1st Credit Cards Issuer Privacy Statement

Protecting Consumer Privacy

Direct Merchants Credit Card Bank, N.A. ("1st Credit Cards Issuers") recognizes that protecting consumer privacy is one of the fundamental responsibilities we have to our customers and potential customers. 1st Credit Cards Issuers gathers information from applicants and customers for our own business needs and to offer customers products and services we think may be of value to them. Because customers trust us to use their information in this manner, we adhere to the following guidelines in order to safeguard consumer information and ensure it is used only for the purposes described below.

Data Security
1st Credit Cards Issuers relies heavily on information to meet its business objectives and to serve its customers. Data is a critical asset to 1st Credit Cards Issuers and a system of internal controls exists to safeguard these assets. Management of 1st Credit Cards Issuers promotes policies, standards, controls and procedures that meet 1st Credit Cards Issuers's needs to secure information. Management sets parameters to limit access to customer information to only those employees with a defined need for such access. Management ensures that 1st Credit Cards Issuers's physical premise and computer systems are secure and that customer information is properly stored and/or disposed of.

Data Accuracy
1st Credit Cards Issuers believes keeping customer information accurate and up to date is critical. Customer information is verified and updated through Customer Service with every customer phone interaction. In addition, customers are encouraged to contact Customer Service in order to verify and correct their information as necessary.

Data Collection
1st Credit Cards Issuers collects the following categories of information on its customers:

• Identifying information such as name, address, phone number, social security number and mother's maiden name.
• Application information such as birth date, employment status, occupation, income, home ownership, and work phone.
• Transaction information such as account number, payment and balance history.
• Relationship history, credit histories and credit scores from credit bureaus and third parties.

Data Sharing
1st Credit Cards Issuers shares customer information under the following guidelines:

• Affiliate Sharing - 1st Credit Cards Issuers shares information with its Metris Companies Inc. affiliates. The information 1st Credit Cards Issuers shares with affiliates includes identifying data, application data, transaction data, and credit bureau data. As required by law, customers are given the right to direct 1st Credit Cards Issuers to not share their information with affiliates.
• Non-Affiliate Sharing - 1st Credit Cards Issuers shares information with third parties for the purposes of those companies offering their products and/or services to 1st Credit Cards Issuers customers. The information 1st Credit Cards Issuers shares with third parties is limited to identifying data only. When sharing data with non-affiliates, Management of 1st Credit Cards Issuers ensures the third party maintains the customer data in a confidential, secure manner, and that the data is only used for the purpose it was intended.

Data Sharing with Service Providers
1st Credit Cards Issuers shares information with other companies we engage to help deliver our products and services to our customers. The information 1st Credit Cards Issuers shares with service providers is limited to the information required to perform the contracted service and may include identifying data, application data, transaction data, and credit bureau data. When sharing data with service providers, Management of 1st Credit Cards Issuers ensures the service provider maintains the customer data in a confidential, secure manner, and that the data is only used for providing the service to 1st Credit Cards Issuers and for no other purpose.

Data Sharing with Marketing Alliances
1st Credit Cards Issuers shares information with other companies we engage to jointly offer products and services to our customers. The information 1st Credit Cards Issuers shares with these companies is limited to the information required to offer the product and/or service and may include identifying data and transaction data. When sharing data with marketing alliances, Management of 1st Credit Cards Issuers ensures the data is maintained in a confidential, secure manner, and that the data is only used for the purpose it was intended.

Data Sharing in Other Circumstances
1st Credit Cards Issuers shares data in other appropriate situations, and only to the extent permitted by law, such as:

• With credit bureaus or other similar reporting agencies;
• With regulatory agencies and auditors;
• When we might sell or merge parts of our business; and
• As required by law (e.g. subpoenas).

If you would like to direct us to not share your information with affiliates and non-affiliates, you can do so by going to "Contact Us" on our home page (www.directmerchantsbank.com). Please provide your name, address, and account number and ask to be added to our Do Not Share list. Due to processing requirements, it may take 4 - 6 weeks for your request to be completed.

Protecting Consumer Privacy on the Internet
We recognize that protecting consumer privacy is one of the fundamental responsibilities we have to both our customers and potential customers.

The following describes how we collect, use and protect the information we learn about you from your visit to our website.

When you visit our site, we collect and store only the following information: your requesting IP (Internet address); the type of equipment you used to access our site (PC, Macintosh, WebTV, etc.); the type of browser you used (Internet Explorer, Netscape, etc.); the date and time of your visit; and any links or URLs you may have used to access our site.

We use this information to learn more about how many people visit our website, how they accessed our website, how our website is utilized, and to help us make our website more accessible and useful for future visitors.

When visiting our website, you may also choose to provide us with personally identifying information. This is done when you apply for one of our products or when you enroll in one of our services. We will use the information you provide to evaluate your application and/or to enroll you in the service you request.

We keep your information secure. When you provide information to us, it is sent through a "secure session" established with Secure Soc-ket Layer (SSL). This technology protects your information while it is transferred over the Internet. Our systems protect your information from access by others using industry standard encryption and security technologies.