Privacy Policy

The Privacy Policy explains the following:

• Protecting the confidentiality of our customer information
• Who is covered by the Privacy Policy
• The types of information we have about you and where it comes from
• The types of information we share, why and with whom
• Special Notice to customers with accounts involving Program "Partners" and to Credit Card customers
• Opting out how to instruct us not to share certain information about you or not to contact you

Protecting the Confidentiality of Customer Information

We take our responsibility to protect the privacy and confidentiality of customer information very seriously. We maintain physical, electronic and procedural safeguards store and secure information about you from unauthorized access, alteration and destruction. Our control policies, for example, authorize access to customer information only by individuals who need access to do their work. From time to time, we enter into agreements with other companies to provide services or make products and services available to you. Under these agreements, we act as the clearinghouse for the offer of these services or products in order to ensure that information about you is safeguarded by our secure information system.

Who is Covered by the Privacy Policy

We provide our Privacy Policy to account holders and clients on our web site. If we change our privacy policies to permit us to share information we have about you, as described below, or to permit disclosures to additional types of parties, you will be notified in advance.

This Privacy Policy applies to clients or former clients of Gibraltar Capital. Clients who receive information from us or transact business with us through the Internet are covered by the privacy policies posted on the website.

The types of information we have about you and where it comes from

Gibraltar Capital receives information about you from various sources, including information from:

• Your requests or applications for products or services

• Your transactions with us

• Consumer reporting agencies (credit bureaus), such as your credit history

• Emails to us from you

The types of information we share, why and with whom

We may share limited information we have about you, as described above, to give you superior customer service, provide convenient access to our services and make a wider range of products available to you. We share this information in the following ways:

Sharing Information for Legal and Routine Business Reasons and for Joint Marketing. We may disclose information we have about you as permitted by law. For example, we may share information with regulatory authorities and law enforcement officials; provide information to protect against fraud; report account activity to credit bureaus; share information with your consent and give account information to check and statement printers and other service providers who work for us. We may also share limited information we have about you, as described above, with firms within the Gibraltar Capital family of companies as fulfillment providers for our financial products and services. For example, we may share information about you with an insurance firm in order that you may receive offers concerning various insurance products.

Sharing Information among the Gibraltar Capital Family of Companies. The Gibraltar Capital family of companies offers a wide array of financial products and services such as loans, deposits, investments and insurance. We may share information we have about you, as described above, such as identification, application and credit bureau information, and transaction and account balance information among the Gibraltar Capital family of companies. Some of the benefits to you of this sharing may include account upgrades based on our more complete knowledge of your total relationship, improved customer service and responsiveness and detection of unusual behavior to help prevent unauthorized transactions or fraud. You may, however, instruct us not to share some of this information among the Gibraltar Capital family of companies for lawful purposes. If you instruct us not to share information, we may continue to share other information among the Gibraltar Capital family of companies, including identification information (such as name and address) and limited information regarding your transactions or experiences with us (such as account balance and trading history), as well as survey or similar information conducted by us.

Special Notice to customers with accounts involving Program "Partners" and to Credit Card customers

"Partner" Accounts: You may choose to participate in a program where we "partner" with a prominent company, such as a risk management provider or financial institution outside the Gibraltar Capital family of companies. When you choose to participate in a program like this, the name or logo of the program "partner" is prominently displayed on the program materials or website. These programs may combine our products or services with those of other companies to give you a distinctive service or other benefits. For example, you may have a credit card from Gibraltar Capital, or our credit card issuer, offering you to do business with a bank that has arranged for us to issue credit cards to its customers. We share information we have about you, as described above, with these program "partners". Our "partners" use that information for purposes related to the "partner" program, for example to service your account, administer the program and update their records. Our "partners" may also use that information for marketing purposes unrelated to the program. You may, however, instruct us not to share personally identifiable information about you with our partners for marketing purposes unrelated to the "partner" program.

Credit Card Customers: Gibraltar Capital periodically reviews its own information regarding its customers, their credit card accounts and transactions to select customers to receive special offers from companies outside the Gibraltar Capital family of companies with whom we have marketing relationships and who offer non-financial products and services. These offers, which we believe will be of interest to you, may be for products or services such as travel programs, legal services, or product/service fulfillment clubs. Information provided to companies making these offers is limited to name, address, telephone number, and email address. You may, however, instruct us not to share this information about you with companies outside the Gibraltar Capital family of companies for these marketing purposes.

Please Note: : If you instruct us not to share information as described above we may continue to share limited information for purposes of for Legal and Routine Business Reasons and for Joint Marketing" and in "Sharing Information among the Gibraltar Capital Family of Companies.

“Opting out”..How to instruct us not to share certain information about you or not to contact you

• Your Right to Opt Out. You may instruct us not to share information about you, as described in this Privacy Policy.

• How To Opt Out: To opt out, simply notify us in writing through our Contact Us system, and save a copy for your records.