Clear Capital

ClearCapital.com, Inc. ("Clear Capital"):

1. Collects non-public personal information about you from the following sources:
   • From applications or other forms we receive from you or your authorized representatives;
   • From transactions with, or from the services being performed by, us, our affiliates, or others;
   • From our internet web sites;
   • From the public records maintained by governmental entities; and
   • From consumer or other reporting agencies;
2. Does not disclose any non-public personal information about you except:
   • to agents, independent contractors or representatives to provide you with requested services;
   • to third-party contractors or service providers who provide services or perform functions on our behalf;
   • to law enforcement or regulatory officials when applicable law or regulations require us to do so;
   • where required by law or judicial process (such as a court order);
   • to other parties with appropriate consent; or
   • otherwise to the extent permitted under federal or state privacy laws;
3. Restricts access to non-public personal information to employees who need to know that information to provide services to clients; and
4. Maintains physical, electronic and procedural safeguards to guard non-public personal information.