunities with regard to all information sharing practices.

Agents
We may contract with an outside shipping company to promulgate correspondence and packages, as well as a credit card processing company to bill you for goods and services. These companies do not retain, share, store or use personally identifiable information for any other purposes.

Service Providers
We use other third parties to provide certain clerical and information processing and shipping services on our site. When you sign up for our services, we will share only as much information as is necessary for the provision of those services. These third parties are prohibited from using your personally identifiable information for any other purpose.

Legal Disclaimer
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 to comply with a judicial proceeding, court order, or legal process served on our Web site

Choice/Opt-out
We provide you the opportunity to ‘opt-out’ of having your personally identifiable information used for certain purposes, when we ask for this information. For example, if you purchase a product/service but do not wish to receive any additional marketing material from us, you can indicate your preference on our order form. If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by emailing or calling us per the information contained on our contact page.

Opting Out
If you do not want your nonpublic personal information disclosed to nonaffiliated third parties, you may “opt out” of those disclosures, meaning that you may tell us not to make those disclosures (other than those disclosures permitted by law even if you do opt out). If you opt out, we will not disclose this information to nonaffiliated third parties to independently market products or services to you, but we may include their offers in billing statements and other routine communications that we send you in connection with servicing your business relationship with us. To opt out, simply reply by electronic mail to: to ChiefPrivacyOfficer@pffs.com and type “opt out” in the subject line of the email. Once you opt out, there is no need to do so again for the same business relationship. You may also telephone us at 1-800-580-8116 to opt out.

Log Files
As is true of most Web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personally identifiable information.

Cookies
A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on this site. We do not link the information we store in cookies to any personally identifiable information you submit while on our site. We use session ID cookies. We use session cookies to make it easier for you to navigate our site. A session ID cookie expires when you close you browser. We can at your option set a persistent cookie to store your passwords, so you don’t have to enter it more than once. Persistent cookies also enable us to track and target the interests of our users to enhance the experience on our site. If you reject cookies, you may still use our site, but your ability to use some areas of our site, such as contests or surveys, will be limited. This privacy statement covers the use of our cookies only and does not cover the use of cookies by any advertisers.

Third Party Advertisers
The ads appearing on this Web site are delivered to users by our advertising partner. We share Web site usage information about users with a reputable third party for the purpose of targeting our Internet banner advertisements on this site. The information collected and shared through this technology is not personally identifiable.

Links to Other Sites
This Web site contains links to other sites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site and to read the privacy statements of each and every Web site that collects personally identifiable information. This privacy statement applies only to information collected by this Web site.

Co-branded sites
We may, in certain circumstances co-brand with “partners and affiliates”. These business to business relationships are helpful to us and to you as they afford all concerned with greater product and service opportunities. We always provide opt-out opportunities regarding the sharing of your information with such partners and affiliates. Please note the sites linked to our site are governed by their own privacy policies which may or may not reach the standards set by our company.

Bulletin Boards/Chat Rooms
If you use a bulletin board or chat room on this site, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these forums. We hereby reserve the right to terminate services of those who use these services in a manner inconsistent with the policies articulated herein as well as those articulated in our terms of use page.

Access to Personally Identifiable Information
If your personally identifiable information changes, or if you no longer desire our service, you may correct, update, delete or deactivate same by making the change on our member information page or by emailing our Customer Support by contacting us by telephone or postal mail at the contact information listed below.

Security
The security of your personal information is important to us. When you enter sensitive information (such as credit card number and/or social security number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. If you have any questions about security on our Web site, please feel free to e-mail us.

Business Transitions
In the event we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personally identifiable information will likely be among the assets transferred. You will be notified via e-mail and/or a prominent notice on our Web site for 30 days of any such change in ownership or control of your personal information.

Changes in this Privacy Statement
We will not jeopardize your privacy. However, if we decide to change our privacy policy, we will post those changes to this privacy statement, the homepage, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page.

Contact Us
If you have any questions or suggestions regarding our privacy policy, please contact us at by e-mail or telephone: chiefPrivacyOfficer@pffs.com or 1-800-580-8116.

Last updated: 8/2/2007