Privacy/Legal

EnCircle has the highest regard for the privacy of its customers. As a result, we safeguard the personal information of our customers in all areas of our business. We regularly assess our business activities to ensure that customer privacy is respected. We will conduct our business in a manner that fulfills our promise to all of our customers.

Information Collection:

EnCircle will limit the collection and use of personal information to the minimum we require to deliver superior products and service to our customers, which may include advising our customers about our products, services and other opportunities and to administer our business. This information may be collected from a variety of sources, such as:


	Information we receive from you on forms and applications, and through other means, such as over the telephone or through online registrations;
	Information about your transactions and account experience with us, our affiliates or others;
	Information we receive from consumer reporting agencies or other outside sources regarding your credit worthiness, employment or other relationships; and
	Other general information we may obtain such as demographic information.

EnCircle strives to keep our customer files complete, up-to-date and accurate. At your request, we will supply your account information, unless prohibited by law. If you have a question or concern about the accuracy or completeness of your personal information, notify us and we will promptly make any required corrections.

Information Use and Disclosure:

EnCircle will use personal information, as appropriate in the normal course of our business, to service your accounts. We will also use personal information to identify you, to communicate with you, to help us respond to your questions and to understand which ENCIRCLE products and services will best meet your needs.

Disclosure to Service Your Account:

EnCircle may disclose all of the personal information that we collect, as described above, in order to establish, administer and manage your accounts, to our affiliates and the following types of non-affiliated third parties:


	Financial and non-financial companies that perform services on our behalf such as check printing, data and transaction processing or companies that assist us in marketing our products and services to you or with whom we have joint marketing agreements; and
	Others, such as credit reporting agencies and similar organizations.

EnCircle may also disclose personal information about you, as permitted by law, to non-affiliated third parties in connection with a subpoena or similar legal process, a fraud investigation, to record a public record or as part of an audit or examination.

Disclosure to Offer Products and Services EnCircle may share all of the personal information that we collect, as described above, with our affiliates and the following types of non-affiliated third parties, in order to deliver products and services that you have requested or to communicate with you about EnCircle and our products and services.

EnCircle does not sell personal information to third parties for the purpose of solicitation or provide personal information to third parties for their own, independent use.

Disclosure to Affiliates:

EnCircle obtains credit account performance information about you from non-affiliated third parties, as permitted by law. EnCircle also maintains credit account performance information with respect to our experience with you. We are permitted by law to share our own account experience with you with our affiliates. You may direct us not to share other credit-related information, such as information shown on a consumer credit report, with our affiliates, by contacting us at the telephone number and address listed on your account statement, bank records or other documentation.

Former Customers:

If you decide to close your EnCircle account(s) or if your account(s) become inactive or closed for some other reason, we will continue to safeguard your personal information as described in this document.

Information Security:

Only authorized EnCircle employees, who are trained in the proper handling of customer's personal information. Employees who violate our privacy policy will be subject to our disciplinary procedures.

EnCircle maintains physical, electronic encryption and procedural safeguards to protect personal information and complies with the National Automated Clearing House Association guidelines regarding the security of electronic transactions. We continually assess new technology for protecting information and upgrade our systems when appropriate.

Whenever EnCircle hires other organizations to provide us or our customers with services, we require them to conform to our customers with services, we require them to conform to our privacy standards, to allow us to audit them for compliance and to enter into a confidentiality agreement that restricts the use of personal information to those purposes intended and prohibits independent use of the information.