Financial Privacy

WHAT DOES COMENITY DIRECT DO WITH YOUR PERSONAL INFORMATION?

Rev. Date 03/19

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 balances and transaction history
  • Credit history and credit scores
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 Direct chooses to share; and whether you can limit this sharing.
Reasons we can share your personal informationDoes Comenity Direct 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
Yes Yes
For our affiliates to market to you Yes Yes
For nonaffiliates to market to you Yes Yes
To limit our
sharing

Call 1-833-755-4354; dial 7 for a representative. For operator relay assistance, first dial 711.

Please note:

If you are a new  customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice.

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

Questions?

Call 1-833-755-4354

Who we are
Who is providing this
notice?

This privacy notice is provided by Comenity Capital Bank doing business under the brand name “Comenity Direct.”

What we do
How does Comenity Direct 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 Direct collect my personal information?

We collect your personal information, for example, when you

  • Open an account or provide account information
  • Make deposits or withdrawals from your account
  • Give us your income information

We also collect your personal information from others such as credit bureaus, affiliates, or 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-affiliates 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?Your choices will apply to everyone on your account.
Definitions
Affiliates

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

  • Our affiliates include companies with a Comenity name; financial companies such as Comenity Capital Bank and Comenity Bank, other Comenity entities; nonfinancial companies such as Epsilon, Alliance Data, and LoyaltyOne.
Nonaffiliates

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

  • Nonaffiliates we share with can include financial service providers, 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 may include lenders and insurance companies.
Other Important Information

We also will comply with more restrictive state laws to the extent that they apply; for example, Vermont or California.