Tuesday, October 24, 2017
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Trust. Respect. Integrity.

Our privacy commitment to you

 To learn more about how we manage our Customer Information and what actions you can take, please continue reading. We are committed to respecting and protecting our customers' privacy.

This document includes information about:

1. Making the security of information a priority

2. Collecting information

3. Managing information

4. Making sure information is accurate

5. Honouring your preferences

6. Actions you can take

7. Guarding your own information

This policy covers Customer Information, which means personally identifiable information about a consumer or a consumer's current or former customer relationship with Us. This policy is provided to you as required by the Federal Financial Privacy Law 15 U-S-C 68016810

1. Making the security of information a priority

Keeping information secure is one of our most important responsibilities. We maintain physical, electronic and procedural safeguards to protect Customer Information. Appropriate employees are authorized to access Customer Information for business purposes only. Our employees are bound by a code of ethics that requires confidential treatment of Customer Information and are subject to disciplinary action if they fail to follow this code.

2. Collecting information

We collect and use various types of information about you and your accounts to service your accounts, save you time and money, better respond to your needs, and manage our business and risks. Customer Information is categorized in the following six ways:

A. Identification Information - information that identifies you such as name, address, telephone number and other personal information (e.g. Social Security number).

B. Application Information - information you provide to us on applications and through other means that will help us determine if you are eligible for products you request. Examples include property / user rights of software.

C. Transaction and Experience Information - information about transactions and account experience, as well as information about our communications with you. Examples include emails, and knowledge contents in any type of written form.

D. Customer Report Information - information about customers.

E. Information from Outside Sources - information from outside sources regarding employment, credit and other relationships that will help us determine if you are eligible for products you request. Examples include employment history, loan balances, credit card balances, property insurance coverage and other verifications

.F. Other General Information - information from outside sources, such as data from public records, that is not assembled or used for the purpose of determining eligibility for a product or service.

As required by the USA PATRIOT Act, we also collect information and take actions necessary to verify your identification.

3. Managing Information

We manage how and when information is shared:

  • Within the company and/or related companies
  • With companies that work for us
  • With third parties
  • In other situations

Managing information within Diamond Concepts

Diamond Concepts is made up of a number of companies, including development operations and other servicing subsidiaries. Diamond Concepts may share any of the categories of Customer Information among our companies unless specifically declared confidential.

We occasionally have access to information related to private information from a customer or its employees. We do not share this type of information among our companies, except to process projects & tasks as part of our agreement to service our customers, to the extent permitted by law.

Managing information with companies that work for us

 We may share any of the categories of Customer Information with companies that work for us, including companies located outside the United States. All non-affiliated companies that act on our behalf and receive Customer Information from us are contractually obligated to keep the information we provide to them confidential, and to use the Customer Information we share only to provide the services we ask them to perform.

In addition, we may share any of the categories of Customer Information with companies that work for us in order to provide marketing support and other services, such as a service provider that distributes marketing materials. These companies may help us to market our own products and services, or other products and services that we believe may be of interest to you. Please note that some of our own companies may provide marketing support and other services for us as well.

Disclosing information in other situations

 We also may disclose any of the categories of Customer Information to credit bureaus and similar organizations and when required or permitted by law. For example, Customer Information may be disclosed in connection with a subpoena or similar legal process, fraud prevention or investigation, risk management and security, and recording of deeds of trust and mortgages in public records. Customer Information may also be disclosed to companies that process your requests for products or services or in connection with the sale of your account to another financial institution. We also may share any of the categories of Customer Information outside Diamond Concepts companies when we have your consent, such as when you request a specific insurance rate quote from a third-party insurer.

4. Making sure information is accurate

 Keeping your account information accurate and up to date is very important. You have access to your account information, which includes your contact information, in response to specific requests. If your account information is incomplete, inaccurate or not current, please call or write to us at the telephone number or appropriate address for such changes listed on your account information or other account materials. We will promptly update or correct any erroneous information.

5. Honouring your preferences

You have choices when it comes to how Diamond Concepts shares and uses information.

Sharing among the Diamond Concepts companies

You may request that Application Information, Consumer Report Information and Information from Outside Sources not be shared among Diamond Concepts companies. Information is shared among Diamond Concepts companies to complete applications for new products or services that you request, thereby saving you time, and to manage our business and risks. During the normal course of doing business, we will continue to share Identification Information, Transaction and Experience Information, as well as Other General Information among our companies.

For sharing among Diamond Concepts companies, each customer may tell us his or her preferences individually, or you may tell us the preferences for any other customers who are joint account owners with you.

Direct Marketing

You may choose not to receive direct marketing offers - sent by postal mail, telephone and/or e-mail - from Diamond Concepts. These preferences apply to all marketing offers from us and from companies working for us. Direct marketing offers from us may include information about products and services we believe may be of interest to you. If you choose not to hear from us, you may not learn about beneficial offers.

If you elect not to receive direct marketing offers by postal mail, telephone and/or e-mail, please note that we may continue to contact you as necessary to service your account and for other non marketing purposes. You may also be contacted from your client relationship manager or assigned account representative if applicable. Diamond Concepts may also continue to provide marketing information in your regular account mailings and statements, including online communications.

Each customer may opt out of each direct marketing option individually. Since marketing programs may already be in progress, it may take up to twelve weeks in some situations for your opt out to be fully effective in some situations. When you opt out of direct marketing by postal mail or telephone, your opt out will last for five (5) years. After that, you may choose to renew your opt out for another five year period.

6. Actions you can take

You can tell us your preferences by:

  • Notifying us at Diamond Concepts and entering your information on a secure Web site
  • Email us at Operations
  • Talking to a customer representative at a service centre or to your client relationship manager
  • When you contact us, please be prepared to provide the following information for each individual:
  • First name, middle initial and last name
  • Address, city, state and ZIP code
  • Account or reference number for third party sharing opt-outs
  • Telephone number (if applicable)
  • E-mail address (if applicable)

If any of these pieces of information change, other than your account number, please notify us to ensure that your preferences are consistently honoured.

Reducing direct marketing from other companies

You may contact the following agencies if you want to reduce the amount of advertising you receive from companies outside Diamond Concepts:

  • Credit Reporting Industry. To have your name taken off all pre-approved credit solicitations (not just Diamond Concepts solicitations), you may call the credit reporting industry Pre-screening Opt-Out number at 1.888.50PTOUT (1.888.567.8688).
  • National Do Not Call Registry. Diamond Concepts supports the National Do Not Call Registry. To have your phone number added to the National Do Not Call Registry, you may call 1.888.382.1222 or register at donotcall.gov. While this will stop most calls, you may still receive calls from businesses where you are a customer

7. Guarding your own information

Diamond Concepts recommends that you take the following precautions to guard against the disclosure and unauthorized use of your account and personal information:

  • Review your company and personal information regularly and report any suspicious activity to us immediately.
  • Report lost or stolen system identification and / or passwords immediately.
  • Memorize PINs (personal identification numbers) and refrain from writing PINs, Social Security numbers or credit card numbers where they could be found.
  • Tear up or shred any pre-approved offers to which you do not respond.
  • Review your identification report at least once every year. Make sure all information is up to date and accurate, and have information relating to fraudulent transactions deleted.
  • If you think you have been a victim of identity theft or fraud, contact one of the three major credit bureaus to place a fraud alert on your account. You may also contact the Federal Trade Commission (FTC) to report any incidents of identity theft and to receive additional guidance on steps you can take to protect yourself. You may contact the FTC at www.consumer.gov/idtheft

Keeping up to date with our Privacy Policy

As required by law, Diamond Concepts will provide notice of our Privacy Policy annually, as long as you maintain an ongoing relationship with us. To receive the most up-to-date Privacy Policy, you can visit our Web site at: www.Diamond-Concepts.com/privacy or call us at 1.888.341.5000.

We may make changes to this policy at any time and will inform you of changes, as required by law.

@2013 Diamond Concepts. Made from recycled paper. 00-06-321 7/2007.


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The eMINT Team.