Online Privacy and Security

Effective July 2023

At Elan Financial Services (“Elan,” “we,” “us” or “our”), trust has always been the foundation of our relationship with customers. We understand your desire for privacy, and we recognize that you trust us with your personal and financial information. This Online Privacy Policy is designed to describe our privacy practices and principles in a format that is easy to navigate, read and understand.

This Online Privacy Policy (the "Policy") describes the treatment of information that is provided or collected through any of our online interfaces to which a copy of the Policy is posted, including elanpaymentsolutions.com (the "Website"), Applications we have placed on third party sites such as Facebook^®, Twitter^® and other social media services, and Elan’s mobile applications (the "Applications," and together with the Website, the "Services"). It also explains how we collect, use and share information based on users’ interactions with online advertisements, both on the Services and on online interfaces owned by third parties. Note that the Policy does not govern our privacy practices offline or with respect to information that is not provided or collected through the Services. For additional information on this Policy or our privacy practices generally, please feel free to contact us directly with your questions.

While this Online Privacy Policy describes how we treat information, please be aware that additional terms and conditions may apply for certain parts of our Website and Applications.

Contents

1. Types of Information We Collect

We collect two basic types of information through the Services – personal information and anonymous information. We also collect location information in connection with our mobile applications.

"Personal information" refers to information that identifies (whether directly or indirectly) a particular individual, such as information you provide on our forms, surveys, applications or similar online fields. Examples may include identifiers like your name, postal address, email address, telephone number, Social Security number, date of birth or account information like your transaction and payment history.

"Anonymous information" means information that does not directly or indirectly identify, and cannot reasonably be used to identify, a particular individual. Examples may include information about your Internet browser, information collected through tracking technologies (see Online Tracking and Advertising), demographic information that you provide to us (e.g., your annual income) and aggregated or de-identified data.

"Location information" means information that may be collected by certain mobile applications that identifies your physical location. This information may be collected from your mobile device’s location-aware features when you request certain services that are dependent on your physical location.

2. How We Collect Your Information

We collect personal information from you or about you when you provide this information to us directly. For example, we may obtain personal information when you request information, products or services from us, register on the Website or an Application, respond to surveys, contact customer support or otherwise interact with us. We may also receive information about you from other online and offline sources, such as public databases, social media platforms, the partner named on your card, and other third parties.

In addition, we may collect information about your activity on the Services automatically using tracking technologies, such as cookies and pixel tags. Definitions for the tracking technologies listed, as well as information regarding how to disable them, are available in the Online Tracking and Advertising section of the Policy.

If you submit any personal information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and permit us to use the information in accordance with this policy.

3. How We Use Your Information

We may use information collected through the Services to, among other things:

• Provide you with, or evaluate your eligibility for, products and services that you request from us 
• Communicate with you about your accounts or transactions with us 
• Send you important information regarding the Services, changes to this Policy and/or other similar administrative information 
• Allow you to participate in surveys, sweepstakes, contests and similar promotions, and to administer such promotions (note that these promotions may contain additional disclosures regarding our collection and/or use of your information) 
• Consistent with local law, required disclosures, and choices and controls that may be available to you: 
  • Send you offers and promotions for our products and services, or products and services that may be of interest to you; 
  • Personalize content and experiences on the Services; 
  • Verify your identity and/or location (or the identity or location of your authorized representative) for security, fraud prevention and other risk control purposes; and 
  • Provide you with advertising based on your activity on the Services and on third-party websites and applications. For additional information regarding our use of your information for personalization and tracking, please refer to the Online Tracking and Advertising section of the Policy. 
• Optimize or improve our products and services 
• Detect, investigate and prevent activities that may violate our policies or be illegal 
• Comply with our legal and regulatory obligations 
• Enforce our terms and conditions and otherwise protect our rights and operations

4. How We Share Your Information

We will not share your personal information outside the Elan Financial Services family of financial service providers, except under limited circumstances as allowed or required by law. Examples include sharing information with third party service providers who work for us to provide or maintain products or services, responding to court orders or judicial process.

5. Online Tracking and Advertising

We and certain trusted service providers operating on our behalf collect information about your activity on the Services using tracking technologies, including:

• Cookies. Cookies are pieces of information that are stored directly on the device that you are using. They allow us to collect information such as the type of browser you are using, the amount of time you spend using the Services, the websites or applications you visit and the preferences you have set up for your accounts. We use this information to personalize your experience, enhance security, facilitate navigation, display material more efficiently and recognize the device that you are using to access the Services. The Services do not use cookies that capture unencrypted personal information about you.
  
  You can choose to have your device refuse to accept any cookies, and the majority of devices and browsers offer additional privacy settings for cookies. You do this through your browser settings. Each device and each browser is a little different, so look at your device Settings or your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you will not have access to many features that make your user experience more efficient and some of the Services will not function properly. Please note that you will need to manage your cookie settings for each device and browser that you use.

• Pixel tags, web beacons, clear GIFs and other similar technologies. These are typically small pieces of data that are embedded in images on the Website, our Applications or certain email communications. They may involve the transmission of information directly to us, to another party on our behalf or to another party in accordance with its privacy policy. We may use these technologies to bring together information we collect about you.
• Location tracking on mobile devices. Certain applications on mobile devices may transmit information to us about your location when you request information from them. An example includes your physical location when you search for a nearby ATM using your mobile device. We may use that information to improve the products and services we provide to you as well as improving our services generally in your area.

Information collected through tracking technologies is used for many purposes including, for example, to:

• Provide useful features to simplify your experience when you return to the Services 
• Deliver relevant content based on your preferences, usage patterns and location 
• Monitor and evaluate the use and operation of the Services 
• Analyze traffic on the Services and on websites or mobile applications of third parties

We may associate this tracking data with your registration information, in which case we will treat it as personal information. Service providers that collect tracking data on our behalf may provide an opportunity for you to choose not to be tracked online.

Do Not Track. There is no industry standard for how Do Not Track consumer browser settings should work on commercial websites. Due to the lack of such standards our websites do not respond to Do Not Track consumer browser settings.

Occasionally, you may encounter banner advertisements for our products and services on third-party websites and mobile applications. We use third-party advertising service providers to distribute our advertisements on websites and mobile applications where we have paid to advertise. These advertisements may use tracking technologies to capture information such as IP address, browser type and usage information in order to track the effectiveness of our advertising efforts. We may associate the information collected by these technologies with your identity. Our advertising service providers are prohibited from using any information collected except to track advertising effectiveness.

In addition, we use advertising service providers such as Google, Yahoo and MSN to place advertisements for our accounts and services on websites not affiliated with us, and to help us determine which of our advertisements are most likely to be of interest to you using non-personal behavioral information. Advertisements placed by these service providers may use tracking technologies that allow monitoring of your responsiveness to such advertisements. We restrict access and collection of information by advertising service providers for purposes other than assisting us with our advertising efforts.

Elan participates in the industry Self-Regulatory Program for Online Behavioral Advertising managed by the Digital Advertising Alliance (DAA) (www.aboutads.info/choices). As part of this service, Elan online advertisements are sometimes delivered with icons that help consumers understand how data about them is being used. Clicking on the icon provides options for consumers who want more control and ability to opt out of such behavioral (targeted) advertising. Elan may use data collected on our website to customize advertisements to you on other sites as you browse the web. You can click on the DAA icon in our targeted advertisements to opt out if you do not want your browsing behavior used for online behavioral advertising purposes. If you prefer not to have non-personal information used for online behavioral advertising purposes, you may also opt-out here. Please note that even if you opt-out, you may still receive online advertising from Elan. Opting-out from a specific advertising provider means that the ads you do receive will not be based on your preferences or behavior. You may still see targeted pages based on your habits as you navigate Elan Financial Services.

In order for behavioral advertising opt-outs to work on your device, your browser must be set to accept cookies. If you delete cookies, buy a new device, access the Services from a different device, log-in under a different screen name or change web browsers, you will need to opt-out again. If your browser has scripting disabled, you do not need to opt-out, as online behavioral advertising technology does not work when scripting is disabled. Please check your browser's security settings to validate whether scripting is active or disabled.

6. Other Information Collected Automatically

Browser or Device Information: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Services (such as the Application) you are using. We use this information to ensure that the Services function properly.

Application Information: When you download and use an Application, we and our service providers may track and collect usage data, such as the date and time the Application on your device accesses our servers and what information and files have been downloaded to the Application based on your device number.

IP Address: Your IP address is a number that is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, helping diagnose server problems and administering the Services.

7. Linked Websites

The Services may contain links to third-party websites not controlled by Elan. We encourage you to be aware when you leave the Services and to read the privacy policies and terms of use of any such websites that may collect your personal information, as they will likely differ from those of the Services. Elan does not guarantee and is not responsible for the privacy or security of these websites, including the accuracy, completeness or reliability of their information.

In addition, Elan is not responsible for the information collection, use and disclosure practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, BlackBerry or any other app developer or provider, social media platform provider, operating system provider, wireless service provider or device manufacturer.

8. Data Security

Your privacy is very important to Elan and we are committed to protecting your personal information from unauthorized access or use. We will use reasonable organizational, physical, technical and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.

9. Preventing Identity Theft

In order to help us protect your personal information, it is important that you always keep your account information safe. We recommend that you consider the risk of sharing your personal ID, password, or PIN with anyone.

Note that Elan will never initiate a request via email for your sensitive information (e.g., Social Security number, personal ID, password, PIN or account number). If you receive an email asking for your sensitive information, you should be suspicious of the request and promptly contact us to report the suspicious activity.

Please be aware, however, that in certain telephone and in-person transactions we may ask for sensitive information to verify your identity before conducting the transactions you have requested. For example, we may ask for such information to verify your identity when you place a call to us. We will never request that you disclose your personal ID, password or PIN under any circumstances, including such telephone or in-person transactions.

Additional information regarding identity theft and the steps you can take to help protect yourself from fraud can be found on the Federal Trade Commission website.

10. Children’s Privacy

We do not use the Services to knowingly solicit data from or market to children under the age of thirteen (13) without parental consent. We request that such individuals do not provide personal information through the Services. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should promptly contact us and we will delete such information from our files. For additional information regarding the Children's Online Privacy Protection Act (COPPA), please visit the Federal Trade Commission website.

11. External Aggregation Services

You have the responsibility to help us protect your accounts. Consider the risk of revealing your user name, password, or other credentials to any person or third party. By providing your user name, password or other credentials to any person or third party (including an aggregation service) you authorize that person or third party to initiate transfers to or from your account.

Some third-party companies offer aggregation services that allow you to consolidate your financial account information from a variety of sources, such that you can view all your account information at a single online location. For example, an aggregation service might collect and consolidate your checking and savings account balances at your bank, the value of your stocks and bonds in your brokerage account and your frequent flier mileage information from an airline. In order to do so, the aggregator may request access to personal information - including identification information, account information, personal IDs and passwords - from you for each individual website.

Please use caution when providing personal information to an aggregation service. By providing your user name, password or other credentials to an aggregation service you authorize that person or third party to initiate transfers to or from your account.

Should you decide to revoke the authority you have given to an aggregation service, you should notify the aggregation service in addition to contacting us, in which case we may need to block your account until we issue new access codes.

12. Social Media Platforms

Elan may interact with registered users of various social media platforms, including Facebook^® and Twitter^®. Please note that any content you post to such social media platforms (e.g., pictures, information or opinions), as well as any personal information that you otherwise make available to users (e.g., your profile), is subject to the applicable social media platform’s terms of use and privacy policies. We recommend that you review this information carefully in order to better understand your rights and obligations with regard to such content.

13. Retention Period

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required by law.

14. Updating Your Information

It is very important that you keep the information associated with your account accurate and up-to-date. If you believe that your account information is incomplete, inaccurate or otherwise not current, please contact us and provide us with the appropriate information. Alternatively, you may call or write to us at the telephone numbers or appropriate address for changes listed on your account statements, records, online or other account materials.

15. Cross-Border Transfer

The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any country or territory other than that of the United States. We may store and process your personal information in any country where we have facilities or in which we engage service providers, and, by using the Services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.

16. California Privacy Center

July 2023

Elan Financial Services is dedicated to doing the right thing. The information on this page provides details on how we respond to and implement processes to uphold applicable state laws. The laws on this page give individuals certain rights regarding the personal information that Elan Financial Services or our affiliates have collected from or about them.

The information on this page complements the notices and disclosures regarding your rights under federal laws and regulations (e.g., the Gramm-Leach-Bliley Act). For more information, please visit the top of this page.

Elan Financial Services California Privacy Notice For California Residents

Last Updated: July 2023

This Privacy Notice for California Residents (this “Notice”) applies solely to residents of the State of California (“consumers” or “you”) and supplements the information contained in any other Privacy Statement or Notice provided by Elan Financial Services and its affiliates (collectively, “Elan Financial Services” “our” or “we”). Please note that some of our affiliates may provide a separate privacy notice, in which case that notice will apply to your personal information. We adopt this Notice to comply with the California Consumer Privacy Act of 2018 and, as amended, the California Privacy Rights Act of 2020 (together, “CPRA”). This Notice describes how Elan Financial Services collects, uses, and discloses information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“personal information”). This Notice applies to personal information we collect online and offline, such as when you apply for our products or services, use our websites or applications, respond to surveys, contact customer support, when you visit our offices or attend a Elan Financial Services event, or otherwise interact with us (collectively, “Services”). The information on this page complements the notices and disclosures regarding your rights under federal laws and regulations (e.g., the Gramm-Leach-Bliley Act). For more information, please visit Online Privacy Policy.

The rights contained in this Notice may not apply in certain situations depending on your relationship with Elan Financial Services and Elan Financial Services’ other legal obligations, and as otherwise provided for in the CPRA, and the GLBA exemption contained therein. We may, from time to time, make changes to this Notice. If we do make changes to the Notice, we will let you know by posting the revised Notice with a new “Last Updated” date posted at the top of the Notice. Any changes to this Notice will become effective when posted unless indicated otherwise. We encourage you to review this Notice regularly to stay informed about our information practices and the choices available to you.

Contents

Categories of personal information we collect

We may collect the following categories of personal information when you engage our Services:

• Identifiers — A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, signature or other similar identifiers 
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) — A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number and ATM card number, or any other financial information, medical information, or health insurance information. 
• Sensitive personal information — Social Security number, driver's license, state identification card, or passport number; your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; racial or ethnic origin, religious beliefs, or union membership; the contents of your mail, email, and text messages unless Elan Financial Services was the intended recipient of the communication; health data; precise geolocation data; biometric information; and sex life or sexual orientation data 
• Protected classification characteristics under California or federal law — Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information) 
• Commercial information — Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies 
• Biometric information — Fingerprints, faceprints, voiceprints and behavioral patterns 
• Internet or other electronic network activity information — Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement 
• Geolocation data — Physical location or movements 
• Audio and visual Information — Audio, electronic, or similar information we capture through your communications with us, e.g., voice recordings of telephone conversations, emails and instant messaging, and security images if you visit our offices 
• Employment information — Current or past job history 
• Inferences drawn from other personal information — Inferences drawn from any of the information identified above to create a profile about you reflecting preferences, characteristics, attitudes and or similar trends

Where we collect your personal information

We will collect the personal information described above from one or more of the following sources:

• Directly from you or your company when you provide this information to us, when you request information, apply for products or services from us, use our websites or applications, respond to surveys, contact customer support, when you visit our ATMs, branches or offices or attend a Elan Financial Services event, or otherwise interact with us 
• From our affiliates, co-owners, partners and other related parties 
• From other online and offline sources, such as public databases, social media platforms, and other third parties 
• Vendors who provide services on our behalf

Use of personal information

We may use or disclose personal information that we collect for one or more of the following business purposes to, among other things:

• Provide you with, or evaluate your eligibility for, products and services that you or your company request from us. 
• Communicate with you about your accounts or transactions with us. 
• Send you important information regarding our products and services, changes to this Notice and/or other similar administrative information. 
• Enter into transactions and conduct business dealings with our business partners, service providers and contractors. 
• Allow you to participate in surveys, sweepstakes, contests and similar promotions, and to administer such promotions (note that these promotions may contain additional disclosures regarding our collection and/or use of your information). 
• Consistent with local law, required disclosures, and choices and controls that may be available to you: 
  • Send you offers and promotions for our products and services, or products and services that may be of interest to you; 
  • Personalize content and experiences on our Services; 
  • Verify your identity and/or location (or the identity or location of your authorized representative) for security, fraud prevention and other risk control purposes; and 
  • Provide you with advertising based on your activity on our Services and on third-party websites and applications. For additional information regarding our use of your information for personalization and tracking, please refer to the Online Tracking section of this policy. 
• Optimize or improve our products and services. 
• Help to ensure security and integrity. Detect, investigate, and prevent activities that may violate our policies or be illegal. 
• Report to credit bureaus 
• Comply with our legal and regulatory obligations. 
• Enforce our terms and conditions and otherwise protect our rights and operations.

Disclosure of personal information for a business purpose

We may disclose your personal information for a business purpose to the following categories of parties:

• Affiliates; 
• Service providers and contractors who help manage, develop, and analyze our business and/or deliver services to us and our clients, such as; 
  • Professional services organizations, such as auditors and law firms 
  • Our business partners 
  • Online advertising services and networks 
  • Internet service providers 
  • Data analytics providers 
  • Operating systems and platforms 
  • Social networks 
  • Data brokers 
• Agencies and organizations working to prevent fraud in financial services; or 
• Law enforcement, regulatory and other governmental agencies.

Retention period

We store personal information for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Sharing or selling your personal information

We do not sell personal information to third parties for monetary consideration without your prior consent, but we may share your personal information with third parties for cross-context behavioral advertising.

The categories of personal information that we may have shared are:

• Identifiers, including IP addresses, cookie identifiers, and other pseudonymous identifiers 
• Account information 
• Protected classification information 
• Internet or other electronic network activity information 
• Professional or employment information 
• Inferences drawn from personal information

We do not purposefully sell or share the personal information of children under the age of 16.

For more on your personal information share/sale rights, see Right to Opt-out of Sharing or Selling.

We reserve the right to transfer any personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).

Use of sensitive personal information

Under the CPRA, we collect the types of sensitive personal information described in the Categories of Personal Information We Collect section above. Elan Financial Services only collects and uses sensitive personal information for certain limited purposes, such as providing services and products to consumers, detecting data security incidents and protecting against fraud (“Limited Purposes”). Because Elan Financial Services uses this sensitive personal information for Limited Purposes, there is no need for us to provide a Limit Use and Disclosure of Sensitive Personal Information right under the CPRA.

Summary of prior 12-month personal information handling practices

We provide in the chart below a summary of our prior 12-month personal and sensitive information handling practices. You can learn more about the information we collect at or before the point of collection above in the Categories of Personal Information We Collect, Where We Collect Your Personal Information, Use of Personal Information, and Disclosure of Personal Information for a Business Purpose sections.

Your rights and choices

This section describes your CPRA rights and explains how to exercise those rights:

Right To Know

You have the right, subject to certain exceptions defined in the CPRA and other applicable laws and regulations, to request that Elan Financial Services disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• The business or commercial purpose for collecting, selling, or sharing the personal information.
• The categories of third parties with whom we disclose that personal information.
• The categories of personal information that each recipient received.
• The specific pieces of personal information we collected about you.

You have the right to receive this information in a format, to the extent technically feasible, that is portable, usable, and allows you to transmit the personal information to a person without impediment, where the processing is carried out by automated means.

Right to Request Deletion

You have the right, subject to certain exceptions defined in the CPRA and other applicable laws and regulations, to request that Elan Financial Services delete any of your personal information that we collected from you and retained. Once we receive and confirm your verifiable consumer request we will delete (and direct the recipients of your personal information to delete) your personal information from our records.

Right to Correct Your Personal Information:

You have the right, subject to certain exceptions defined in the CPRA and other applicable laws and regulations, to submit a request to correct any inaccurate personal information that we may have about you. To correct your information, please call the customer service support line at 1-800-344-5696.

Right to Opt-out of Sharing or Selling:

We use technologies such as cookies, pixel tags, web beacons, and other similar technologies, that gather information on our websites. That information is used for a variety of purposes, such as to understand how visitors interact with our websites, or to serve advertisements on our websites or on other websites. The use of technologies, such as cookies, constitutes a ‘share’ or ‘sale’ of personal information under the CPRA. You can stop the use of certain third-party tracking technologies that are not considered our service providers or by clicking on “Your California Privacy Choices” at the bottom of applicable pages. Note that due to technological limitations, if you visit our website from a different computer or device, or clear cookies on your browser that store your preferences, you will need to return to this screen to opt-out and/or rebroadcast the signal.

We also treat opt-out preference signals, such as the Global Privacy Control, as valid requests to opt-out of the sale or sharing of your personal information. An opt-out preference signal is a signal that is sent by a platform, technology, or mechanism on your behalf that communicates your choice to opt-out of the sharing for targeted advertisements or sale of your personal information. You can learn more about implementing opt-out preference signals by visiting the Global Privacy Control website here or by exploring other developing technologies and services that offer this tool.

Exercising your rights

To exercise the rights described above, please submit a verifiable consumer request to us through one of the following methods:

• Current, Former or Prospective Customer Requests:
  • Please complete the Personal Information Request Form. This form allows you to request the details of the personal information that Elan Financial Services has about you and to request access, to that information. Once received, Elan Financial Services must use reasonable methods to verify the identity of the requestor before responding. If we cannot verify the requestor, we will either deny the request or ask for additional identifying information. Elan Financial Services will respond within 45 days of the request unless additional time is required.
  • Or call us at 1-800-344-5696.

You may only make a verifiable consumer request for access twice within a 12-month period.

Requests by Authorized Agents

You may exercise your privacy rights through an authorized agent. If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.

Nondiscrimination

You have the right not to be discriminated against for exercising any of your privacy rights. This includes us not: (a) denying you goods or services; (b) charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (c) providing you a different level or quality of goods or services; (d) suggesting to you that you will receive a different price or rate for goods or services or a different level or quality of goods or services; and (e) retaliating against you for exercising your privacy rights.

Annual report

The 2022 CCPA Annual Report graph outlines the number of requests to know, delete or opt out, the business has received, complied with and denied.

17. Changes to the Online Privacy Policy

From time to time, we may make changes to this Policy in order to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We encourage you to review the Policy periodically to ensure that you understand how we collect, use and share information through the Services. If we do make changes to the Policy, we will also update the "Effective Date" posted at the top of the Policy.

Any changes to the Policy will become effective when the revised Policy is posted on the Website, relevant Application or other Elan online interface, as applicable. By continuing to use the Services following such changes, you are agreeing to accept the terms of the revised Policy.

18. Contact Us

If you have any questions, comments, or complaints about the Elan privacy policy and/or the way it affects you, please feel free to call the number on the back of your card or write to us at the following address:

Corporate Payment Systems­
EP-MN-L29C
200 S. 6th St.
Minneapolis, MN 55402
1-800-344-5696