Our Commitment to Privacy

EFSTS Online Privacy Statement
Effective December 5, 2005

OUR COMMITMENT TO PRIVACY
EFS Transportation Services, Inc. ("EFSTS") is a subsidiary of First Data Corporation. Protecting consumer privacy is very important to us. This Online Privacy Statement is available to inform you about our collection and use of personal and non-personal information so that you can make informed choices about how your own information is collected and used. Currently, this EFSTS Online Privacy Statement is only applicable to customers and visitors in the United States who visit our website. This Online Privacy Statement reflects the EFSTS policies covering personal information collected by us on or after the effective date shown above.

We believe that information used responsibly benefits consumers and the economy, whether it is information we house on behalf of consumers conducting transactions or information we collect on behalf of our business clients. The relationships we have developed through the years have been established based on mutual trust. Each day strive to reinforce our commitment to our clients and consumers. Central to that commitment is ensuring that we abide by a set of privacy policies, which are outlined below. These policies guide us in the collection and use of information as well as employee responsibilities in protecting your privacy. We use personal information about consumers only in a manner consistent with these policies.

COLLECTION OF INFORMATION
EFSTS collects personal and non-personal information in order to offer or provide goods and services to consumers and our customers. We may obtain this information from a variety of sources:

> Directly from customer applications, questionnaires and other materials submitted to us by customers;
> From transactions in which EFSTS and consumers are involved;
> From clickstream activity on our web sites (including the use of "cookies" and or "web beacons," as discussed below); and
> From a variety of third-party sources, such as our business customers, government repositories, consumer reporting agencies and financial institutions.

USE OF COOKIES AND WEB BEACONS
A "cookie" is a small text file placed on your computer's hard drive by a web server and which is acknowledged by your web browser. "Web beacons" are transparent electronic images placed in the web code, also called "clear GIFs" or "Web bugs." We use cookies and/or web beacons for a variety of purposes, including, but not limited to, the following:

> To assist us in providing our services to you;
> To allow you to change pages during your visit to our website without repeatedly having to re-enter your password;
> To track activity on our website;
> To determine whether you came to our site from a banner ad or an affiliate website; or
> To serve ads to you on this and other websites.

You can usually set parameters on your computer that allow you to elect to accept cookies or to have your browser notify you each time a cookie is offered. You can also usually delete cookies from your hard drive. Instructions on how to accept cookies, on how to be notified that a cookie is being offered and on how to delete cookies are available through your Internet Browser.

DISCLOSURE OF INFORMATION
EFSTS does not disclose an individual’s information to third parties without first giving the individual an opportunity to opt-out of certain kinds of disclosures. There are some disclosures to third parties that are not subject to the opt-out, such as disclosures necessary to effect, administer or enforce a transaction requested by you, to companies that perform services for us or to prevent fraud. In addition, EFSTS may disclose customer information to companies that, like EFSTS, are part of the First Data corporate family. Finally, EFSTS may disclose information about former customers to third parties and companies with which EFSTS is affiliated, as well as unaffiliated third parties. Those disclosures may consist of the following:

> Financial background information describing a customer's financial status;
> Identification information, such as name and address data;
> Transaction information, such as account activity, debit activity or credit activity; and
> Other information relating to financial matters.

RECIPIENTS OF INFORMATION
EFSTS may disclose consumer information to companies affiliated with EFSTS and to companies or other parties not affiliated with EFSTS (subject to consumers' opt-out rights). These recipients include:

> Financial institutions, such as banks, credit card companies and brokerage houses;
> Retailers, such as home furnishers, clothing stores and florists;
> Companies that process transactions or provide other services for us;
> Government agencies; and
> Catalogue companies and other direct marketers.

In addition, under federal law EFSTS is permitted to disclose customer information to certain recipients, such as credit reporting companies.

WE ARE COMMITTED TO PROTECTING THE CONFIDENTIALITY OF PERSONAL CONSUMER INFORMATION.
EFSTS limits access to personal information to those employees of EFSTS and its affiliates who need it to fulfill their business responsibilities. Employees must adhere to EFSTS privacy policies. Employees violating these policies may be subject to disciplinary action, up to and including dismissal. Vendors and other outside contractors we engage are subject to our contractual requirements to ensure that sensitive personal information is safeguarded.

WE USE APPROPRIATE SECURITY SAFEGUARDS.
At EFSTS, security is a priority. We employ appropriate measures to protect consumer information against unauthorized access, disclosure, alteration or destruction. These may include, among others, encryption, physical access security and other appropriate technologies. EFSTS continually reviews and enhances its security systems, as necessary.

WE MAINTAIN PROCEDURES TO ASSURE THE QUALITY OF INFORMATION WE COLLECT AND WHERE APPLICABLE, WE WILL INFORM CONSUMERS ABOUT HOW THEY CAN ACCESS THEIR PERSONAL INFORMATION AND MAKE CORRECTIONS, IF NECESSARY.
EFSTS employs appropriate measures to assure the quality of information we collect directly from consumers. Where information is collected by EFSTS directly from consumers or sources other than our business customers, we permit them, if possible, to dispute or correct any erroneous or out-of-date personally identifiable information. Of course, this correction would not be possible if the information is proprietary to one of our business customers, reflects historical transaction information or if correction would violate the privacy or legal rights of a third party. Where applicable, we abide by laws related to such information. You can correct factual errors in your personally identifiable information by sending us a written request that credibly shows error. Call the customer service number listed below for details. We reserve the right to independently verify claims made. To protect your privacy and security, we also will take reasonable steps to verify your identity before making corrections. We reserve the right to assess a service charge for providing you with any information in connection with your request.

THE EFSTS WEBSITE IS NOT DIRECTED AT CHILDREN UNDER THE AGE OF 13.
Our website is not directed at children under the age of 13 and EFSTS does not collect or maintain information at our website from those we actually know are under the age of 13.

EFSTS' WEBSITE MAY BE LINKED TO OTHER WEBSITES
EFSTS may create links to third party websites. EFSTS is not responsible for the content or privacy practices employed by websites that are linked from our website.

OPT OUT RIGHT (NON-VERMONT CONSUMERS)
EFSTS may disclose consumer information to third parties as described earlier in this notice. Many of these disclosures are beneficial to consumers because they permit goods and services of interest to consumers to be offered to consumers at attractive rates. We strive to give consumers choices about how their data will be used. You have the right to opt-out of (direct us not to make) these disclosures when the consumer information is about you. Of course, there are some disclosures to third parties that are not subject to the opt-out, such as disclosures necessary to effect, administer or enforce a transaction requested by you, to companies that perform services for us or to prevent fraud.

If you wish to opt out, simply call the customer service number listed below. You always have the right to change your mind. If you do not opt out, we'll assume that you have agreed that EFSTS may use your personal information to determine what goods and services you may be interested in, offer you goods and services that we think meet your needs, disclose your personal information to third parties, and for the other purposes described herein.

EFSTS maintains the information it collects on each transaction for a fixed time period. In the event you perform a transaction and exercise your right to opt out, your information and your opt out decision will be maintained for the fixed time period. In the event you do not perform another transaction during the fixed time period, your personal information, as well as your opt out election, will be removed from our records. After the removal of your information from our records, you will have to exercise your right to opt out again if you provide us with your information again.

VERMONT CONSUMERS
EFSTS will not disclose nonpublic personal information about you to nonaffiliated third parties (other than as permitted by law) unless you authorize us to make that disclosure. Your authorization must be in writing, or, if you agree, in electronic form. If you wish to authorize us to disclose your nonpublic personal information to nonaffiliated third parties, you may either write to us at 7000 Goodlett Farms Pkwy - 2nd Floor, Cordova, TN 38016-4916, or send us an email at webmaster@concordefs.com. Your written or electronic authorization must contain your name, address and signature and state that you authorize us to disclose your nonpublic personal information to nonaffiliated third parties. You may revoke your consent at any time by calling us at (866)841-9315 or by writing or emailing us at the addresses provided above.

PERMISSION MARKETING EMAILS
Beyond communications required as part of terms of service (order confirmations, shipping details, etc.), users will occasionally receive information on products, services, special deals, and/ or a newsletter via email. Users who no longer wish to receive our email newsletter and promotional email communications may indicate such wish by contacting us via email at webmaster@concordefs.com or by contacting our customer service center at (866) 841-9315.
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WE HOLD OURSELVES ACCOUNTABLE TO OUR PRIVACY PRINCIPLES.
If you have any questions or comments about EFSTS's Online Privacy Statement, or for some reason believe we have not adhered to our statement, please contact us at the customer service number listed below.

As stated above, this EFSTS Online Privacy Statement is currently only applicable to our website customers and visitors in the United States. As we develop websites for international audiences, we may adopt additional rules and practices consistent with this statement to conform to the policies or requirements of those countries. We may alter this statement as needed for certain products and services and to abide by local laws or regulations around the world. EFSTS reserves the right to amend or modify this statement from time to time. We urge you to review this statement whenever you visit in order to obtain the most current statement. You may change your choices at any time.

EFSTS Customer Service (866) 841-9315

 

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