RV  FINANCING  USA, INC.

PRIVACY   POLICY

Effective September 13, 2004

While information is the cornerstone of our ability to provide superior service, our most important asset is earning our customer's trust.  RV Financing USA, Inc. maintains practices and procedures designed to ensure the security, integrity and confidentiality of customer information.

Topics:

• Privacy Notice of RV Financing USA, Inc.
• Questions and Answers about our Privacy Notice.
• What are my financial Privacy Rights?
• Who is covered by this Privacy Notice?
• Who is information disclosed to?
• What financial information is covered by the Privacy Notice?
• What are our information sharing (Disclosure) Policies and Practices?
• What information do we share with our affiliates?
• What information do we share with non-affiliated “third” parties?
• Who are the non-affiliated "third" parties we disclose information to?
• Are the non-affiliated "third" parties that receive my information required to protect it?
• What is "Sharing as otherwise Permitted by Law"?
• Why isn't there an “Opt Out” provision attached to my privacy notice?
• Information Security Practices
• Online Security Practices
• What information do we collect online?
• What information do we share?
• How do we ensure the security of your information?
• How will you be notified regarding changes in the on-line policy?
• Children's information

PRIVACY NOTICE OF RV FINANCING USA, INC.

Our privacy Policy is designed to protect the information you give us while providing you with valuable financial service.  Please read this important Privacy Notice which describes your financial privacy rights.  This Privacy Notice informs you of the types of nonpublic personal information we collect about you, how we use that information, and the circumstances under which we share that information with affiliates and non-affiliated “third” parties.

This Privacy Policy applies only to customers or former customers (“you”or “your”) who obtain or have obtained a financial product or service primarily for personal, family, or household use.  We may revise this Privacy Notice at any time and will notify you, as required by law.

Information We Collect

We collect nonpublic personal information about you (personally identifiable financial information, which you provide us, that results from, or we otherwise obtain, in connection with your transactions or services we perform for you) from the following sources:

• Information we receive from you on applications or other forms, or by other means, such as your name, address, income, and assets;
• Information about your transactions with us, our affiliates, or others, such as your account balance and payment or claims history; and
• Information we receive from third parties, such as consumer reporting agencies, employers and federal and state agencies.
• The types of nonpublic personal information RV Financing USA collects varies according to the products and services provided.

Information We May Share

We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law.  These exceptions may include disclosing information to third parties assisting us in servicing and processing you credit account, in response to subpoenas, to credit bureaus, and others.

We may disclose all types of nonpublic personal information we collect for:

(i)  other financial institutions (banks) with which RV Financing USA has entered into an        agreement to provide underwriting and/or term financing.

(ii) extended warranty service providers for applicable coverage which may benefit you.

Safeguarding Your Information

We restrict access to nonpublic personal information about you to those persons employed by us who have a legitimate business need to know that information to provide products or service to you.  We safeguard information according to established security procedures.  Our employees are trained to understand and comply with these information principles. 

QUESTIONS & ANSWERS ABOUT OUR PRIVACY NOTICE

WHAT ARE MY FINANCIAL PRIVACY RIGHTS?

In 1999, Congress passed a new federal law that gave American consumers important financial privacy rights.  The law was passed in response to concerns from consumers that they did not have enough information about how their financial information was being used, safeguarded and protected by financial institutions.  Consumers were also concerned that they could not limit the amount or types of information that were disclosed to third parties, particularly for marketing purposes.  The new law, Title V of the Gramm-Leach Bliley Act of 1999 (15 U.S.C. 6801-6810), required financial institutions to develop privacy policies regarding their information sharing practices.  Those policies must be communicated to consumers when they enter into financial transactions, annually thereafter, and whenever financial institutions change their policies.

Our Privacy Notice explains the information we collect and retain about our customers and former customers, who that information is disclosed to, and how that information is used and safeguarded.  In addition to the privacy rights you have under the Gramm-Leach-Bliley Act of 1999, you may have other privacy protections under federal and state laws, and we will comply with applicable laws when w disclose information about you.

We reserve the right to make changes to our Privacy Policy at any time, and will notify you if we do so, as required by law. 

WHO IS COVERED BY OUR PRIVACY NOTICE?

RV Financing USA, Inc. and it's subsidiaries, to  include Boat Financing USA, are financial service companies providing quality lending and sales financing advice   to our consumer customers.  In our Privacy Notice, “we,” “our,” and “us” mean and include the following:

  ! RV Financing USA, Inc., BOAT Financing USA, Inc.

“You” and “your” mean customers or former customers who obtain or have obtained financial products and services from us in the United States for a primarily personal, family, or household purpose.

WHO DO WE DISCLOSE INFORMATION TO?

We do not disclose any nonpersonal personal information about our customers or former customers to anyone, except as permitted by law.  These exceptions may include the following:

• To any of our affiliates (companies that are in the same corporate family as RV Financing USA because of common ownership)
• To various non-affiliated third parties (parties that are not under common ownership) in order to (i) perform services for or functions on behalf of us or to offer financial products or services jointly with another institution; (ii) to service and process your accounts with us; or (iii) as otherwise permitted by law.

WHAT FINANCIAL INFORMATION IS COVERED BY THE PRIVACY NOTICE?

The financial information that may be disclosed to affiliates or non-affiliated third parties refers to all the nonpublic personal (personally identifiable) information about you that we collect when we provide you with a financial product or service (for instance, processing your transactions  and servicing you account).  It does not include publicly-available data from sources such as telephone directories or government records.  Nonpublic personal information includes (i)    information you provide us; (ii) information that results from your transactions; and (iii) information we otherwise obtain in connection with you transactions or while performing services for you.  We collect and retain the following categories of information about you.

• Information that you have given us (such as your name, address, income, assets and debt) from applications, and other forms, and by other means, such as online, as well as from correspondence and communication by mail, fax, telephone, and e-mail.
• Information obtained through non-affiliated third parties, including the following:
• Credit history and creditworthiness data from consumer reporting agencies to evaluate your eligibility for financial products and service.
• Verification of information by outside sources (such as employment history)
• Information about your transactions and experiences with non-affiliated third parties (data that is collected solely about your relationships, such as account balances, types of accounts, parties to transaction, security and collateral, account activity and usage, payment and transaction history);
• Information about your transactions and experiences with affiliates or with us.

WHAT ARE OUR INFORMATION SHARING (DISCLOSURE ) POLICIES AND PRACTICES?

As described above, we restrict the information that we share about you with affiliates and non-affiliated third parties.  The law provides for certain exceptions that are considered necessary for financial institutions to conduct every day business and provide services to you.  The following explains the disclosures that are permitted by current law.

WHAT INFORMATION DO WE SHARE WITH NON-AFFILIATED THIRD PARTIES?

Federal law allows us to share information about your transactions and experiences (data that is collected solely about your account relationships, such as account balances, types of account, parties to the transaction, security and collateral, account activity and usage, payment and transaction history, and claims history) with our affiliates.  These affiliates may include financial service providers that engage in sales finance activities, servicing, leasing, loan brokering, lending, service agreement administration, insurance, account aggregation, banking, and securities brokerage.

We may share all the data we collect about you (more than just transactions and experiences) with affiliates in order to service and process your accounts with us.

WHAT INFORMATION DO WE SHARE WITH NON-AFFILIATED THIRD PARTIES?

As permitted by law, we may disclose any of the information we collect and retain about you to non-affiliated third parties who perform services for or functions on our behalf, including the marketing of our own products or services (we do not disclose information to outside marketers for their own marketing purposes).  Federal law also permits us to disclose all of the information we collect and retain about you to other financial institutions with whom we have joint marketing agreements.  Joint marketing agreements allow us and other financial institutions to jointly offer, endorse, or sponsor financial products and services that may interest you.  We require these third parties to use the information only for the purpose for which it was disclosed.

We may disclose any of the information we collect about you to non-affiliated third parties in order to process and service your accounts with us.  The following are some of the examples of when we disclose information to carry out day-to-day business transactions.

• As necessary to carry out, administer, complete or enforce transactions that you have requested or authorized.
• To service or process a financial product or service you have requested or authorized.
• To record, maintain, or service your accounts with us, or another entity as part of an extension of credit on behalf of that entity.
• To administer or service benefits or claims relating to a transaction.
• To effect a proposed or actual securitization, secondary market sale, or similar transaction related to your account.
• To accrue or obtain incentives that are provided by us or any other party in connection with a transaction.
• To underwrite insurance at your request or for reinsurance purposes, or for any of the following purposes as they relate to you insurance: account: administration, reporting, investigating, or preventing fraud or material misrepresentation, processing insurance claims, administering insurance benefits (including utilization review activities), or as otherwise requires or specifically permitted by federal or state law.

WHO ARE THE NON-AFFILIATED THIRD PARTIES WE DISCLOSE INFORMATION TO?

The financial service providers that we may contact with to provide us with services or for joint marketing agreements include financial institutions that engage in sales finance activities, loan brokering, servicing, lending, leasing, service agreement administration, insurance operations, account aggregation and banking. 

ARE THE NON-AFFILIATED THIRD PARTIES THAT RECEIVE MY INFORMATION REQUIRED TO PROTECT IT?

We require the companies with whom we conduct business to comply with the same privacy laws and regulations that apply to us, which may include confidentiality clauses in our contracts, and limitations on the use, reuse, and the redisclosure of the information that was provided to those companies.  We only permit non-affiliated third parties to use the information we disclose to them for the limited purposes for which it was disclosed (they may not use the information to market their own products and services), and as otherwise permitted by law.

Subject to a few limited exceptions, we not disclose the account number or similar form of access number or access code for your transaction accounts to any non-affiliated third party (other than a consumer reporting agency) for use in the marketing of that party's products and services.

WHAT IS “SHARING AS OTHERWISE PERMITTED BY LAW”?

We may disclose any of the information that we collect and retain about you under the following circumstances:

• With your consent or at your direction.
• To resolve your disputes or inquiries.
• To report on the existence and status of your account with a credit reporting agency, in accordance with the federal Fair Credit Reporting Act.
• To comply with a law, regulation, legal process or court order which applies to us or an affiliate, as permitted or required by law.
• To local, state or federal authorities, if we believe a crime may have been committed, and/or to protect against or prevent actual or potential fraud, unauthorized transactions, claims or other liability.
• In response to requests by our regulatory agencies or requests by our or our affiliates' agents, such as independent auditors, consultants, or attorneys.
• To effect a proposal or actual sale, transfer, merger, or exchange of all or a portion of our business.
• To protect the confidentiality and security of our records.
• To persons holding a beneficial or legal interest relating to your transactions.

WHY ISN'T THERE AN OPT OUT PROVISION ATTACHED TO MY PRIVACY NOTICE?

Since we currently limit our disclosure of your information in accordance with specific exceptions under the law (described above), no opt out is required. If we want to share additional information beyond the exceptions at some point in the future, we will send you an opt out, as required by law, as well as a new Privacy Notice.

INFORMATION SECURITY PRACTICES

RV Financing USA and its subsidiaries maintain practices and procedures designed to ensure the security of your information (as well as the information systems that maintain your information) from a variety of risks.  Access to you information is limited to those persons employed by us, and are required to protect confidential and sensitive information at all times.

ONLINE SECURITY POLICY

Our goal is to protect the information that is collected about you over the Internet as stringently as that collected in person or by any other means.  In general, you can visit our Web sites without telling us who you are or revealing any information about yourself.  However, if you utilize our Web sites to conduct financial transactions (such as to submit a credit application), we must then collect personal information in order to serve your financial needs.

WHAT INFORMATION DO WE COLLECT ONLINE?

When you visit our web pages, our web server automatically recognizes the visitor's domain name but not the e-mail address.  The information we collect by this means is used only to improve the content and layout of our Web sites.

WHAT INFORMATION DO WE SHARE?

For customers or former customers who obtain financial products and services primarily for personal, family and household purposes, we will only share nonpublic personal information in accordance with the Privacy Notice described above.

HOW DO WE ENSURE THE SECURITY OF YOUR INFORMATION?

RV Financing USA is protected by a system of filtering routers and firewalls, which form a barrier between the outside Internet and internal network.  The filtering router verifies the source and destination of each network packet, and determines whether or not to let the packet through.  Access is denied if the packet is not directed at a specific, available service.

The firewall is used to shield RV Financing USA's client service network from the internet.  All incoming IP traffic is actually addressed to the firewall, which is designed to allow only e-mail into the client service environment.  Traffic through the firewall is subjected to a special proxy process which operates in much the same way as a filtering router, verifying the source and destination of each information packet  The proxy then changes the IP address of the packet to deliver it to the appropriate site within the client service network.  In this way, all addresses are protected from outside access.

CHILDREN'S INFORMATION

We do not knowingly collect or retain personally identifiable information from consumers under the age of 13.