PRIVACY POLICY FOR Brella(tm)

This privacy policy explains how we collect, share, use and protect information when you visit or use our online service and any other online services offered by SHAZAM websites and the Brella(tm) mobile banking application and website. Our goal is to maintain your comfort and trust when handling your personal information. SHAZAM is the sole owner of the information collected. We will not sell or rent this information to others.

Security of Personal Information

The security of your personal information is of high priority. We protect this information by maintaining physical, electronic and procedural precautions that meet applicable law and industry best practices. SHAZAM recommends that you verify you are on a secure site by looking for a closed lock icon at the bottom of your Web browser or by looking for "https" at the beginning of the address page. We equally train our employees in the proper handling of personal information.

Our online privacy statement does not cover:

1. What information do we collect?

We collect two types of online information: non-personal and personal.

Non-personal information

When you visit our site or application, we gather information such as unique or other device identifiers; device software and firmware information; device operating system type or model; browser characteristics, domain and other system settings; and the country, time zone and geo-location of your device.

Personal information

In addition to the information described in the previous section, we may also gather personal information you provide to us, such as your name, address, mobile number and email address. Collecting this personal information enables us to offer you online experiences that help you with your financial needs. For example: We collect personal information when you are:

o   Registering an account

o   Performing transactions with your account

2. How do we use the information we collect?

SHAZAM uses the information we collect about and from you to provide services, manage our business and to offer an enhanced, personalized online experience on our website/application.

The information we collect allows us to:o Recognize you when you return to our site so we can personalize your experienceo Process applications and transactions

o   Respond to your requests

o   Recognize and provide you with account-related benefits and informationo Respond to court orders and subpoenas

o   Directly market new product enhancements and offerings to you

We may also use personal information, such as your email or postal address, to deliver communications to you directly to elicit user feedback or notify you of future enhancements.

SHAZAM will not share, sell, or divulge personally-identifying information to any unaffiliated third party, except when disclosure is required to conduct our business, comply with applicable law, or when it is authorized by you. We maintain personally-identifying information you send us in accordance with our usual strict confidentiality standards on personally-identifying information.

Specific information and personally-identifying information you provide in an email as a comment, question, or response from our site is only used to answer your request or help us provide services to you. We reserve the right to contact you for additional information in response to an email you initiate. If you submit a resume via email, your resume is handled under the same confidentiality standards as resumes that are mailed or faxed.

If we have received personal information from you, or have information that is publicly available from other sources, we may use it in combination with the information that collects online. This information may be used to better tailor or personalize our service and communications with you, both online and offline. If you are communicated to and wish to no longer receive such communication, you may utilize the 'Unsubscribe' link at the bottom of the message. 'Unsubscribe' will not be available on the application alerts, as these are transactional based. If you would like to no longer receive any messages from, you must terminate your account.

If you are a customer, the personal information you provide online is held by the SHAZAM company (SHAZAM, Inc., ITS, Inc., and ITS Bank). The data collected is only shared with the institution that your debit account resides. You can access and/or change information in connection with your account or application by logging into your account online or contacting your participating financial institution.

Links to Other Sites

SHAZAM assumes no responsibility for the content of other Websites, which are not within SHAZAM's control. Links to other Websites which are provided on our Website, are for visitor convenience and information only. They are not intended to imply SHAZAM's endorsement of information, products, or services.

General Operations

• Non-Disclosure to Third Parties
• Disclosure Necessary to Transactions
• Disclosure of Business Statistics

SHAZAM will not disclose or divulge non-public personal information about any consumer to nonaffiliated third parties in connection with any financial product or service provided by SHAZAM to network participants that provide financial products and services to consumers and their customers. For purposes of this paragraph, the definitions of "non-public personal information", "non-affiliated third parties", "consumers", "customers", and "financial products or services" are as set forth in applicable federal and/or state laws and/or regulations including Section 504 of the Gramm-Leach-Bliley Act, Pub. L. 106-102, and any amendments thereto.

1. Can you control your information that is collected and used online?

It is critical to note that the information we use about you helps us provide you with products, services and experiences that benefit you. You have the ability to control how your non-personal information is collected and used online.

Email

When you provide your email address, we will use it to send you transaction alerts and system notifications. Customers whose email addresses have been provided to SHAZAM for the purpose of requesting another user to register can opt out of the use of their email address through the "Opt-Out" link provided in our registration request emails. Please keep in mind that we will continue to notify you by email.

Disclosure Necessary to Transactions

As a service provider, SHAZAM is authorized to disclose non-public personal information about a consumer performing EFT transactions to other parties that are necessarily involved with the transaction. The exchange of such information is necessary and appropriate in connection with the financial product or service being supported by SHAZAM. Pursuant to certain federal regulatory exceptions, there is no prohibition on a disclosure of such information by a financial institution, or by SHAZAM to another involved party to the EFT transaction, as necessary to perform transaction processing on behalf of the consumer. There is also no prohibition on disclosure of such consumer information that is appropriate or necessary in connection with the authorization, settlement, processing, or reconciliation of amounts that may be charged, debited, or otherwise paid using a transaction card.

SHAZAM may disclose such non-public personal information under the following circumstances:

• To each participant or agent of a participant that is a necessary party to the completion of the transaction.
• To any other person or entity that is a party to the transaction or is necessary to the completion of the transaction.
• In response to a written request of any regulatory authority with jurisdiction over financial institutions, processors, or SHAZAM.
• To any third-party auditor of the SHAZAM network if a compelling need to examine such transactions is demonstrated by the auditor.
• As required by law or a court with apparent jurisdiction.

Disclosure of Business Statistics

SHAZAM will not divulge to any third-party statistics on the business operations of any SHAZAM network participant without written consent of the participant. SHAZAM may compile and disclose, without limitation, total terminal statistics that are generic to the network and that do not contain specific information identifying particular participants or information concerning the operations of any participant.

Spam Email

The data in shazam.net email listings is provided by SHAZAM for information purposes only and to assist persons in obtaining information about or related to SHAZAM products and services. SHAZAM does not guarantee the accuracy or completeness of this data. By using this Web page, you agree to use the data only for lawful purposes and that under no circumstances will you use this data to: (1) allow, enable, or otherwise support the transmission of mass unsolicited, commercial advertising or solicitations via email, telephone, or facsimile; or (2) enable high-volume, automated, electronic processes that apply to SHAZAM (or its computer systems). The compilation, repackaging, dissemination, or other use of this data is expressly prohibited without the prior written consent of SHAZAM. SHAZAM reserves the right to terminate your access to the email listings or any other portion of its Website in its sole discretion, including (without limitation) for excessive querying of the Website or for failure to otherwise abide by this policy. SHAZAM reserves the right to modify these terms at any time. By using this Website, you agree to abide by this policy.

Contact Us

If you have any questions or concerns about the privacy statement or any other privacy concern, please contactlegalteam@shazam.net.