Halliday Privacy Notice

Consumer Privacy Notice

Halliday International, Inc. ("Halliday")

Facts	What does Halliday do with your personal information?
Why?	Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?	The types of personal information we collect and share depend on the product or service you have with us. This information can include: Government identification number and income Account balances and payment history Credit history and credit scores When you are no longer our customer, we continue to share your information as described in this notice.
How?	All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons Halliday chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information	Does Halliday share?	Can you limit this sharing?
For our everyday business purposes— such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, report to credit bureaus, or as otherwise permitted by law	Yes	No
For our marketing purposes— to offer our products and services to you	Yes	No
For joint marketing with other financial companies	No	We don't share
For our affiliates' everyday business purposes— information about your transactions and experiences	No	We don't share
For our affiliates' everyday business purposes— information about your creditworthiness	No	We don't share
For our affiliates to market to you	No	We don't share
For nonaffiliates to market to you	No	We don't share

Who we are
Who is providing this Privacy Policy?	This privacy notice is provided by Halliday International, Inc. (“Haliday”) and is applicable to your personal Halliday account.

What we do
How does Halliday protect my personal information?	To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We restrict our employees' access to your information so that it is only accessible when they need it to do their work, and we require companies that work for us to protect your information.
How does Halliday protect my personal information?	We collect your personal information, for example, when you provide us your contact information open an account, provide account information, login to your Halliday account, or use Halliday services link your bank account, credit, or debit card to your Halliday account We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
Why can't I limit all sharing?	Federal law gives you the right to limit only sharing for affiliates' everyday business purposes— information about your creditworthiness affiliates from using your information to market to you sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. See below for more information on your rights under state law.

Definitions
Affiliates	Companies related by common ownership or control. They can be financial and nonfinancial companies. Halliday has no affiliates.
Nonaffiliates	Companies not related by common ownership or control. They can be financial and nonfinancial companies. Nonaffiliates with which we share personal information include service providers that perform services or functions on our behalf, including our bank partner(s).
Joint Marketing	A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Halliday has no joint marketing agreements.

Other important information
For Alaska, Illinois, Maryland, and North Dakota Customers: We will not share personal information with nonaffiliates either for them to market to you or for joint marketing without your authorization. California Residents: We will not share your information with non-affiliated third parties, except for our everyday business purposes, for marketing our products and services to you, with your consent (as required), or as otherwise permitted by law. For Massachusetts, Mississippi, and New Jersey Customers: We will not share personal information or share relationships with nonaffiliates either for them to market to you or for joint marketing without your authorization. Vermont Residents: We will not share your information with non-affiliated third parties, except for our everyday business purposes, for marketing our products and services to you, with your consent (as required), or as otherwise permitted by law. We will not disclose creditworthiness information about you within or outside Halliday except as permitted by law, unless we otherwise obtain your consent.

Other important information

For Alaska, Illinois, Maryland, and North Dakota Customers: We will not share personal information with nonaffiliates either for them to market to you or for joint marketing without your authorization.

California Residents: We will not share your information with non-affiliated third parties, except for our everyday business purposes, for marketing our products and services to you, with your consent (as required), or as otherwise permitted by law.

For Massachusetts, Mississippi, and New Jersey Customers: We will not share personal information or share relationships with nonaffiliates either for them to market to you or for joint marketing without your authorization.

Vermont Residents: We will not share your information with non-affiliated third parties, except for our everyday business purposes, for marketing our products and services to you, with your consent (as required), or as otherwise permitted by law. We will not disclose creditworthiness information about you within or outside Halliday except as permitted by law, unless we otherwise obtain your consent.