Legal / Privacy Statement

Privacy at a Glance

Infinity Commercial Capital is dedicated to protecting your privacy and providing you with the highest level of service. We want you to understand how we gather and may share customer information at Infinity Commercial Capital, the choices you have, and how we protect that information in everything we do.

How We Protect Customer Information

Keeping financial information secure is our responsibility and our commitment to you.

• We protect customer information through physical, electronic, contractual and procedural measures that comply with or exceed applicable laws and standards.
• We train our employees to protect customer information and only authorize access for employees who we believe have a business need for that information. Employees are held accountable by Infinity Commercial Capital Code of Conduct and Ethics to properly protect customer information.
• We maintain policies and procedures that provide for the proper physical security of workspaces and records.
• We require contractors and other companies that provide services on our behalf to protect information, and we prohibit those companies from using it for any other purpose. We only provide them with information that we believe is necessary to fulfill their responsibilities or to provide a financial service to you.

How We Gather Customer Information

The information we gather about you helps us to better understand your financial needs and to provide more personalized, efficient service to you.

The information we gather comes from a variety of sources, including:

• Information you provide to us (such as name, address and telephone number).
• Information about your transactions with Infinity Commercial Capital.
• Information we receive from credit reporting agencies and other companies and agencies (such as your credit history).

Sharing Customer Information Outside of Infinity Commercial Capital

We do not provide customer information to companies outside of Infinity Commercial Capital, except as outlined below. You do not need to request this confidentiality; it is our standard practice.

In order to serve your needs, we may provide all of the information we gather to:

• Companies that act on our behalf to market our services, or financial institutions with whom we have entered into a joint marketing agreement in order to provide you with valuable financial products and services.*
• Others as permitted or required by law (such as to protect against fraud or in response to a subpoena).

Our policies for sharing customer information, both within and outside of Infinity Commercial Capital as described above, also apply to all of the information we have gathered about former customers of Infinity Commercial Capital.

We Strive to Maintain Accurate Information

We strive to maintain complete and accurate information about you and your accounts. If you ever believe that our records contain inaccurate or incomplete information about you, please let us know immediately by contacting us at (248) 615-7771. We are committed to resolving any inaccuracies as quickly as possible.

If You Have Questions, Contact Us

We welcome the opportunity to answer any questions you may have about this statement or the safeguarding and confidentiality of information about our customers. Please call us at (248) 615-7771 to speak to a representative.

*Other Applicable Laws

The practices described above are in accordance with federal law. You may have other protections under applicable state laws, such as those in Vermont, California and Nevada. To the extent these state laws apply, we will comply with them when we share information about you. For example, Vermont law places additional limits on sharing information about Vermont residents. As long as they remain residents of Vermont, we will not share information we collect about Vermont residents to companies outside of Infinity Commercial Capital, except:

• To companies that perform marketing or other services on our behalf;
• Contact information (like name and address), to other financial institutions with which we have joint marketing agreements;
• With the authorization or consent of the Vermont resident; or
• As permitted or required by law.

We also will not share credit information about Vermont residents received from others within Infinity Commercial Capital except with the authorization or consent of the Vermont resident.

For Nevada residents: At any time, you may request to be placed on Infinity Commercial Capital's internal do not call list by contacting our office at (248) 615-7771. Nevada law also requires that we provide you with the following contact information: