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Privacy Statement

The categories of nonpublic personal information that SMI collects - Personal information is information that is associated with your name or personal identity. SMI collects information from you for purposes including but not limited to establishing and maintaining a relationship, carrying out the terms of financial requests (including credit card/debit processing, credit granting and enquiries), offering and providing products and services, future promotions, rendering credit decisions, marketing services, complying with applicable law, protecting both the interests of yourself and SMI, for any other compatible purposes, and as may be necessary to enforce the foregoing. As an example, this may include any information provided by you or otherwise obtained in connection with reserving accommodations, including information from a consumer report. SMI uses such personal information to understand better your needs and interests and to provide you with better service. Once you choose to provide us with personal information, you can be assured it will be used only to support your customer relationship with SMI. We take seriously the trust you place in us. Specific personal information you provide to us may include name, address, phone number, e-mail address, drivers license, income, credit information inclusive of user IDs and passwords, billing and transaction information, credit card information, contact preferences, educational and employment background.

Categories of nonpublic personal information that SMI discloses - SMI discloses your personal information in order to provide you with services and to help us better understand your needs and interests, including use of your information to help you complete a transaction, to communicate with you, to provide service and support, to update you on services and benefits, and to personalize promotional offers. Occasionally we may also use your information to contact you for market research regarding SMI products or services. Credit card information is used only for payment processing and fraud prevention. Sensitive personal information may be disclosed to facilitate our financial service decisions. Personal data collected may be combined with information you provide SMI through other sources such as product registration, call centers or public events such as trade shows or seminars. For example, disclosures of nonpublic personal information may occur as necessary to effect, administer, or enforce a transaction requested or authorized by you in connection with: servicing or processing a financial product or service requested or authorized; maintaining or servicing an account as part of the extension of credit; and a proposed or actual securitization, secondary market sale or similar transaction. Personal data given to SMI may be transferred across country borders for the purposes of data consolidation, storage and simplified customer information management. SMI reserves the right to disclose categories of nonpublic personal information that it does not currently disclose.

Categories of affiliates and nonaffiliated third parties to whom SMI discloses nonpublic personal information - SMI may share your personal information with third parties in responding to your requests for products or services. SMI shares customer information across transaction related entities and companies working on our behalf, inclusive of credit grantors, consumer credit or personal reporting agencies. SMI also contracts with third-party service providers and suppliers to deliver complete products, services and customer solutions. For example, categories of affiliated and nonaffiliated third parties to which nonpublic personal information may be disclosed include non-financial companies such as direct marketers. Suppliers and service providers are required to keep confidential the information received on behalf of SMI and may not use it for any purpose other than to carry out the services they are performing for SMI. These service providers may change or we may contract with additional service providers to better accommodate our customers. SMI will also share personal information as required by law enforcement action, subpoena, or local law, and make disclosures to other nonaffiliated third parties as permitted by law. SMI or its related entities could merge with or be acquired by another business entity or some or all of their respective assets could be acquired, and if such a combination or acquisition occurs, SMI will make every reasonable effort to notify you in the event we share with the merging or acquiring entity some or all of your personal information to continue serving you. SMI reserves the right to disclose to categories of nonaffiliated parties to which it does not currently disclose nonpublic personal information. You may opt-out of disclosures of nonpublic personal information to nonaffiliated third parties, by way of contacting SMI at 800-786-4143 within 30 days of receipt of this notice. Opt-out for joint consumers obligations will require that all consumers notify SMI of their intention to opt-out.

Access to and accuracy of your information - SMI strives to keep your personal information accurate. We have implemented technology, management processes and policies to maintain customer data accuracy. We will provide you with access to your information, including making reasonable efforts to provide you with online access and the opportunity to change your information. To protect your privacy and security, we will also take reasonable steps to verify your identity, such as a password and user ID, before granting access to your data. Certain areas of SMI's websites may limit access to specific individuals through the use of passwords and other personal identifiers.

SMI's policies & practices with respect to protecting confidentiality, security and integrity of nonpublic personal information - SMI is committed to protecting the information you provide us. To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of the information, SMI has in place appropriate physical and managerial procedures to safeguard the information we collect.

Changes to this Statement - If there are updates to the terms of SMI's Privacy Statement, we will mail such revised notice to you or post those changes on our website and update the revision date in this document, so you will always know what information we collect, how we use it, and what choices you have. Rev. March 2010
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