Arrow Financial Services LLC is a leading purchaser, servicer and data processor of performing and non-performing consumer debt. Arrow currently manages receivables on both debt purchased for our own accounts, and on behalf of other credit grantors (contingency and first party) and debt purchasers.

Arrow Financial Services LLC recognizes that privacy is very important to our clients, and we pledge to protect the security and privacy of any personal information that clients send to us for processing. In its capacity as a service provider for European clients, Arrow Financial Services LLC processes personal data including: names and surnames, Tax Identification Number (NIP), parents' names, place of work, date of birth, occupation, place of birth, education, place of residence, identity card number, Personal Identification Number (PESEL), and telephone number.

We restrict access to personal information to those employees who need to know that information to service the data or manage our business. We maintain physical, electronic, and procedural security measures to protect personal information. The effective date of this notice is May 15, 2006. We reserve the right to amend this Safe Harbor notice at any time.

Arrow Financial Services LLC strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business and it also has a tradition of upholding the highest ethical standards in its business practices. This Safe Harbor Privacy Policy (the "Policy") sets forth the privacy principles that Arrow Financial Services LLC follows with respect to transfers of personal information between the European Union (EU) and the United States.

Arrow Financial Services LLC is committed to protecting the privacy of personal data that is gathered and maintained on behalf on behalf of our clients. We certify that, in relation to personal data collected in the EU, we adhere to the seven "Safe Harbor Principles" of the United States Department of Commerce as outlined in the European Commission's Directive on Data Protection. Our adherence to the seven Safe Harbor Principles is demonstrated below:

Notice and Choice

Arrow Financial Services LLC does not disclose European personal information to third parties. We store personal information from individuals only as permitted by the Principles and with authorization from the Data Controller. To the extent permitted by the Safe Harbor Agreement, we reserve the right to process personal information in the course of providing professional services to our clients without the knowledge of individuals involved. Under these agreements, the EU client is responsible for providing notice to its customers as to what data will be collected and for what purpose the data will be used. The EU client is also responsible for receiving consent, if required, based on such notice.

Onward Transfer (Transfers to Third Parties)

With respect to the transfer of consumer data to third parties, the principles of "Notice" and "Choice" apply. Accordingly, data is only stored and processed according to the provisions in the contract between the client and Arrow Financial Services LLC. Arrow Financial Services LLC does not transfer any EU personal information to third parties.

Access

Individuals may request, in writing, to the EU client, access to all data that is in Arrow Financial Services LLC's possession. Arrow Financial Services LLC affords the individual a reasonable opportunity to correct, amend, or delete information that is inaccurate or incomplete, except where the burden or expense of providing access would be disproportionate to the risks to the individual's privacy, or where the rights of persons other than the individual would be violated.

Arrow Financial Services LLC makes every effort to ensure that the data we store or process is as accurate as possible. If the EU client advises Arrow Financial Services LLC that the information pertaining to an individual is found to be inaccurate, Arrow Financial Services LLC will correct, amend, or delete it as directed by the EU client.

How to Apply for Access to Personal Data. To request information relating to personal data you may contact the Data Controller in writing.

Security

Arrow Financial Services LLC takes all reasonable procedures to protect personal and identifiable information from loss, misuse and unauthorized access, disclosure, alteration and destruction. All data transmissions to and from our clients are encrypted. All of our users' information, not just the sensitive information mentioned above, is kept strictly confidential in our offices. Only employees who are authorized by the Data Controller have access to the information. Strong password protection protocols are used on all computers and all employees are kept up-to-date on our security and privacy practices. Physical access to the servers that are used to store personally identifiable information are kept in a secure environment, with appropriate security measures. Any questions about the security precautions can be sent to the contact person listed below.

Data Integrity

Arrow Financial Services LLC takes reasonable steps to ensure that data collected is accurate, complete, current, and reliable for its intended use. We only process data that is strictly necessary for the purposes listed under the section entitled "Notice," including (but not limited to) information that is necessary to identify the consumer.

Enforcement

Arrow Financial Services LLC verifies adherence to the EU Safe Harbor Policy via in-house verification by the management of this company. In addition, Arrow Financial Services LLC has a compliance department and internal auditors which audit Arrow Financial Services LLC's compliance with this policy and its Safe Harbor commitment.

You may send any question regarding our Privacy Policy to the following address and contact person:
Brian Cutler, Executive Vice President & Chief Technology Officer
Arrow Financial Services LLC
5996 W Touhy Ave
Niles, IL 60714
United States of America
safeharbor@arrow-financial.com
*Any changes that are made to the Safe Harbor Privacy Policy of Arrow Financial Services LLC will be posted on this website.