We Are Committed to Safeguarding Customer Information
In order to better serve your needs now and in the future, we may ask you to provide us with certain information. We understand that you may be concerned about what we will do with such information - particularly any personal or financial information. We agree that you have a right to know how we will utilize the personal information you provide to us. Therefore, we have adopted this Privacy Policy to govern the use and handling of your personal information.

Applicability
This Privacy Policy governs TrueConnect Loans and our use of nonpublic personal information about you. This Privacy Policy does not govern publicly available information we obtain about you.

Types of Information
We collect nonpublic personal information about you from the following sources:
• Information we receive from you on the TrueConnect Loan application web site
• Information we receive from your employer via periodic payroll census/eligibility file extracts
• Information confirmation we receive from a third party identification verification service

Use of Information
We request certain information from your employer to continually qualify your eligibility for the TrueConnect Loan program. Only active employees, who meet specific income and employment tenure thresholds, are eligible for TrueConnect Loan offerings and the data received from your employer’s payroll system is required to independently verify this eligibility. We do not receive or store such specific information from your employer, such as social security number or bank account information, which would potentially compromise your online security. This payroll based information is received from your employer on an ongoing basis in order to accurately assess your eligibility for TrueConnect Loan offerings at any point in time. Information received directly from you is further used to authenticate your identity with a third party service in compliance with Federal consumer lending law and to facilitate the transfer of TrueConnect Loan funds to a bank account of your choosing.

Former Customers
Even if you are no longer our customer, our Privacy Policy will continue to apply to you.

Confidentiality and Security
We will use our best efforts to ensure that no unauthorized parties have access to any of your information. We restrict access to nonpublic personal information about you to those individuals and entities who need to know that information to provide products or services to you. We will use our best efforts to train and oversee our employees and agents to ensure that your information will be handled responsibly. We currently maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.

Information Obtained Through Our Internet Site
TrueConnect Loans is sensitive to privacy issues on the Internet.

We believe it is important you know how we treat the information about you we receive on the Internet. In general, you can visit the TrueConnect Loans Internet site without telling us who you are or revealing any information about yourself. Our Internet servers collect the domain names, not the e-mail addresses, of visitors. This information is aggregated to measure the number of visits, average time spent on the site, pages viewed and similar information. TrueConnect Loans uses this information to measure the use of our site and to develop ideas to improve the content of our site.

Should you choose to apply for a TrueConnect Loan, we will first assess your eligibility by authenticating your employment. You will be required to enter several pieces of personally identifiable information about yourself (not social security number) in order for us to look up and verify your employment status and income/tenure eligibility.

Should you pass eligibility tests for the Bank to offer TrueConnect Loan products, you will be required to provide proof of your identity to a third party confirmation service as part of the federal Customer Identification Program (CIP). This will require you to submit your social security number. TrueConnect Loans will use this data for this purpose in accordance with section 326 of the USA PATRIOT Act of 2003.

Once you are fully qualified as eligible and your identification is confirmed, you will be offered one or more qualifying TrueConnect Loan offers. Upon selecting your desired loan product, you will provide a bank account routing and account number in order to facilitate the transmission of approved loan funds to a destination of your choosing.

Upon completion of these steps, TrueConnect Loans will transmit your personal information to test in order for them to establish your new loan on their loan making system. You may access their privacy policy here: 2013_Sunrise_Banks_Privacy_Policy1.pdf

Upon transmission of your personal information to test, TrueConnect Loans will purge your social security number and bank account information from our storage.

Your Contact Information
Your personal contact information, such as telephone numbers, mailing address, or email addresses are not sold or distributed to third parties outside of the purpose of qualifying your eligibility, funding, or servicing TrueConnect Loan. It is our policy to hold your personal information strictly for these purposes.


Last Updated December 21, 2013

This is a contract. By using this website you agree to be bound by these terms. These Terms of Use contain an agreement to arbitrate all Claims as well as disclaimers of warranties and limitations of liability. These provisions form an essential basis of our bargain. Please read these terms carefully. If you do not agree to these terms, do not access or use this website.

1. Acceptance of Terms Through Use. Sunrise Banks makes the TrueConnect Loan application process available on the website and via email subject to the following terms and conditions of use (the "Terms of Use"). These Terms of Use also apply to any updates, enhancements and new features and products. By using this website, you represent to TrueConnect Loans that you have read, understood, and agree to all terms, conditions, and notices contained or referenced in these Terms of Use and on the website and agree to follow all applicable laws and regulations.

2. Changes in these Terms of Use. TrueConnect Loans may modify these Terms of Use from time to time by posting modified Terms of Use on the website. Your continued use of the website and any emails thereafter will constitute agreement to such modifications. At the time of any material modifications, TrueConnect Loans will change the "Last Updated" date below. Please review these Terms of Use from time to time so that you are apprised of any changes.

3. Registration & Use. By registering with this website and providing requested data during the application process, you understand and agree that you have established a business relationship between you and TrueConnect Loans. BY REGISTERING ON THIS WEBSITE AND PROVIDING REQUESTED INFORMATION, YOU AGREE THAT TRUECONNECT LOANS QUALIFY YOUR EILIGIBILITY FOR A TRUECONNECT LOAN BASED ON DATA SUPPLIED FROM YOUR EMPLOYER AND DIRECTLY BY YOU. You further agree that TrueConnect Loans may offer you eligible loan products based solely on a third party bank’s underwriting rules executed by TrueConnect Loans at the time of your application. You agree that TrueConnect Loans will electronically authenticate your identification with a qualified third party service in accordance with Federal small lending regulations. You finally agree that any loans offered to you and selected by you will entail transferring personal information about you to the bank issuing the loan in order to legally establish the TrueConnect Loan on the bank’s loan making system.