CELTIC BANK PRIVACY NOTICE

Legal Rights & Agreement Rules · Context

Celtic Bank provides this notice; no other entity is named

The form is Celtic Bank's FACTS privacy notice: the title asks what Celtic Bank does with the reader's personal information, and the 'Who is providing this notice?' entry names Celtic Bank. The supplied copy names no other entity, including Affirm, and it does not identify which Celtic Bank-issued accounts or programs it accompanies. That entry is the notice's statement of who provides it.

Supporting quotations

| FACTS | WHAT DOES CELTIC BANK DO WITH YOUR PERSONAL INFORMATION? |

| Who is providing this notice? | Celtic Bank |

Qualifications & exceptions

• The notice names only Celtic Bank; it does not mention Affirm or any product brand.

Not stated here

• Which Celtic Bank accounts or programs the notice accompanies is not stated in this copy.

Legal Rights & Agreement Rules · Context

Federal law supplies the notice's basis and a limited right to limit sharing

The 'Why?' entry says federal law gives consumers the right to limit some but not all sharing, and that federal law requires financial companies to tell consumers how they collect, share and protect personal information. The notice does not name the statute. The 'some but not all' scope is specified later under 'Why can't I limit all sharing?', which lists only three categories the right covers.

Supporting quotations

| 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. |

Qualifications & exceptions

• The text refers to 'Federal law' without naming a statute.

Cross-references

• narrowed by (model-proposed): The federal right to limit sharing covers three listed categories — The general statement that federal law gives consumers the right to limit some but not all sharing is narrowed by the later section listing only three categories the right covers.

Legal Rights & Agreement Rules · User right or choice

The federal right to limit sharing covers three listed categories

Under 'Why can't I limit all sharing?', the notice says federal law gives the consumer the right to limit only affiliate everyday-business sharing about creditworthiness, affiliate use of information to market, and nonaffiliate marketing. It adds that state laws and individual companies may give additional rights to limit sharing. Because the table answers NO to each of those three categories, the notice identifies no sharing in them that the federal right would limit. The notice also gives no opt-out form, address or online mechanism; it directs questions to 800.854.7848 and www.celticbank.com.

Supporting quotations

| 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 nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. |

| For our affiliates’ everyday business purposes— information about your transactions and experiences | NO | We don’t share |

| For our affiliates’ everyday business purposes— information about your creditworthiness | NO | We don’t share |

| For our affiliates to market to you | NO | We don’t share |

| For nonaffiliates to market to you | NO | We don’t share |

| Questions? | Call 800.854.7848 or go to www.celticbank.com |

Qualifications & exceptions

• State laws and individual companies may give additional rights to limit sharing.
• No opt-out form, mailing address or online mechanism is stated; the only contact channel is the phone number and website for questions.

Not stated here

• Which additional state-law rights apply to a particular consumer is not stated.

Cross-references

• narrows (model-proposed): Federal law supplies the notice's basis and a limited right to limit sharing — The general statement that federal law gives consumers the right to limit some but not all sharing is narrowed by the later section listing only three categories the right covers.
• refers to (model-proposed): Celtic Bank answers NO to all listed affiliate sharing — The limit section names affiliate creditworthiness sharing and affiliate marketing; the affiliate card records Celtic Bank's NO answers to those same categories.
• refers to (model-proposed): Celtic Bank does not share with nonaffiliates for their marketing — The limit section names nonaffiliate marketing; the nonaffiliate card records Celtic Bank's NO answer to that category.

Legal Rights & Agreement Rules · Procedure

Questions go to a phone number and the Celtic Bank website

The notice's stated channel for questions is the telephone number 800.854.7848 or www.celticbank.com. The supplied copy does not provide an opt-out form, a privacy-specific mailing address or an online privacy-request mechanism.

Supporting quotations

| Questions? | Call 800.854.7848 or go to www.celticbank.com |

Legal Rights & Agreement Rules · Context

The notice shows a January 2015 revision marker and no effective date

Both pages carry 'Rev. January 2015'. The supplied copy states no separate effective date, announces no successor version and includes no linked policy text. The revision label is therefore the only date in the document; it does not by itself establish when the notice took effect or whether it remains the current version.

Supporting quotations

Rev. January 2015

Rev. January 2015

Qualifications & exceptions

• A revision label is not proof of an effective date or current in-force status.

Not stated here

• Effective date and current applicability are not stated in the supplied copy.