Your privacy is important to Arrow. The following Privacy Notice applies to current and former individual customers. We collect and use nonpublic personal information ("information") about you to conduct and manage our business.

• Information we receive from your original creditor and from applications submitted by you to the original creditor;
• Information we receive from you through correspondence or communication with us, whether by mail, telephone, or the Internet, and which may include your name, address, Social Security Number, assets, income, or other information you provide;
• Information about your transactions with us, our affiliates, or others, such as your account balance and payment history;
• Information we receive from third parties, such as consumer reporting agencies.

We only disclose information to affiliated and non-affiliated third parties as permitted or required by the federal Fair Debt Collection Practices Act ("FDCPA"). We may share information we collect with third parties that provide mailing and/or other collection-related services to us. When we share your information with these companies, they are required to limit their use of your information to the particular purpose for which it was shared and they are not allowed to share it with others except to fulfill that limited purpose. In addition, if permitted by FDCPA, we may also share your information with our affiliates and non-affiliated third parties if also permitted by applicable law.

We restrict access to nonpublic personal information about you to those employees who need to know that information to service your account or manage our business. We maintain physical, electronic, and procedural security measures to protect your information. You may have other privacy protections under state laws. The effective date of this notice is February 1, 2005. It replaces all prior privacy policies issued by Arrow Financial Services LLC or any other Arrow company. We reserve the right to amend this privacy notice at any time and we will inform you of any changes to this notice as required by law.

This notice is made on behalf of Arrow Financial Services LLC and all companies, trusts or other special purpose entities established by any Arrow company.

Privacy Notice - Canada

Your privacy is important to AFS US, Inc.

We collect and use personal information about you (“Information”) to conduct and manage our business. Sources of Information include the following:

• Information we receive from your original creditor and from applications submitted by you to the original creditor, such as your name, address, Social Insurance Number, e-mail address, telephone number, account balance and payment history;
• Information we receive from you through correspondence or communication with us, whether by mail, telephone, or the Internet, and which may include your name, address, Social Insurance Number, assets, income, or other information you provide;
• Information about your transactions with us and our affiliates, such as your account balance and payment history;
• Information we receive from third parties, such as information about your credit history from consumer reporting agencies;

We use Information only for the purpose of collecting your accounts.

We disclose Information to affiliated and non-affiliated third parties, including consumer reporting agencies, for the purpose of collecting your accounts only if permitted or required by all applicable laws, rules and regulations of the United States and of Canada including, but not limited to, laws, rules and regulations relating to debt collection, personal information privacy, and consumer reporting (collectively, “Applicable Law”).

We may also share Information with third parties that provide mailing and/or other collection-related services to us. When we share Information with these companies, they are contractually required by us to limit their use of Information to the particular purpose for which it was shared and they are not allowed to share it with others except for that limited purpose.

We restrict access to Information to those employees who need to have access to Information for collection purposes or to manage our business. We maintain physical, electronic, and procedural security measures to help protect Information.

We may store and use Information in facilities located in the United States. As a result, when this is done Information may be subject to disclosure pursuant to laws or regulations in effect in the United States, which may differ from Applicable Law in Canada.

If you have any questions about our privacy practices, please contact us at (866) 758-7809 or canadian.privacy@arrow-financial.com.

The effective date of this notice is February 1, 2008. It replaces all prior privacy policies issued by AFS US, Inc. We reserve the right to amend this privacy notice at any time and we will use reasonable efforts to inform you of any changes to this Privacy Notice.

This Privacy Notice is made on behalf of AFS US, Inc., and all affiliated companies, trusts or other special purpose entities established by AFS US, Inc. It applies to current and former individual customers of AFS US, Inc.