Security and Privacy Policy for Great Lakes Capital Acceptance, LLC

At Great Lakes Capital Acceptance, LLC, hereinafter "Company", "we" or "us", we are committed to protecting the privacy of our customers' information. We know that your financial information is personal. Our goals are to serve you as effectively and conveniently as possible and to ensure that information you share with us remains confidential. As part of our commitment, we have adopted the following Privacy principles and have implemented them at all levels of our organization.

1. Privacy of Information-Customer Expectations
Trust, privacy, and confidentiality are the most important part of our commitment in meeting customer expectations of how we use the information we obtain. We will maintain standards to ensure that your information is private and secure at all times.

2. Employee Access to Information is Limited
We have policies and procedures in place that limit access to your personal information to those employees with business reasons for knowing such information. We have appropriate policies to enforce employee responsibilities regarding the privacy of customer information. Our employees are aware it is inappropriate to discuss the affairs of customers and their finances, except with outside professionals retained by the mortgage company, and then only to the extent necessary for business purposes.

3. Use, Collection, and Retention of Customer Information
We collect, retain, and use information about you in order to conduct our business with you, satisfy legal reporting requirements, and administer our internal operations. We may routinely collect or retain information that includes your: (1) name, address, telephone number, social security number, annual income, current and past employers; (2) answers to questions on loan applications; and (3) We collect information from consumer reporting agencies regarding credit and checking account histories.

We do not provide information to outside parties unless it is in direct support of your account activities or as otherwise permitted by law. We do not sell our information to companies that offer other products and services. When we collect information about you, we do so only for a specific business purpose.

When you end your customer relationship with us, or when we end our customer relationship with you, we will treat the information we have about you as if you were still our customer.

4. Accuracy of Information
Maintaining the accuracy of your personal information is important. We have procedures to help assure that your personal information is accurate, current, and complete. We also have procedures to correct inaccurate information in a timely manner. If you discover any information we have about you that is incorrect, please let us know.

5. Security of Consumer Information Collected
We maintain security standards and procedures regarding unauthorized access to customer information. We constantly update and test our technology to improve the protection of our customer information and to protect the integrity of our systems. We do not provide information about you to anyone without first verifying who they are and whether they may have legal access to the information.

6. Disclosure of Account Information is Restricted
We do not reveal specific information about your application outside our organization except for the performance of bona fide corporate due diligence supported by a confidentiality agreement, or under the following circumstances:

• you request or authorize disclosure;
  
• the information is provided to help complete a transaction initiated by you;
  
• the information is provided to a reputable credit bureau or similar information reporting agency; or
  
• the disclosure is otherwise authorized or required by law.
  

7. We do not sell our customer lists
We do not share information with vendors who wish to provide special offers of financial products and services, such as insurance companies or credit card issuers.

8. Changes
Our privacy principles may change from time to time, so please check our web site regularly to view the most current version.

9. Complaints
Because of  the Company's high commitment to confidentiality of customer information, complaints relating to this policy should be forwarded directly to our office, for prompt consideration.

10. Whom should you contact with Questions?
We value customer relationships. We want you to understand how we use the information you provide and our commitment to ensuring your personal privacy. If you have questions about our privacy policy, please contact the customer service department at 1-888-716-7770. We will be glad to answer your questions.