Important Information About Your Financial Privacy
The financial products and services of FIA Card Services, N.A. are endorsed by hundreds of financial institutions. We back our products and services with top-quality service. Collecting and sharing data about you helps us do this. This notice explains the data collection and sharing practices of FIA Card Services, N.A. and its affiliate, IFIA Insurance Services, Inc. (collectively "FIA"). It also lets you choose whether FIA may share certain data about you.

This notice describes the privacy practices of FIA for consumer financial products and services governed by the laws of the United States of America and all state insurance privacy laws that apply. It applies to open, closed and inactive accounts with these entities.

Our Security Procedures Protect Your Data
Keeping financial data secure is one of our most important jobs. We maintain physical, electronic and procedural safeguards to protect customer data. Appropriate employees are authorized to access customer data for business purposes only. Our employees are bound by a code of ethics that requires private treatment of customer data and are subject to discipline if they fail to follow this code.

Data We Collect to Conduct Our Business
We collect data about you to conduct our business, assist us in keeping information up to date, and deliver the top-quality service you expect. Sources include:

• data we receive from you;
• data we receive from third parties, such as consumer reporting agencies, to verify statements you’ve made to us, or regarding your employment, credit, or other relationships. We also may obtain data from insurance support groups not connected with us. These groups may prepare and provide reports to others as well as to us;
• data about your transactions with FIA and with other companies.

Data Shared Internally
We may share internally all the Data we collect within the FIA family of companies. The FIA family of companies is made up of a number of companies. These companies include:

• financial service providers (such as our brokerage company, insurance company and agency, and credit card company); and
• nonfinancial companies (such as our operations and servicing subsidiaries).

For example, we may share:

• ID data (such as name and address);
• transaction and experience data (such as purchases and payments);
• credit eligibility data (such as credit reports); and
• other data.

You may tell us not to share credit eligibility data about you within the FIA family of companies, as explained in the section captioned, Data Sharing: It’s Your Choice. Your choice will not affect the sharing of ID and transaction and experience data.

We may receive medical or health data from you when you apply for insurance from us. We do not share medical or health data, including data we receive from third parties, among our companies, except to:

• maintain or collect on accounts;
• process transactions;
• service customer requests; or
• perform insurance tasks to the extent allowed by law.

Data Shared Outside of Our Family of Companies
FIA may share all the data we collect with the following types of nonaffiliated third-party companies:

• financial service companies (such as banks, insurance companies, and organizations with which we have joint marketing agreements);
• nonfinancial companies (such as retailers, direct marketers, communications companies, and travel companies), except for data about IFIA Insurance Services, Inc. customers;
• companies performing marketing or other services for us (such as data processing or direct mail services); and
• other companies (such as nonprofit organizations), except for data about IFIA Insurance Services, Inc. customers.

FIA may also share all of the data we collect with outside companies as permitted by law.

You may tell us not to share data about you with a nonaffiliated third party, as explained in the section captioned, Data Sharing: It’s Your Choice. Your choice will not affect sharing with:

• companies performing marketing or other services for us;
• other financial institutions under joint marketing agreements;
• government entities in response to subpoenas or regulatory requirements;
• law enforcement agencies for fraud prevention or investigation;
• consumer reporting agencies; and
• as otherwise permitted by law.

Federal law requires us to provide this notice on an annual basis, whether or not you previously opted out. Please remember that if you previously opted out an account, you do not need to opt out for that account again.

You may have other privacy protections under state laws. We will comply to the extent applicable.

For Vermont (VT) and California (CA) residents only. The data-sharing practices described above are in accordance with Federal law. VT and CA law place additional limits on sharing data about VT and CA residents so long as they remain residents of those states.

For VT Customers
In accordance with VT law, FIA will not share data we collect about VT residents to nonaffiliated third-party companies except:

• with the authorization or consent of the VT resident;
• to companies that perform marketing or other services on our behalf;
• name, contact and transaction and experience data (such as your account balance and payment history) to other financial institutions with which we have joint marketing agreements; or
• as permitted by law.

FIA will not share credit and insurance eligibility data about VT residents within the family of companies except with the authorization or consent of the VT resident.

For CA Customers
To the extent required by CA law, FIA will not share data we collect about CA residents with companies outside of the FIA family of companies except:

• with the consent of the CA resident;
• to service the customer’s accounts;
• to fulfill on rewards or benefits; or
• as permitted by law.

We will limit sharing among the FIA family of companies to the extent required by applicable CA law. For Insurance Customers Residing in AZ, CA, CT, GA, IL, ME, MA, MN, MT, NV, NJ, NC, OH, OR and VA: We may give customer data related to insurance transactions (Insurance Data) to insurance support companies and other like businesses. Such companies may keep the Insurance Data or give it to others.

We may also give Insurance Data to:

• state insurance officials;
• law enforcement agencies;
• group policyholders about claims experience; and
• auditors as allowed by law.

We may give health data:

• to decide if you are eligible for insurance;
• to process claims;
• to prevent fraud;
• as allowed by you; or
• as allowed by law.

You may ask for access to the Insurance Data that we have about you by writing to Insurance Services, PO Box 19702, Irvine, CA 92623-9702, Attn: Data Request. You will need to describe the type of Insurance Data you want to access. You must also give your full name, address and policy number (if you have one). We will tell you the types of Insurance Data we have about you. If you want to see the Insurance Data, you may review and copy the data in person at our offices. Or you may ask for a copy to be sent to you by mail. You may not see data that we deem privileged, such as data about claims or lawsuits. We may charge a fee for sending the data to you by mail.

To correct data that we have about you, send a written request as described above. Say why you dispute the data. We will tell you of our action with respect to this dispute. You may file a statement with us if you disagree with our decision.

For MA Insurance Customers: You may ask in writing the specific reasons for an adverse underwriting decision. An adverse underwriting decision is where we:

• decline your application for insurance;
• offer to insure you at a higher than standard rate; or
• terminate your coverage.

Keeping Data Accurate
You can make sure data is accurate by:

• accessing your account information (for example, on a statement or in response to specific requests); and
• telling us if it is incorrect by calling or writing to us at the telephone number or appropriate address for such changes on your statement or other account materials.

Updates and Additional Data
This notice replaces any previous notices from FIA about the privacy, security, and protection of data. You may have other privacy protections under state laws. We may amend this privacy notice at any time. We will inform you of changes as required by law.

Tips to Protect Your Data
FIA works hard to keep your data secure. You can help by following these tips to protect your data:

• Store personal data in a safe place and tear up or shred old receipts and account statements before throwing them away.
• Protect your PINs and other passwords. Do not share them with anyone unless it’s for a service or transaction you request.
• Do not respond to e-mails requesting account numbers, passwords or PINs. Call the institution to verify the legitimacy of the e-mail.
• Carry only the minimum amount of identifying data you require.
• Pay attention to billing cycles and statements. Inquire if you do not receive a bill.
• Check account statements carefully to ensure all charges, checks, or withdrawals are authorized.
• Guard your mail from theft. Do not leave bill payment envelopes in your mailbox with the flag up. Instead, deposit them in a post office collection box or at the local post office. Promptly remove incoming mail.
• Order copies of your credit report from each of the three major credit bureaus once a year to ensure they are accurate.
• If you believe you are a victim of identity theft, take action right away. Keep records of your phone calls and e-mail or letters. While the steps you must take will vary with your individual circumstances, four basic actions are appropriate in almost every case:
• Contact the fraud departments of any one of the three major credit bureaus to place a fraud alert on your credit file:
• Equifax (www.equifax.com): 1-888-766-0008 / P.O. Box 740241, Atlanta, GA 30374-0241
• Experian (www.experian.com): 1-888-397-3742 /P.O. Box 9532, Allen, TX 75013
• TransUnion (www.transunion.com): 1-800-680-7289 / P.O. Box 6790, Fullerton, CA 92834
• Contact the creditors for any accounts that have been tampered with or opened fraudulently.
• File a report with your local police or the police in the community where the identity theft took place and get a copy of the police report.
• File a complaint with the FTC. Complaints can be filed by phone 1-877-IDTHEFT or through the FTC's identity theft Web site at ftc.gov/idtheft.

Although many consumers appreciate the convenience and customer service of direct marketing:

• If you prefer not to receive pre-approved offers of credit and insurance, you can opt out of such offers by calling 1-888-5-OPT OUT.
• 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.

©2009 FIA Card Services N.A.