Our customer information privacy policy, detailed in this statement, serves as the standard for all Global Data Solutions Inc employees in the collection, use, sharing, retention, and security of individual customer information.

Without compromising your privacy, we also wish to offer you, from time to time, superior products and services that we believe can help you achieve your objectives. We believe we can do this by observing our policy.

Expectation of Privacy

Safekeeping of customer information is a high priority at Global Data Solutions. We will continue to maintain the high standards necessary to ensure that your information is kept private and secure at all times.

If you discontinue using our services or becoming an inactive customer, we will continue to adhere to this privacy policy.

Maintenance of Accuracy

We strive to maintain complete and accurate information about you and your accounts. Should you believe that our records contain inaccurate or incomplete information about you, please notify us at the telephone number listed in the “Where to Call” section at the end of this statement. We will correct any inaccuracies.

Global Data Solutions Information Management Practices

Information about customers is accumulated from a variety of sources. You provide some information. We record other information, such as your account history, and still other information is obtained from outside sources, such as affiliates and credit reporting agencies.

We limit the collection and use of information about customers to the data necessary to administer our business, provide superior service and offer opportunities we believe may benefit our customers. We use some information to help identify and mitigate potential risks or loss to us. We also use customer information to identify a likely interest in particular products or services. We use this information only in accordance with our policy.

Limitation of Employee Access

Company employee access to information about individual customers is limited to those with a business reason to have such access. Employees are made aware of our privacy policy and trained in procedures that maintain confidentiality. Employees who violate provisions of the privacy policy are subject to disciplinary action.

Information Security Protection

Global Data Solutions safeguards information about you according to established security procedures designed to prevent unauthorized access. We continually assess new information protection technology. We use commercially reasonable efforts to ensure that your information is stored and maintained in a secure environment. We have implemented procedures to ensure that your information is only made available to such designated staff as necessary to carry out the stated purposes that we have communicated to you.

Types of Personal Information Collected

In conducting business with Global Data Solutions, we collect and maintain various types of information about our customers, including:

• Identification information (contact numbers, dates of birth, addresses, and PIN codes);
• Information regarding your credit worthiness and credit capacity (financial statements, employment information, credit history, and income and expenses);
• Account activity information; and
• Information regarding your financial situation that allows us to recommend our products and services.

Global Data Solutions uses this personal information only for business purposes consistent with ethical business practices and in compliance with applicable laws and regulations. We do not share any of the information that we collect with third parties.

Information Use by Global Data Solutions

The company may use your personal information as follows: Within Global Data Solutions and Affiliated Companies:

• As a security measure, to prevent unauthorized persons from accessing your accounts.
• To conduct business safely and soundly.
• We may share information about our experience and transactions with you amongst GDS’s family of companies as permitted by law.
• In satisfying legal requirements, such as for tax reporting, as required by state and federal government.
• In determining which products and services may best serve your needs. Some of these services may be offered through our affiliates.
• We do not share medical or health information among our family of companies or with other third parties except to process transactions or to provide services you have requested.

With Unaffiliated Third Parties:

Global Data Solutions does not reveal customer account information or provide other personally identifiable information to unaffiliated companies for their independent use.

As Permitted by Law:

The company may legally share customer account information or other personally identifiable information with
unaffiliated companies when:

• They assist by contract in providing data products and services.
• Information sharing is in the normal course of business, e.g., with credit reporting agencies.
• The law requires company cooperation, e.g., fraud investigation, subpoena, or a request by an authorized government regulator.
• “Due diligence” is performed during a merger, acquisition or sale.
• A customer has earlier been informed of the possible disclosure of information for marketing or similar purposes and given an opportunity to decline (“opt out”).

Customer Privacy in Third Party Relationships

When we provide customer information to a third party, as permitted by law, we insist–through a written agreement–that the third party maintain the confidentiality of that information.

Marketing of Global Data Solutions Products and Services

From time to time, the Company may promote its products and services directly to customers. If you do not want to receive these offers, you may ask the company not to include you by following the “opt-out” procedures below.

Ways to Limit the Company’s Use or Disclosure of Your Personal Information

We, at Global Data Solutions, have developed this policy statement because we want you to understand and trust our commitment to confidentiality and to further understand how we use personally identifiable information. If you have questions about the privacy of your information, please call us at the telephone number listed in the “Where to Call” section at the end of this statement.

Opt–Out Procedures

To instruct the company not to:

• provide nonpublic personal information about you to unaffiliated companies offering products and/or services,
• share information from your account or outside sources among our family of companies, or
• provide information to you about the companies products and services,

Contact us at the number listed in the “Where to Call” section below.

Where to Call

For questions about our privacy policy or to speak to our Chief Privacy Officer Stephen Pachikara, please contact us at 267.210.9320. Global Data Solutions reserves the right to amend this privacy policy at any time. You will be given prior notice of any change.