This Privacy Policy notification applies to current, as well as to former clients. It discloses among other things, the type of information we collect and how it was obtained, the security measures we implement and enforce to safeguard the confidentiality and integrity of the personal information of our clients, the subsidiaries with whom we share your information for direct marketing offers and finally your preference that this information not be shared among our subsidiaries.

Some benefits that you may receive by allowing us to share your information among our subsidiaries, under the strictest confidentiality, are discounts, direct marketing offers, combined account statements, information about new and improved products and easy access to information about your accounts from any of our subsidiaries.

1. The type of information we collect and how we obtain it.

We collect the following types of information about you from various sources:

• Personal Information, which includes: name, address and phone number that you have provided us on credit applications, account opening documents or any other document.
  
• Transaction information, such as balances, payment history and credit card transactions with us, our affiliates or others.
  
• Credit information, such as credit capacity and history that we obtain from consumer reporting agencies.


Also, the information described above is shared with our subsidiaries for direct marketing offers. These product and services offers are based on the information collected.

2. With whom do we share your information?

We exclusively share the aforementioned information with our subsidiaries. Our subsidiaries are companies controlled by Popular, Inc. and comprise several industries, including banking, mortgage, leasing, insurance and securities. For example, the following are some of these subsidiaries: Banco Popular, Popular Mortgage, Popular Auto, Popular Securities, Popular Insurance and EVERTEC.

We do not share your personal information with non-affiliated third parties except as permitted by law. These are companies or organizations that are not part of, or controlled by, Popular, Inc. An example of a non-affiliated third party with whom we share information would be the company that prints checks for our deposit customers. As an exception, we share your personal information with respectable institutions to carry out marketing services on our behalf. In addition, we enter into joint marketing agreements with other companies only for the purpose of offering you products or services.

When we enter joint marketing agreements, we only share the necessary information to achieve the aforementioned purposes. Furthermore, we require through a contract that these companies maintain strict confidentiality of the information provided and limit its use solely for the purposes for which it was provided.

3. What security measures do we implement to ensure the privacy of your information?

We limit the access to your information only to those employees who need it to provide you products and services, or to those who need access to comply with federal and local regulations of the financial industry. We hold our employees responsible for complying with our Privacy Policy and its principles, and we take the appropriate measures to enforce our employees’ responsibilities, as specified in our Code of Ethics and Rules of Conduct.

We also maintain physical and electronic security measures necessary to safeguard the confidentiality of your information as required by law and by this policy.

4. What alternatives do we offer?

If you allow us to continue to share your personal information among our subsidiaries, you do not have to return this document. Therefore, you will have access to all the benefits including discounts, direct marketing offers, combined account statements, information about new and improved products and easy access to information about your accounts from any of our subsidiaries. We thank you for trusting us and for patronizing our products and services.

On the contrary if you do not want us sharing your personal information among our subsidiaries for direct marketing offers regarding product and services, complete the Opt Out Request Form below and send it to: Popular, Inc., ATT CIF (612), PO Box 362708, San Juan, PR 00936-2708. Your Opt Out Request will be effective until you revoke it in writing. If you have already made your Opt Out Request it is not necessary to send it again. Your Opt Out Request will be effective in approximately four weeks. Remember that we can continue to share transaction and credit information as permitted by law. If you maintain joint accounts, the secondary accountholder will not receive this notification separately. If the secondary accountholder wishes to opt out, he/she should request it separately.

Exclusion Form