American Express Prepaid Cards

Sharing & Disclosure · Context

How the sharing table is organized

The notice says all financial companies need to share customers' personal information to run their everyday business, and that the table lists the reasons financial companies can share, the reasons American Express chooses to share, and whether you can limit that sharing. The table has three columns: the reason for sharing, whether American Express shares, and whether you can limit this sharing. The next cards read it row by row.

Supporting quotations

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 American Express chooses to share; and whether you can limit this sharing.

Does American Express share?

Can you limit this sharing?

Qualifications & exceptions

• Each row answers the two questions only for that row's reason.

Sharing & Disclosure · Company practice

Sharing for everyday business purposes

American Express says it shares personal information for its everyday business purposes, such as processing your transactions, maintaining your accounts, responding to court orders and legal investigations, and reporting to credit bureaus. The table answers "No" to whether you can limit this sharing.

Supporting quotations

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

Qualifications & exceptions

• The listed activities follow "such as", so they are examples.

Not stated here

• The notice does not say which recipients receive information for these purposes.

Sharing & Disclosure · Company practice

Sharing for American Express's own marketing

American Express says it shares personal information for its own marketing purposes, to offer its products and services to you. The table answers "No" to whether you can limit this sharing through that row, but points you to the "To limit direct marketing" box for additional privacy choices.

Supporting quotations

For our marketing purposes – to offer our products and services to you

Yes | No (but please see the “To limit direct marketing” box below for information about additional privacy choices)

Qualifications & exceptions

• The "No" is followed by a pointer to additional privacy choices in the direct marketing box.

Sharing & Disclosure · Company practice

Sharing for joint marketing with other financial companies

American Express says it shares personal information for joint marketing with other financial companies, and the table answers "No" to whether you can limit this sharing. The notice defines joint marketing as a formal agreement between nonaffiliated companies that together market financial products or services to you, and says its joint marketing partners include financial companies.

Supporting quotations

For joint marketing with other financial companies

Yes | No

A formal agreement between nonaffiliated companies that together market financial products or services to you.

Our joint marketing partners include financial companies.

Qualifications & exceptions

• Joint marketing is defined as a formal agreement between nonaffiliated companies.

Not stated here

• The notice does not name the joint marketing partners or the products marketed.

Cross-references

• defined by (model-proposed): Joint marketing defined — The definitions section explains the term used in the joint marketing row of the sharing table.

Sharing & Disclosure · Company practice

Sharing with affiliates for their everyday business: transactions and experiences

American Express says it shares information about your transactions and experiences with its affiliates for the affiliates' everyday business purposes. The table answers "No" to whether you can limit this sharing.

Supporting quotations

For our affiliates’ everyday business purposes – information about your transactions and experiences

Yes | No

Qualifications & exceptions

• This row covers information about transactions and experiences only; creditworthiness information is a separate row.

Not stated here

• The notice does not list which affiliates receive this information.

Sharing & Disclosure · User right or choice

Sharing creditworthiness information with affiliates, and your choice to limit it

American Express says it shares information about your creditworthiness with its affiliates for the affiliates' everyday business purposes. The table answers "Yes" to whether you can limit this sharing. If your account has a Vermont billing address, American Express says it will automatically treat the account as if you had told it not to share creditworthiness information with its affiliates.

Supporting quotations

For our affiliates’ everyday business purposes – information about your creditworthiness

Yes | Yes

Vermont: If your American Express account has a Vermont billing address, we will automatically treat your account as if you have directed us not to share information about your creditworthiness with our affiliates.

Qualifications & exceptions

• You can limit this sharing; the notice's "To limit our sharing" box says how.
• Vermont billing address: the account is automatically treated as opted out of creditworthiness sharing with affiliates.

Cross-references

• has exception (model-proposed): Vermont billing address — The Vermont billing-address rule treats Vermont accounts as already opted out of the creditworthiness sharing that the table lets other customers limit.

Sharing & Disclosure · User right or choice

Affiliates marketing to you, and your choice to limit it

American Express says it shares personal information so that its affiliates can market to you. The table answers "Yes" to whether you can limit this sharing.

Supporting quotations

For our affiliates to market to you

Yes | Yes

Qualifications & exceptions

• You can limit this sharing; the notice's "To limit our sharing" box says how.

Not stated here

• The notice does not say whether the "To limit direct marketing" choices cover the same marketing by affiliates.

Sharing & Disclosure · Company practice

Nonaffiliates marketing to you: not shared

For nonaffiliates to market to you, American Express answers "No" to whether it shares and, in the limit column, says it does not share personal information. In the "Does American Express share?" column it adds that it may share aggregated or de-identified data.

Supporting quotations

For nonaffiliates to market to you

No (although we may share aggregated or de-identified data)

We don’t share personal information

Qualifications & exceptions

• The "No" is qualified: American Express may share aggregated or de-identified data.

Not stated here

• The notice does not define aggregated or de-identified data or say who receives it.

Cross-references

• contrast (model-proposed): Who counts as a nonaffiliate — The table says American Express does not share personal information for nonaffiliates to market to you, while the definitions say it shares with nonaffiliate service providers, including direct marketers, that act on its behalf. The notice does not say how these fit together.

Sharing & Disclosure · User right or choice

How to limit sharing, and the new-customer delay

To limit sharing, the notice tells you to use the "Questions?" section to call or visit American Express online for your product. If you are a new customer, American Express says it can begin sharing your personal information 30 days from the date it sent the notice. When you are no longer a customer, it says it continues to share your personal information as described, but that you can contact it at any time to limit sharing.

Supporting quotations

See the “Questions?” section below to call or visit us online for your respective product.

If you are a new customer, we can begin sharing your personal information 30 days from the date we sent this notice.

When you are no longer our customer, we continue to share your personal information as described in this notice.

However, you can contact us at any time to limit our sharing.

Qualifications & exceptions

• The 30 days run from the date American Express sent the notice, not from account opening.
• Sharing continues after you are no longer a customer, as described in the notice.

Not stated here

• This box does not say which table rows the contact covers.

Sharing & Disclosure · Restriction or exception

Why you cannot limit all sharing

The notice says federal law gives you the right to limit only three kinds of sharing: affiliates' everyday business use of creditworthiness information, affiliates using your information to market to you, and nonaffiliates marketing to you. It says state laws and individual companies may give additional rights to limit sharing and that state law may be more protective than federal law. As one example, if your account has a California billing address, American Express says it will not share your personal information except as California law permits.

Supporting quotations

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.

State law may be more protective than federal law.

California: If your American Express account has a California billing address, we will not share your personal information except to the extent permitted under California law.

Qualifications & exceptions

• The federal right covers only three kinds of sharing.
• California billing address: sharing only to the extent California law permits.

Not stated here

• The notice does not say what California law permits, or how that limits the "Yes" answers in the table.

Cross-references

• referred to by (model-proposed): California billing address — The California card repeats the state-law sentences that follow the list of federal limiting rights.

Sharing & Disclosure · Context

Who counts as an affiliate

The notice defines affiliates as companies related by common ownership or control, financial or nonfinancial. It says the affiliates include companies with the American Express name, and may also include other companies related by common ownership or control, such as AMEX Assurance Company, a provider of American Express Card-related insurance services.

Supporting quotations

Companies related by common ownership or control. They can be financial and nonfinancial companies.

Our affiliates include companies with the American Express name, including financial companies such as American Express Travel Related Services Company, Inc. and nonfinancial companies.

Affiliates may also include other companies related by common ownership or control, such as AMEX Assurance Company, a provider of American Express Card-related insurance services.

Qualifications & exceptions

• Affiliates can be financial or nonfinancial companies.
• "May also include" means the notice does not give a complete list.

Not stated here

• The notice does not list all affiliates.

Sharing & Disclosure · Context

Who counts as a nonaffiliate

The notice defines nonaffiliates as companies not related by common ownership or control, financial or nonfinancial. It says nonaffiliates with which American Express shares personal information include service providers, for example direct marketers, that perform services or functions on its behalf.

Supporting quotations

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

Nonaffiliates with which we share personal information include service providers, including, for example, direct marketers, that perform services or functions on our behalf.

Qualifications & exceptions

• The service providers named perform services or functions on American Express's behalf.

Not stated here

• The notice does not say which row of the table covers sharing with these service providers, including direct marketers.

Cross-references

• contrast (model-proposed): Nonaffiliates marketing to you: not shared — The table says American Express does not share personal information for nonaffiliates to market to you, while the definitions say it shares with nonaffiliate service providers, including direct marketers, that act on its behalf. The notice does not say how these fit together.

Sharing & Disclosure · Context

Joint marketing defined

The notice defines joint marketing as a formal agreement between nonaffiliated companies that together market financial products or services to you, and says its joint marketing partners include financial companies. Nonaffiliated companies are those not related by common ownership or control.

Supporting quotations

A formal agreement between nonaffiliated companies that together market financial products or services to you.

Our joint marketing partners include financial companies.

Companies not related by common ownership or control.

Qualifications & exceptions

• Partners are nonaffiliated companies, and the notice says they include financial companies.

Not stated here

• The notice does not name the partners.

Cross-references

• defines (model-proposed): Sharing for joint marketing with other financial companies — The definitions section explains the term used in the joint marketing row of the sharing table.

Sharing & Disclosure · Company practice

Insurance-related disclosures of personal information

The notice says personal information may be disclosed by American Express to detect fraud or misrepresentation, to verify insurance coverage, to an insurance regulatory authority, law enforcement or other governmental authority pursuant to law, or to a group policyholder for reporting claims experience or conducting an audit.

Supporting quotations

Personal information may be disclosed by us to detect fraud or misrepresentation, to verify insurance coverage, to an insurance regulatory authority, law enforcement or other governmental authority pursuant to law, or to a group policyholder for purposes of reporting claims experience or conducting an audit.

Qualifications & exceptions

• The wording is "may be disclosed", so these are permitted disclosures, not required ones.

Not stated here

• This passage follows the line about AMEX Assurance Company customers; the notice does not say whether it applies only to them.

Sharing & Disclosure · Restriction or exception

California billing address

If your account has a California billing address, American Express says it will not share your personal information except to the extent permitted under California law. The notice prefaces this with the statement that state law may be more protective than federal law.

Supporting quotations

State law may be more protective than federal law.

California: If your American Express account has a California billing address, we will not share your personal information except to the extent permitted under California law.

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

Qualifications & exceptions

• Applies to accounts with a California billing address.

Not stated here

• The notice does not say what California law permits or how this changes the table's "Yes" answers.

Cross-references

• refers to (model-proposed): Why you cannot limit all sharing — The California card repeats the state-law sentences that follow the list of federal limiting rights.

Sharing & Disclosure · Restriction or exception

Vermont billing address

If your American Express account has a Vermont billing address, the notice says American Express will automatically treat the account as if you had directed it not to share information about your creditworthiness with its affiliates.

Supporting quotations

Vermont: If your American Express account has a Vermont billing address, we will automatically treat your account as if you have directed us not to share information about your creditworthiness with our affiliates.

Qualifications & exceptions

• Applies to accounts with a Vermont billing address.
• Covers creditworthiness information shared with affiliates only.

Not stated here

• The notice does not say whether affiliates may still market to Vermont account holders.

Cross-references

• exception to (model-proposed): Sharing creditworthiness information with affiliates, and your choice to limit it — The Vermont billing-address rule treats Vermont accounts as already opted out of the creditworthiness sharing that the table lets other customers limit.