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Comenity Capital Bank Privacy Policy for the PayPal Credit Payment System

Rev. September 2015

Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What? The types of personal information we collect and share depend on the product or service you have with us. This information can include:
  • Social Security number and income
  • Account balance and transaction history
  • Credit history and credit scores
When you are no longer our customer, we continue to share your information as described in this notice.
How? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Comenity Capital Bank chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information Does Comenity Capital Bank share? Can you limit this sharing?
For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus Yes No
For our marketing purposes – To offer our products and services to you Yes No
For joint marketing with other financial companies Yes No
For our affiliates' everyday business purposes - information about your transactions and experiences Yes No
For our affiliates' everyday business purposes - information about your creditworthiness No No
For our affiliates to market to you No No
For non-affiliated companies to market to you No No
Questions? Call: 1-866-528-3733. For operator relay assistance, first dial 711.
Who we are
Who is providing this notice? This privacy notice is provided by Comenity Capital Bank and is applicable to all PayPal Credit accounts.
What we do
How does Comenity Capital Bank protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
How does Comenity Capital Bank collect my personal information? We collect your personal information, for example, when you:
  • Open a PayPal Credit account or use your PayPal Credit account
  • Pay your bill or give us your contact information
  • Provide account information
We also collect your personal information from others such as credit bureaus, affiliates, and other companies
Why can’t I limit all sharing? Federal law gives you the right to limit only:
  • sharing for affiliates’ everyday business purposes – information about your creditworthiness
  • affiliates from using your information to market to you
  • sharing for non-affiliated companies to market to you
State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
What happens when I limit sharing for an account I hold jointly with someone else? We do not offer joint accounts.
Affiliates Companies related by common ownership or control. They can be financial and nonfinancial companies.
  • Comenity Capital Bank does not share with affiliates. However, our affiliates include companies with the Comenity name, and other nonfinancial companies, such as Epsilon, Alliance Data and LoyaltyOne.
Non-affiliated Companies Companies not related by common ownership or control. They can be financial and non-financial companies.
  • Comenity Capital Bank does not share with nonaffiliates so they can market to you. Nonaffiliates we share with can include financial service providers – like Bill Me Later, Inc. and PayPal, Inc. – retailers, direct marketers, publishers, and nonprofit organizations.
Joint Marketing A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
  • Our joint marketing partners include financial companies – like PayPal, Inc. – banks, or insurers.
Other Important Information
We will also comply with more restrictive state laws to the extent that they apply. For example, if your billing address is in Vermont or California, we will automatically opt you out of sharing your information with nonaffiliates for marketing purposes.