Privacy Policy

At Early Warning Services, LLC (“Early Warning”), we recognize that ensuring the privacy and security of customer information is vitally important to our continued success. When we receive or work with personal information about individual customers of our customers, we recognize that it is given to us for the very limited purpose of meeting our customers’ needs. We will safeguard such customer information by adhering to the following guidelines:

Collection, Use, Sharing and Retention of Customer Information

We will collect, use, share and retain personal information about individual customers of our customers solely in order to provide services to our customers and solely pursuant to operating rules distributed to our customers. In addition to our privacy policy, our use of certain personal information about consumers is also subject to the requirements of the Fair Credit Reporting Act (“FCRA”) and other applicable privacy laws. We will maintain the confidentiality of customer information except when disclosure is authorized or legally required.

Maintenance of Accurate Information

We will employ appropriate measures to ensure customer information is processed accurately, completely and timely in accordance with the requirements of applicable laws and the standards set forth in the operating rules. We will always respond to requests to correct inaccurate information in a timely manner.

Limiting Access to Customer Information

We will limit access to customer information to those employees and agents who need it to fulfill their legitimate business responsibilities. We will educate our employees to comply with the requirements of the FCRA and other applicable privacy laws, as well as Early Warning’s privacy and information security policies. Early Warning will take appropriate disciplinary action to enforce employees’ privacy responsibilities. We will ensure that, where appropriate, vendors and other outside contractors we engage are subject to contractual requirements to ensure that customer information is appropriately safeguarded.

We Use Appropriate Security Safeguards

We are committed to meeting the highest standards in privacy and information security. To that end, Early Warning has appointed a senior officer who has responsibility for company-wide administration and implementation of our privacy and information security policies. The Chief Data, Risk and Security Officer, working closely with individual business units, is responsible for administering employee training related to Early Warning’s privacy and information security policies and conducting periodic assessments of Early Warning’s compliance with its privacy and information security policies.

We may alter this policy as needed for certain products and services and to abide by applicable laws.