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“Borrower” means all borrowers obtaining a loan with Tower Loan. “Lender” means Tower Loan and its affiliated lending companies. “Insurance Companies” means American Federated Insurance Company and American Federated Life Insurance Company, affiliates of Lender that may provide insurance coverage on Lender’s loans. Lender and the Insurance Companies are separate companies that are in the same corporate family and may be jointly referred to herein as “Group.”
Confidentiality and Security
Group is committed to safeguarding its customers’ financial information and has established policies and practices that respect the privacy of its customers. Group restricts access to protected information (known as “nonpublic personal information”) to its employees who need to know that information in order to provide products or services to its customers. Group maintains physical, electronic, and procedural safeguards that comply with federal regulations to guard nonpublic personal information from unauthorized use. As permitted or required by law, Group may disclose certain types of nonpublic personal information about its current and former customers to its affiliates and to nonaffiliated third parties.
Types of Information Collected
Group may collect, retain and use nonpublic personal information from about Borrower from the following sources:
- Information received on Borrower’s applications or other forms, such as Borrower’s name, address, social security number, assets, and income;
- Information about Borrower’s transactions with Lender, the Insurance Companies, their affiliates or others, such as account balances and payment histories; and
- Information from consumer reporting agencies and other creditors during the loan approval process, such as credit histories.
Information Sharing Practices
Group restricts the types of information that it shares and the types of entities with whom such information is shared. Group’s reason for sharing information is to make its customers transactions more convenient and to give its customers more choices about financial services and products. Group may disclose all of the above information about Borrower that it collects, except that Group does not disclose information received from consumer reporting agencies and other creditors to nonaffiliated third parties.
Parties to Whom Group Discloses
Group may disclose nonpublic personal information about Borrower to the following types of third parties:
- To the affiliates within Group and to Group’s affiliates such as its parent holding company and to its affiliated finance companies. All affiliates are separate companies that adhere to the same strict standards that Lender uses to make sure that customer information is safe and secure;
- The administrative agent to the Insurance Companies who performs account administration, processes insurance claims and premium payments, and performs other functions necessary to effect and administer insurance coverage that the Borrower requested or authorized;
- Nonaffiliated financial service providers such as other creditors who seek information necessary to effect a transaction that Borrower has requested or authorized;
- Nonaffiliated service providers, such as direct marketers, who do not sell this information to third parties and are restricted by contract from doing so; and
- Others, such as attorneys who conduct transactions for Lender and Borrower and maintain confidentiality.
Group also may disclose nonpublic personal information about Borrower to nonaffiliated third parties as permitted or required by law, such as in response to a court summons or subpoena, to protect against fraud, to a consumer reporting agency in accord with the Fair Credit Reporting Act, and in other situations.
The law permits Group to share with its affiliates information about its experiences or transactions with Borrower or Borrower’s account (such as Borrowers account balance and payment history with Group). Unless Borrower directs otherwise, the law also permits Group to share with its affiliates information that it receives in applications, from credit reporting agencies and other creditors. Borrower may direct Group not to disclose information that does not relate solely to Lenders experiences or transactions with Borrower or Borrower’s account by “opting out” following the directions below.
Except for information received from consumer reporting agencies and other creditors, Lender may disclose all of the information that it collects about Borrower (as described above) to companies that perform marketing services on Lender’s behalf with whom Lender has contractual agreements. Lender’s contract prohibits these companies from using or disclosing the information that Lender provides to them except as necessary to carry out Lender’s marketing services or to the extent otherwise permitted by law. The Insurance Companies disclose no nonpublic personal information to third party marketing services.
Opt Out Rights
Borrower can exercise the opt out rights described at any time during the course of its customer relationship. Borrower’s decision will last in perpetuity, unless changed in writing by Borrower or Borrower’s legal representative. Even if Borrower opts out, the law permits, and business purposes require, that Group shares certain information about Borrower. If two or more co-borrowers jointly obtain a loan or other product or service from Group, one Borrower may opt out on behalf of all of the co-borrowers, or, if the co-borrowers prefer, each Borrower may opt out separately.
Opt Out for Nonaffiliates
Group’s ability to share information about its customers with nonaffiliated third parties enables Group to offer more products and services and makes it more convenient for customers to do business with Group. If Borrower prefers that Group not disclose nonpublic personal information about Borrower to nonaffiliated third parties, Borrower may opt out of those disclosures; that is, Borrower may direct Group not to make disclosures (other than disclosures permitted by law) by signing and mailing an “Opt Out Notice” to Group. The notice should include your name(s) and social security number(s) and request the lender and/or insurance companies NOT share your nonpublic personal information, except as required or permitted by law, and should be mailed to: Tower Loan, P.O. Box 320001, Flowood, MS 39232-0001.
Opt out for Affiliates
Group’s ability to share information about customers with its affiliates enables Group to offer better products and services that meet customer needs. If Borrower chooses to prohibit the sharing of Borrower information among Group’s affiliates, Borrower may miss out on receiving valuable communications and services. Borrower cannot limit Group’s ability to share among its affiliates information about Group’s experiences or transactions with Borrower or Borrower’s account. Group is permitted by law to share that information, however, by signing and mailing an “Opt Out Notice” to Lender, Borrower can direct Group to share with its affiliates only Borrower’s account information, information needed to process transactions or provide services that the Borrower has requested or initiated and any other information required or permitted by law.