Privacy Policy Notice

First Bank of Delaware - Privacy Notice
Effective May 31, 2008

Because your trust is so important to us
Your trust is the cornerstone of our relationship.  That is why we work so diligently to safeguard your privacy.  First Bank of Delaware is committed to providing you with the best service and respecting your privacy at the same time.  In our effort to provide you with enhanced financial services, First Bank of Delaware may work with affiliates and non-affiliated third parties to provide you with products and services designed to assist you in meeting your financial goals.  In order to fulfill this goal, we may share information about you with affiliates or non-affiliated third parties.

The following Privacy Notice explains how we use and protect the information about our customers.  We ask that you read it carefully.

Notice of Your Financial Privacy Rights
We, our, us, or Bank when used in this Notice, means First Bank of Delaware

This is our Privacy Notice for our customer related to your credit card account with us.  When we use the words, “you” and “your” we mean the following types of customers:

Our consumer customers who have a continuing relationship by purchasing or holding financial products or services such as these credit cards:

• Continental Finance® Gold MasterCard® Credit Card
• Continental Finance® Classic MasterCard® Credit Card

We will tell you the information we collect about you and the measures we take to secure that information.  We first define some terms:

Non-Public Personal Information
Nonpublic personal information means information about you that we collect in connection with providing a financial product or service to you.  Nonpublic personal information does not include information that is available from public sources, such as telephone directories or governmental records.  Hereinafter, we will use the term “information” to mean nonpublic personal information as defined in this section.

Affiliate
An affiliate is a company we own or control, a company that owns or controls us, or a company that is owned or controlled by the same company that owns or controls us.  Ownership does not mean complete ownership, but means owning enough to have control.

Non-Affiliated Third Parties
A person we do not employ or a company that is not an affiliate of ours.

The Confidentiality, Security and Integrity of Your Information
We restrict access to your personal account information to those staff members who need to know that information in order to provide products and services to you.  Examples of how we protect your information include, but are not limited to, the following:

• Restricting physical or other access to  your personal information to persons with a legitimate business need to know the information;
• Contractually requiring third parties doing business with us to comply with privacy and security laws;
• Maintaining physical, electronic, and procedural safeguards that comply with federal standards to guard your personal information.

The Information We Obtain
Since some of the information we obtain about you is not publicly available, we take great care to ensure that the information is protected from unauthorized access and is not shared in violation of any regulation or law.  We may obtain this type of information about you from the following sources, among others:

• Information you give us on applications or other forms;
• Information about your transactions with us, our affiliates or nonaffiliated third parties;
• Information from a consumer reporting agency;
• Information we receive as a result of verifying customer information;
• Information you provide when you register for our Internet website or use our online services;
• Communications we have with you, including by telephone, fax, mail, e-mail, or face-to-face contact.

Information That We May Disclose
We carefully select the companies that provide services on our behalf, or offer you financial services that we do not provide.  In order to optimize your relationship with us, we may share nonpublic information we collect about you as follows:

• Information we receive from you on applications or other forms in connection with our products and services (including for example, your name, address, social security number, date of birth, assets and income);
• Information about your transactions with us, an affiliate or others (including for example, your account balance, payment history, and  credit or debit card usage); and
• Information we receive from a consumer reporting agency (including for example, your creditworthiness and credit history).

Parties With Whom We May Share Nonpublic Personal Information
We may share nonpublic personal information about you with the following types of parties as permitted by law (which may be an affiliate or a nonaffiliated third party):

• Financial services providers, such as mortgage and insurance companies;
• Non-financial companies, such as direct marketers, retailers and publishers; and
• Others, such as nonprofit organizations.

Information We May Share With Service Providers and Joint Marketers
We may have agreements with certain companies to jointly offer financial products that the Bank does not directly provide.  These companies are prevented by contractual provisions from using this information for their own purposes or selling this information to others.

In order to provide you with information about additional products and services, we may disclose the following information to companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements:

• Information we receive from you on applications or other forms, such as your name, address, telephone number, social security number, and date of birth;
• Information about your transactions with us, our affiliates, or others, such as your account balance, types of accounts, or payment performance; and,
• Information we receive from a consumer reporting agency, such as your creditworthiness and credit history.

Information About Former Customers
All information conveyed herein with respect to how we use or disclose nonpublic personal information shall also apply to former customers.

Fair Credit Reporting Act
Under the Fair Credit Reporting Act, we are permitted to share your name, address, and facts about your transactions with us (such as your payment history and other transactions on your accounts with us) with companies affiliated with First Bank of Delaware. 

Tips to Help You Protect Your Customer Information and Assistance to Victims of Identity Theft
If you believe you may be a victim of identity theft, please follow the following procedures:

• If you suspect that someone has had unauthorized access to your account with us, or access to your personal identifying information such as your social security number or credit/debit card information, please call us immediately at 1-888-FBD-3511 so we can take action to protect you.  Our website also provides additional information regarding “Customer Security Awareness” --Please visit our website at http://www.fbdel.com/.

• You should also report the crime to your local law enforcement agency and to the Federal Trade Commission (“FTC”).  To speak with a trained FTC telephone counselor, call toll-free at 1-877-IDTHEFT (1-877-438-4338).  Or to enter information about your complaint into a secure FTC online database, sign onto www.ftc.gov/idtheft.  The site also provides links to numerous consumer education materials. 

• Contact the Social Security Administration’s Fraud Hotline toll-free at 1-800-269-0271 to report any suspected fraudulent use of your identification information.

• Report the incident as quickly as possible to any one of the credit reporting agencies:

  Experian:        888-397-3742
  Equifax:          800-525-6285
  Tran Union:     800-680-7289

• You should obtain and review a current credit bureau report to identify any unauthorized accounts or inquiries and ask the credit reporting agency about placing a “Victim Alert Flag” on your files.

Your Privacy Rights & Choices
Federal law gives you the right to limit some but not all marketing from our affiliates.  Federal law also requires us to give you this Notice to tell you about your choices to limit marketing from our affiliates. 

You may limit our affiliates from marketing their products or services to you based on your personal information that we collect and share with them.  This information includes your income, your account history with us, and your credit score. 

You have the right to restrict the sharing of personal and financial information with our affiliates(s) and outside companies that we do business with.  Nothing in the Notice prohibits the sharing of information as permitted by law.  This includes sending you information about some other products or services. 

If you have no objection to our sharing of information about you as described in this Notice, you do not have to do anything.  If you have previously opted not to allow us to share your information, again, you do not have to do anything as that election will continue to be honored until you tell us to change your choice. Your election will also apply to all individuals with whom you hold joint accounts.

Please remember that if we are not permitted to share non-transaction information about you with our affiliates, it may affect our ability to help you fulfill your financial goals and the way we manage our relationship with you.

If you wish to opt-out of our sharing of information about you, please complete the following “Your Choices” form in its entirety and return it to:

First Bank of Delaware
c/o Continental Finance Company, LLC
Attention:  Privacy Choice Processing/Operations
P.O. 8099 Newark, De 19714-8099

---------------------- CUT HERE & RETURN BOTTOM PORTION ONLY ----------------------
(PLEASE RETAIN PRIVACY NOTICE FOR YOUR RECORDS)

YOUR CHOICES (Please State Your Choices Below):

Restrict Information Sharing With Companies We Own or Control (Affiliates)
Unless you “Opt-Out” below, First Bank of Delaware may share non-transaction (other than transaction or experience information) personal and financial information about you with our affiliated companies.

______ Yes, I want to “Opt-Out” of sharing – Please do not share my non-transaction personal and financial information with your affiliated companies. 

Restrict Information Sharing With Other Companies We Do Business With
Unless you “Opt-Out” below, First Bank of Delaware may share personal and financial information about you with outside companies we contract with to provide financial products and services to you.

______ Yes, I want to “Opt-Out” of sharing – Please do not share my personal and financial information with outside companies you contract with to provide financial products and services.

NAME:  _____________________________________________________________________
(Please Print)

SIGNATURE: ________________________________________________________________
 

ACCOUNT(s):  _______________________________________________________________
(Account Numbers to be Provided by Customer)

Time Sensitive Rely: You may make your Privacy Choice(s) at any time.  Your Privacy Choice(s) marked here will remain unless you state otherwise.  However, if we do not hear from you, we may share some of your information with affiliated companies and other companies with whom we have contracts to provide products and services.

Special Notice to Vermont and California Customers: If you have a Vermont or California mailing address, we will automatically limit the disclosure of your information to affiliated and non-affiliated companies.

Other State Privacy Laws:  We will also comply with all other state privacy laws to the extent that they apply to First Bank of Delaware.