We collect only customer information that is needed, and we tell customers how we use it. We limit the collection of information about our customers to what we need to know to administer their accounts, to provide customer services, to offer new products and services, and to fulfill any legal and regulatory requirements. We tell our customers about the general uses of information we collect about them, and we will provide additional explanation if customers request it.

We give customers choices about how their data will be used. On a regular basis, we give our customers the option to decide whether or not they wish to have their names added or removed from lists used for mail, telephone and online marketing. These opt-in and opt-out choices include product and service offers from Janastar and those made in conjunction with our business partners.

We ensure information quality. We use advanced technology and well-defined employee practices to help ensure that customer data is processed promptly, accurately and completely. We require high standards of quality from the consumer reporting agencies and others who provide us with information about prospective customers.

We use information security safeguards. Access to customer data is limited to those who specifically need it to conduct their business responsibilities. We use security techniques designed to protect our customer data -- especially when certain data is used by employees and business partners to fulfill customer services.

We limit the release of customer information. In addition to providing customers with the opportunity to op- out of marketing offers, we release information only with the customers' consent or request, or when required to do so by law or other regulatory authority. When a court order or subpoena requires us to release information, we notify the customer promptly to give the customer an opportunity to exercise his or her legal rights. The only exceptions to this policy are when we are prohibited by court order or law from notifying the customer, or cases in which fraud and/or criminal activity is suspected.

We are responsive to customers' requests for explanations. If we deny an application for our services or end a customer's relationship with us, to the extent permitted by applicable laws, we provide an explanation, if requested. We state the reasons for the action taken and the information upon which the decision was based, unless the issue involves potential criminal activity.
We extend these privacy principles to our business relationships. We expect the companies we select as our business partners to honor our privacy principles in the handling of customer information. These include companies that (a) assist us in providing services to our customers; (b) supply us with information for identifying or evaluating prospective customers; or (c) are given the opportunity to send mailings to approved Janastar customer lists. In selecting business partners, Janastar considers the accuracy and quality of the data they provide, how they respond to consumer complaints and whether or not they provide opt-out choices for those whose information they process. We also participate actively in industry associations to support strong and effective privacy guidelines and practices.