I. ABOUT THIS PRIVACY STATEMENT

This Privacy Statement ("Statement") explains how Eastern Credit Wave collects, uses and shares Personal Information, from or about you in connection with our products and services, as well as when you use CIT’s websites or mobile applications that link to this Statement (each, a “Site”, and collectively, “Sites”).

Throughout this Statement, we refer to "Personal Information", which means information that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with you or your household. Personal Information does not include Public Information (for example, information from federal, state or local government records), Aggregated Information (information relating to multiple individuals that has been combined and grouped together, resulting in a data set that is not reasonably capable of identifying any individual) or De-identified Information (information that is not attributable to an identified or identifiable individual).

California Consumers have certain rights under the California Privacy Rights Act of 2020 (“CPRA”) with respect to their Personal Information. A “California Consumer” is a natural person who resides in California. For further information, please see our CPRA Privacy Notice for California Residents.

If you are an individual and have a CIT financial product or service for your personal, family or household purposes, please see our CIT Consumer Privacy Notice for additional details about how we use and share Personal Information that we collect in connection with providing you those financial products or services.

II. HOW WE COLLECT, USE AND SHARE PERSONAL INFORMATION

How we collect Personal Information

The types of Personal Information we collect depends on your interaction with us, including the types of products or services you applied for or use. We, or entities that we contract with to provide services to support our business and delivery of our products and services (“Service Providers”), may collect Personal Information:

• * Directly from you, such as when you apply for or obtain one of our products or services, or if you apply for a job with us;
• * From financial and non-financial companies related by common ownership or control (our “Affiliates”), based on your relationship with them and as permitted by law; and/or
• * From other entities that we work with who are not Service Providers (“Third Parties”), such as credit bureaus or marketing partners.

We (or our Service Providers) may also collect Online Information, such as IP address, browser or device information, or other information about you directly or indirectly through interactions with our Sites, applications, or ads, such as:

• * The internet address (referral site) which brought you to the Site;
• * The types of devices you use to visit our Sites and interact with us such as device, operating system, web browser, and the IP address;
• * Your device’s browsing history on our Sites and the time and duration of your visit;
• * Information about the ads or content from us (or our Service Providers) that you view, access or click on;
• * Information that is collected through Cookies, Web Beacons, and/or mobile ad identifiers as described below;
• * Your contact lists, photos, or access to your camera, when you request certain services that require such access, and only with your consent.

Though Online Information may not, alone, reveal your specific identity, some of this information may be used or associated with Personal Information, or may itself be considered Personal Information. Please see Section III for more information.

How we use Personal Information

We (or our Service Providers) may use Personal Information for the following business purposes:

To deliver products, information, or services, including to:

• * complete transactions;
• * provide account services;
• * recognize and remember you when you visit our Sites;
• * improve our Sites and make them easier to use, and provide you with an overall improved experience on our Sites;
• * notify you about updates to your accounts, products, and/or services;
• * perform quality assurance activities that maintain the quality of services provided to you; or
• * respond to your inquiries.

To provide advertising about our products and services, including:

• * sending marketing materials inclusive of special offers, email notifications, or other notices regarding CIT’s products, services, or news; or
• * presenting personalized content or tailored ads that may relate to your interests and/or location.

To manage security risks and prevent fraudulent activity, including to:

• * detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activities;
• * debug to identify and repair errors that may impair existing intended functionality;
• * maintain a secure session, authenticate your computer and verify transactions;
• * verify your identity such as when you apply for an account or access our online/mobile services; or
• * assess your creditworthiness, including obtaining credit reports if you apply for credit or apply for a financial product or service.

To conduct employment-related activities at CIT, including to:

• * perform background checks;
• * deliver employee benefits programs; or
• * contact references you provide during your application process.

To perform other activities, as permitted or required by law, including:

• * to perform internal research;
• * in connection with litigation;
• * to comply with regulatory record retention requirements;
• * to perform analytics concerning your use of our online services, including your responses to our emails and the pages and advertisements you view; or
• * for audit purposes within our organization.

How we share Personal Information

We may share your Personal Information, as permitted or required by law with:

• * Our Affiliates;
• * Service Providers;
• * Regulatory authorities or governmental agencies to meet regulatory or legal requirements; or
• * Third Parties, with your consent or as permitted by law.

How we retain Personal Information

We retain Personal Information for as long as necessary to fulfill the purpose(s) for which they were obtained, unless a longer retention period is required by law. The criteria used to determine our retention periods include:

• * The length of time we have an ongoing relationship with you;
• * Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• * Whether retention is advisable based on our legal position, such as applicable statutes of limitations, litigations, or regulatory investigations.

Special Considerations for Minors

Our Sites are not intended for children under 16 years of age and we do not knowingly market our products or services to children.

First Citizens does not knowingly collect or retain Personal Information from individuals under the age of 13. Visit the Federal Trade Commission website for more information about the Children’s Online Privacy Protection Act (COPPA).

III. ADDITIONAL INFORMATION ABOUT ONLINE INFORMATION

Online Information

When you visit or browse our Sites, we may collect Online Information as described in Section II of this Statement. The purpose of collecting this information is to improve the effectiveness of our Sites and product offerings. The collection of this information also allows for the compilation of De-identified and Aggregated Information that can help us improve our Sites and product offerings.

Links to Other Sites and Other Privacy Policies

Our Sites may contain links to other parties’ websites. When you click on these links, you may be providing information, including Personal Information, to the other party, us, or both. CIT has no control over the privacy practices or content of these linked websites, so we recommend that you carefully review the privacy policies or statements of every other party website that you visit.

Online Behavioral Advertising, “Cookies”, and Similar Technologies

CIT and our digital Service Providers and Third Parties (e.g., Google or Facebook) may use Cookies, Web Beacons, mobile advertising identifiers, and other technologies for the purposes of delivering tailored advertising to you across the internet, and to help manage and optimize our internet-business and communications. “Cookies” are pieces of data stored by your browser and used by web servers to uniquely distinguish your browser from all others and remember your browser over time, including preferences and other information. “Web Beacons” are small image files that are loaded when a web page or other online resource is processed by your browser (including when emails are opened). Should you configure your browser to reject Cookies, you may disable some of our online service's features.

We use the following types of Cookies:

• * Performance Cookies: These Cookies let us count visits and traffic sources to measure and improve the performance of our Sites. They help us know which pages are the most and least popular and help us understand how visitors move around the Site.
• * Marketing Cookies: These Cookies collect information to help us market our products and services. Online Information, including digital identifiers, may be collected through these technologies (e.g., Google Analytics) and may be shared with Service Providers and Third Parties to conduct analytics and/or to display ads based on a user’s experience on our Site and/or other websites.
• * Strictly Necessary Cookies: These Cookies are necessary for the Site to function and enable you to use its services and features. Without these Cookies, our Site could not perform certain functions or offer certain services or features.
• * Functional Cookies: These Cookies enable the website to provide enhanced functionality and personalization. They may be set by us or our Service Providers.

IV. CHOICES RELATED TO HOW WE USE PERSONAL INFORMATION

You have choices about how we use your information, including what kinds of marketing you want to receive from us.

You can opt-out of having Third Parties use your web browsing behavior to serve our interest-based ads by clicking the Your Privacy Choices link in the footer of this page and turning off Marketing Cookies. You may still see advertisements while you are browsing online; however, the advertisements you see may be less relevant to you and your interests. Please note this opt-out works via Cookies, so if you delete Cookies, use a different device, or change web browsers, you will need to opt-out again.

You can also opt-out of receiving marketing offers via email, telephone or direct mail. Offers may include instructions on how to opt-out, or if you prefer, please call 855-462-2652. We will still contact you for transactional purposes, such as to service your account or respond to an inquiry.

Do-Not-Track Signals

We currently do not employ technology that changes how our servers treat your browser if our servers receive a "do-not-track" signal since there is currently no universal standard on how to apply these settings.

V. HOW WE PROTECT THE CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION

To protect your Personal Information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. Only people who have a legitimate business reason to do so in connection with their job responsibilities are authorized to access customer information. For further information, please see our Privacy & Security page.

VI. CHANGES TO THIS STATEMENT

This Statement is subject to change. If we make changes to this Statement, we will revise the “Last Updated” date at the top of this Statement. Your use of the Site means that you accept the terms of this Statement.

Any dispute related to this Statement will be governed by our Terms of Use.

VI. CONTACT FOR MORE INFORMATION

If you have questions or concerns about CIT’s privacy practices or this Statement, please contact us:

Mail
62/63 Cheapside, London EC2V 6BP, United Kingdom
Telephone: +1 401-227-0740
Email: Support@easterncreditwave.com