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ICUT SERVICES Privacy Policy May 2010 ICUT Services is committed to providing members with training programs to meet their needs and to reach their business goals. We are equally committed to protecting members privacy. The following constitutes ICUTs policy on protecting the privacy of members nonpublic personal information. The ICUT Services collects nonpublic personal information about members from the following sources:
We may disclose all of the information we collect, as described above, to companies that perform marketing or other services on our behalf or to other financial institutions with whom we have joint marketing agreements. To protect our members nonpublic personal information, we will only use vendors that agree that they will maintain the strictest confidentiality of members nonpublic information and only use the information for the purposes intended. We will not allow these companies to sell any nonpublic personal member information to other third parties. In order to conduct the business operations of ICUT Services, we may also disclose nonpublic personal information about members under other circumstances as permitted or required by law. These disclosures typically include information to process transactions on our behalf, to conduct the operation of the ICUT Services, to follow members authorized instructions, or to protect the security of our financial records. Restriction on Sharing Account Numbers ICUT Services prohibits the sharing of account numbers with any nonaffiliated third party for use in telemarketing, direct mail marketing or marketing through electronic mail to members. Disclosure of Information About Former Members ICUT Services will not share nonpublic personal information that has been collected about a member once that member has terminated their membership with the ICUT Services except as may be permitted by law. How We Protect Member Information ICUT Services restricts access to nonpublic personal information about members to those employees who need to know that information to provide products and services to those members. It is required that all officers of ICUT Services hold in confidence all transactions of this ICUT Services with its members and all information respecting their personal affairs, except when permitted by state or federal law. The ICUT Services also maintains physical, electronic, and procedural safeguards that comply with federal regulations to guard the nonpublic personal information of members. Distribution of Policy ICUT Servicess privacy policy will be distributed in three manners:
Opt Out Requirement Currently, the ICUT Services does not disclose any nonpublic personal information to nonaffiliated third parties that would require the ICUT Services to provide members with an option to opt out of information disclosure. The ICUT Services has evaluated all nonpublic information that is disclosed; and at this time all disclosures fit into one of the following exceptions to the opt out option Requirement:
If it becomes necessary to provide an option to opt out it will be added to the ICUT Servicess privacy policy and disclosed to members as described above.
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