Your privacy and the security of your personal information are very important to us. We are dedicated to protecting the privacy of those who visit our website at www.safeguardcredit.org (the “Website”). This Privacy Policy governs the Website and explains how your personal information is collected on our Website, how your information is protected, and the choices you have concerning the use of such information. Please read this Privacy Policy carefully.

We may amend this Privacy Policy from time to time. We will post any changes to this Privacy Policy here so that you will always know what information we gather, how that information may be used, and whether that information will be disclosed to anyone. Please refer back to this Privacy Policy on a regular basis. By using our Website or any of our products, offerings, features, tools or resources that we provide on our Website (collectively, our "Online Products"), you agree to the terms of this Privacy Policy.

In addition, we will notify current Safeguard Debt Management Program registered Users (“Registered Users”) by e-mail of any changes in our Privacy Policy that may affect the types of information that we share with third parties and the parties with which we share such information.

POLICY REGARDING INFORMATION SUBMITTED TO SAFEGUARD AT THIRD- PARTY WEBSITES

In addition to users of the Website, this Privacy Policy applies to you if you submit personal information through our contact form available at a website other than the Safeguard Website.

WHAT INFORMATION ABOUT YOU IS COLLECTED ON OUR WEBSITE?

We collect two types of information: personally identifiable information and non-personally identifiable information.

Personally Identifiable Information

Personally identifiable information (“PII”) is information that allows you to enroll and receive benefits in the Debt Management Program (“DMP”) offered by the Safeguard through the Website. During the enrollment process we collect a wide variety of personal and financial data.

Such PII may include:

Debt information is used to qualify the applicant for the DMP and to make payments on a Registered User's behalf. Budget information is collected to provide the Registered User with an overview of where Registered Users’ money is spent and is required by the Creditors. The data for those applicants who do not complete the enrollment process is kept for internal analysis only.

We are committed to protecting the privacy of minors. Our Website is not designed for or directed to visitors under the age of 18. We do not collect PII from any person we actually know is under the age of 18. We urge all parents or guardians to participate in their children's exploration of the Internet, and to teach their children about protecting their personal information while online.

In general, we use the information collected on our Website to help us understand who uses our Website and how it is used, to personalize your online experience, to complete your enrollment in a DMP, to assist you in using our services, and to improve upon them.

If you become a Registered User, we may use your information to send you a welcoming e- mail that confirms your User name and password. We may send you electronic newsletters, contact you about products, services, information and news that may be of interest to you, and provide you with targeted feedback. In compliance with the Graham-Leach-Bliley Act, as a Registered User you will receive a separate privacy notice sent to you at the e-mail address submitted in your application, (the “GLB Notice”). In addition, we will send any further required notices to the Registered User’s same e-mail address.

Opt-out Policy

If you prefer that we do not send you e-mail communications, you may opt-out of those services, that is, you may direct us not to use your e-mail address as part of our marketing efforts for new products and services. If you wish to opt-out of e-mail communications, you may do so by emailing us, by replying to an existing email with your request to be removed from the mailing list or call 1-800-673-6993. In addition, if you identify yourself to us by sending us an e-mail with questions or comments, we may use your information (including PII) to respond to your questions or comments, and we may file your questions or comments for future reference. The GLB Notice will instruct Registered Users as to how they may opt-out from the sharing of their PII with third parties.

We may also use the information gathered to perform statistical analysis of Registered User behavior, to analyze and evaluate issues relating to the DMP, enrollment behavior and credit education, or to evaluate and improve our services. We may link some of this information to PII for internal purposes only or to assist you in your debt reduction efforts.

WHEN DOES OUR WEBSITE DISCLOSE INFORMATION TO THIRD PARTIES?

The PII of Registered Users may be disclosed to third parties only as described in the GLB Notice. In addition to receiving the GLB Notice via e-mail, the GLB Notice also appears on our Website. In short, the GLB Notice discloses that all of the PII collected on our Website may be disclosed (both to affiliates and to non-affiliates) unless the Registered User chooses to opt- out from such disclosure. However, even if a Registered User chooses to opt-out from such disclosure, the PII collected on this Website may be disclosed to certain parties as permitted by law. For example, the PII of Registered Users will be disclosed to certain third parties, such as credit card companies, if disclosure is necessary to effectuate or administer the DMP and to other third party service providers and financial institutions with whom Safeguard maintains
joint marketing agreements.

IS THE INFORMATION COLLECTED ON OUR WEBSITE SECURE?

We want your information (including personally identifiable information) to remain as secure as possible. We strive to provide secure transmission of your information from your computer to our servers through industry-standard techniques. To help ensure the integrity and privacy of the personally identifiable information you provide to us via the Internet, we use Secured Socket Layer (SSL) encryption technology in transmitting such PII over the Internet to our servers. We secure the PII you provide on servers located in controlled, secure environments, protected from unauthorized access, use, or alteration. Only employees who need access to your information to perform a specific task or function are granted access to such information.

No personal data is ever stored on our web servers. Sensitive information is encrypted within our database, to ensure internal security. In addition, all of our employees must abide by this Privacy Policy and are kept up-to-date on security practices. Any employee who violates this Privacy Policy is subject to disciplinary action, up to and including termination.

Notwithstanding the above commitments to protect your information (including PII) from loss, misuse or alteration by third parties, you should be aware that there is always some risk involved in transmitting information over the Internet. There is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your information, we cannot ensure or warrant the security and privacy of any information you transmit to us, and you do so at your own risk.

CAN I UPDATE OR CORRECT MY PERSONALLY IDENTIFIABLE INFORMATION?

You can always contact us in order to update, correct or delete your PII or change your preferences with respect to communications and other information you receive from us by calling Safeguard Customer Service at 1-800-673-6993. Such updates, corrections and deletions will not have an effect on the data we are required to maintain by any creditors in order to administer the DMP.

You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our system. The need to back-up our systems to protect information from inadvertent loss means that a copy of your PII may exist in a non-erasable form that will be difficult or impossible for us to locate. We promise that promptly after receiving your request, all PII stored in marketing databases we actively use and other readily searchable media will be updated, corrected, changed or deleted, as appropriate, as soon as reasonably practicable.

LIMITATIONS

While our Privacy Policy covers all DMP applicants, Safeguard’s DMP is only available for residents of the United States. Registered Users must make payments from a US bank account, have a US residence and any DMP-associated debt must be for US-based liabilities and payable in US currency.

HOW WILL I KNOW IF THERE ARE ANY CHANGES TO THIS PRIVACY POLICY?

If we decide to change this Privacy Policy, we will post those changes on our Website so you are always aware of what information we collect, how it is used, and under what circumstances, if any, it is disclosed. If at any point PII will be used in a manner significantly different from that stated in this Privacy Policy, or otherwise disclosed to you, at the time it was collected, we will prominently post any changes on our website for 30 days prior to any change. We may also make non-significant changes to our Privacy Policy that generally will not affect our use of your NPPI. If you are a Registered User, you will be notified by e-mail. If you do not agree to the terms of this Privacy Policy, you are not permitted to use or submit PII at our Website.

If you have any questions about our Privacy Policy or feel that we are not abiding by the terms of our posted Privacy Policy, please contact our Privacy Coordinator by calling 1-800-673- 6993.

Opt-Out Third Party Sharing of Information

I instruct SafeGuard not to share my nonpublic personal information with unrelated third parties.

Name:

Address:

Account Number:

Phone Number:

Signature:

Please print and mail this form or call us at the above number. If you would like to submit your information via email click here.

SafeGuard Credit Counseling Services-Telemarketing Do Not Call Policy

State and federal law requires companies which intitiate telemarketing sales calls to institute policies and procedures for maintaining a list of telephone numbers of consumers who do not wish to receive telephone solicitation calls. In compliance with the requirements, SafeGuard has established the following "do-not call policy" to be followed by all persons making telephone solicitations on its behalf.

• SafeGuard maintains a do-not call list that contains telephone numbers of consumers who either; (i) request directly from SafeGuard or persons calling on its behalf not to be called again for any solicitations or; (ii) have requested to be included in either the national do-not call registry or a similar state-maintained registry.
• For requests made directly to SafeGuard, such request is maintained for a period of five (5) years. Regarding requests maintained by the consumer placing its telephone number on a state or federal registry, SafeGuard subscribes to these lists, receives updates as frequently as required by applicable state and federal law, and does not call numbers appearing on the then-current list.
• No telemarketing agent shall place any telephone solicitation call to any telephone number without first ensuring that the telephone number has been checked against the then-current do-not call list maintained by SafeGuard. NO HAND DIALING OF TELEPHONE NUMBERS FOR TELEPHONE SOLICITATIONS IS ALLOWED.
• At the beginning of every telemarketing sales call, the telemarketing agent shall clearly state; (i) his or her first and last name; (ii) that he or sheis calling on behalf of SafeGuard; (iii) the nature of the call; (iv) the telephone number and (v) the address at which SafeGuard may be contacted.
• When a telemarketing agent receives a request from a consumer to not receive future telemarketing calls, the telemarketing agend shall; (i) immediately record teh request on the telephone consumer's file in the computer; (ii) immediately record the subscriber's name, address and telephone number on the manual request sheet that is subsequently returned to the agent's supervisor at the end of each shift; (iii) politely inform the consumer that his or her request has been recorded and that is takes approximately 3 business days after receipt of the request to remove the customer's telephone number form SafeGuard's telemarketing lists; (iv) end the call.
• Upon request by any consumer, SafeGuard shall promptly foward to the consumer a written copy of this telemarketing policy. All such requests shall be recorded in the computer and on the manual request sheet provided to the supervisor at the end of each shift. In the event any consumer requests an address to which the consumer may make a written request for the do-not call policy of SafeGuard, the telemarketing agent shall inform the consumer that written requests should be made to: SafeGuard, Do Not Call List, 112 Parkway Drive South, Hauppauge, NY 11788
• In the event any consumers indicatea desire to terminate the call, the telemarketing agent must immediately and politely comply with the request: thank the consumer for their time and end the call.
• Consumers must inform SafeGuard of any change in telelphone number if they desire to place a new phone number on SafeGuard's internally generated do-not call list.
• SafeGuard does not share or disclose a consumer's do-not call request with external parties.
• Any person involved with telemarketing for SafeGuard is trained, informed and directed to comply with applicable state and federal do-not call requirements as well as SafeGuard do-not call policy. Failure to comply with the do-not call policy is grounds for termination of the business relationship between SafeGuard and the telemarketing agent.