November, 2007

Virgin Money USA, Inc. (Virgin Money) is a business built on trust. You entrust us with sensitive personal, financial and relationship information. We fully appreciate and respect the private nature of this information; we use it with discretion for lawful purposes and take great care to protect it. Here’s how.

1. We Exceed Industry Standards

• We provide you notice of our policies. This is often called disclosure. You’re looking at it. We’ll send you this notice once a year, you can find it on our website and if you have questions contact us at privacy@virginmoneyus.com or by submitting an inquiry on our website.
  
  
• We offer you choice about how your personal information is stored and used. If you want to make a change in how we handle your information, let us know. Email us at privacy@virginmoneyus.com and we’ll adjust according to your wishes. 
  
  
• You can access your information. Want to view, fix or update your information? Send an inquiry to privacy@virginmoneyus.com (but it’s not safe to send private information by email) or log on to our secure website. Checking your account on our website is the best and safest way to alert us of any potential discrepancy.
  
  
• We assure you that information you provide us is secure. We use online and financial security technologies that preserve confidential information. When we believe we can enhance the security of your information, we will adopt additional measures appropriate to the dynamic online environment in which we operate.
  
  

In addition to these best practices, Virgin Money conducts business in accordance with laws and regulations relating to our products and services, including the Financial Services Modernization Act of 1999, a federal law commonly known as the Gramm-Leach-Bliley Act (“GLB”). Under GLB, an individual’s nonpublic personal information (“NPPI”) is afforded certain legal protections. Virgin Money abides by and endorses the philosophy underlying these pertinent laws. Abiding by best practices and pertinent laws isn’t an obligation; it’s just plain right.

Anyone wishing to permanently “opt out” portions of the information gathering and sharing process we currently use or may employ in the future is free at any time to contact Virgin Money at support@virginmoneyus.com, and we will work to honor your request.

2. We respect your information.

• We only ask for and use information needed for business purposes, and when lawfully permitted or necessary to comply with legal requirements.
  
  
• We limit internal access to information to personnel having legitimate business reasons. 
  
  
• We disclose customers’ information only for appropriate business purposes, when we have permission, when we are obliged by competent authorities or upon consent of the individual customer. For example, we do exchange certain information with our customers’ financial institutions (such as when Virgin Money needs the routing number for direct deposit into a lender’s bank account); we do so with express permission and solely to satisfy the needs of the loan. 
  
  
• To guard against “downstream” or third-party disclosure of your information, we may require that entities such as your financial institution and our business partners be required to demonstrate compliance with applicable laws and regulations and compatibility with this Privacy Policy. If we learn or believe that a third party poses a risk to your information, we may contact you (and, if appropriate, regulators and law-enforcement officials) to express that concern.
  
  

The GLB mentioned previously allows sharing of customer information among affiliates, also known as sister companies. Virgin Money customers might welcome information and special offers from other Virgin businesses and we plan to work with these affiliates to develop compelling offers. Aside from these affiliates, we neither sell nor share information gathered during the course of our business, except as authorized.

If you tell us not to share information about you with our affiliates, we will honor your instructions. Please note that if you choose not to hear from us, you will not receive offers about products and services offered by Virgin Money and our affiliates that may be of value to you.

3. We protect your privacy.

Applicable privacy laws distinguish between a “consumer” and a “customer.” Here’s how that plays out at Virgin Money.

• Consumer privacy. If you are visiting our website because you’re considering our services, then your privacy is protected as a consumer. This means that even if you’re not a full-fledged Virgin Money customer, we will not share collected information, except as permitted by law. 
  
  
• Customer privacy. Customers are consumers who enter into more complex or enduring relationships with us. In addition to consumer protections, our loan customers can expect secure information storage, and annual privacy notices. 
  
  
• Past Customer privacy. Even after a loan agreement ends, Virgin Money will continue to treat your information as though you actively remain our customer. We abide by applicable record-retention and privacy rules even after a loan has been repaid or otherwise has come to a close.
  
  

Please note that Virgin Money will furnish pertinent information where compelled or in order to comply with relevant law, in response to a subpoena, court order and other judicial processes, or as required by competent regulatory authorities.

4. What You Can Do

Fully shielding your information is a team effort and responsibility. You can:

• protect your Virgin Money password and similar login information. 
  
  
• never send confidential information to us by email. 
  
  
• use our secure online environment or call a customer service representative to submit confidential information. 
  
  
• review this policy when we send it annually, or on our website.
  
  

5. Special Case: Medical Information

6. Permission Marketing

7. And finally, regarding updates to this policy

© 2007 Virgin Money USA, Inc. All rights reserved.