Financial institutions, including a group of financial holding company affiliates that use a
common privacy notice, may use the following sample clauses, if the clause is accurate for each
institution that uses the notice. (Note that disclosure of certain information, such as assets and
income, may give rise to obligations under the Fair Credit Reporting Act, such as a requirement to
permit a consumer to opt out of disclosures to affiliates or designation as a consumer reporting
agency if disclosures are made to nonaffiliated third parties.)
A-1–Categories of information you collect (all institutions)
You may use this clause, as applicable, to meet the requirement of § ___.6(a)(1) to
describe the categories of nonpublic personal information you collect.
Sample Clause A-1:
We collect nonpublic personal information about you from the following sources:
Information we receive from you on applications or other forms;
Information about your transactions with us, our affiliates, or others; and
Information we receive from a consumer reporting agency.
A-2–Categories of information you disclose (institutions that disclose outside of the
exceptions)
You may use one of these clauses, as applicable, to meet the requirement of § ___.6(a)(2)
to describe the categories of nonpublic personal information you disclose. You may use these
clauses if you disclose nonpublic personal information other than as permitted by the exceptions in
§§ ___.13, ___.14, and ___.15.
Sample Clause A-2, Alternative 1:
We may disclose the following kinds of nonpublic personal information about you:
Information we receive from you on applications or other forms, such as [provide
illustrative examples, such as “your name, address, social security number, assets, and income”];
Information about your transactions with us, our affiliates, or others, such as [provide
illustrative examples, such as “your account balance, payment history, parties to transactions, and
credit card usage”]; and
Information we receive from a consumer reporting agency, such as [provide illustrative
examples, such as “your creditworthiness and credit history”].
Sample Clause A-2, Alternative 2:
You may use this clause, as applicable, to meet the requirements of §§ ___.6(a)(2), (3),
and (4) to describe the categories of nonpublic personal information about customers and former
customers that you disclose and the categories of affiliates and nonaffiliated third parties to whom
you disclose. You may use this clause if you do not disclose nonpublic personal information to
any party, other than as permitted by the exceptions in §§ ___.14, and ___.15.
Sample Clause A-3:
We do not disclose any nonpublic personal information about our customers or former
customers to anyone, except as permitted by law.
A-4–Categories of parties to whom you disclose (institutions that disclose outside of the
exceptions)
You may use this clause, as applicable, to meet the requirement of § ___.6(a)(3) to
describe the categories of affiliates and nonaffiliated third parties to whom you disclose nonpublic
personal information. You may use this clause if you disclose nonpublic personal information
other than as permitted by the exceptions in §§ ___.13, ___.14, and ___.15, as well as when
permitted by the exceptions in §§ ___.14, and ___.15.
Sample Clause A-4:
We may disclose nonpublic personal information about you to the following types of third
parties:
Financial service providers, such as [provide illustrative examples, such as “mortgage
bankers, securities broker-dealers, and insurance agents”];
Non-financial companies, such as [provide illustrative examples, such as “retailers, direct
marketers, airlines, and publishers”]; and
Others, such as [provide illustrative examples, such as “non-profit organizations”].
We may also disclose nonpublic personal information about you to nonaffiliated third
parties as permitted by law.
A-5–Service provider/joint marketing exception
You may use one of these clauses, as applicable, to meet the requirements of § ___.6(a)(5)
related to the exception for service providers and joint marketers in § ___.13. If you disclose
nonpublic personal information under this exception, you must describe the categories of
nonpublic personal information you disclose and the categories of third parties with whom you
have contracted.
Sample Clause A-5, Alternative 1:
We may disclose the following information to companies that perform marketing services
on our behalf or to other financial institutions with whom we have joint marketing agreements:
Information we receive from you on applications or other forms, such as [provide
illustrative examples, such as “your name, address, social security number, assets, and income”];
Information about your transactions with us, our affiliates, or others, such as [provide
illustrative examples, such as “your account balance, payment history, parties to transactions, and
credit card usage”]; and
Information we receive from a consumer reporting agency, such as [provide illustrative
examples, such as “your creditworthiness and credit history”].
Sample Clause A-5, Alternative 2:
We may disclose all of the information we collect, as described [describe location in the
notice, such as “above” or “below”] to companies that perform marketing services on our behalf
or to other financial institutions with whom we have joint marketing agreements.
A-6–Explanation of opt out right (institutions that disclose outside of the exceptions)
You may use this clause, as applicable, to meet the requirement of § ___.6(a)(6) to
provide an explanation of the consumer’s right to opt out of the disclosure of nonpublic personal
information to nonaffiliated third parties, including the method(s) by which the consumer may
exercise that right. You may use this clause if you disclose nonpublic personal information other
than as permitted by the exceptions in §§ ___.13, ___.14, and ___.15.
Sample Clause A-6:
If you prefer that we not disclose nonpublic personal information about you to
nonaffiliated third parties, you may opt out of those disclosures, that is, you may direct us not to
make those disclosures (other than disclosures permitted by law). If you wish to opt out of
disclosures to nonaffiliated third parties, you may [describe a reasonable means of opting out,
such as “call the following toll-free number: (insert number)].
A-7–Confidentiality and security (all institutions)
-You
may use this clause, as applicable, to meet the requirement of § ___.6(a)(8) to
describe your policies and practices with respect to protecting the confidentiality and security of
nonpublic personal information.
Sample Clause A-7:
We restrict access to nonpublic personal information about you to [provide an appropriate
description, such as “those employees who need to know that information to provide products or
services to you”]. We maintain physical, electronic, and procedural safeguards that comply with
federal regulations to guard your nonpublic personal information.
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