Grand Castle, Inc. and its affiliates, are committed to providing the highest level of security and privacy regarding the collection and use of our user's personal information, as well as that of all visitors to our web site. Personal information may be collected through the submission of registration information, bid submission and through online communications. We recognize the importance of respecting the privacy of our users and we hope that the following privacy statement will help you understand how Grand Castle, Inc. collects, uses and safeguards the personal information you provide to us on our website. We are required by law to give you this privacy notice. It describes our policies and practices that protect your

privacy and enable us to share information to provide you with competitive financial products and services. If you have any questions after reading it, please contact us at (866) 945-9872.

What follows is a description of the information we collect and disclose, including the parties who receive nonpublic information from us.

INFORMATION WE COLLECT ABOUT YOU

We collect information about you from the following sources:

• Information we receive from you on applications and other forms; Information obtained when verifying the information you provide on an application or other form (this may be obtained from, but is not restricted to, your current or past employers or from other institutions where you have conducted financial transactions).
• Information about your transactions with us, or others including those companies that work closely with us to provide you with diverse financial products and services; Information we receive from a credit report agency.
• Information we may obtain from consumer purchasing and census data providers to develop competitive marketing programs for our customers.

DISCLOSURE OF INFORMATION TO PARTIES THAT PROVIDE SERVICES TO US

We may disclose information we collect, as provided by state and/or federal law and as described above, to companies that perform marketing or other services on our behalf or to other financial institutions with whom we have joint marketing agreements, so that we may provide customers competitive products and services.

We may also disclose non-public personal information about you under circumstances as permitted or required by state and/or federal law. These disclosures typically include information to process transactions on your behalf, conduct the operations of and follow your instructions as you authorize or protect the security of financial records.

DISCLOSURE OF INFORMATION ABOUT FORMER CUSTOMERS

If you decide to terminate your relationship with Grand Castle, Inc., we will not share

information we have collected about you, except as may be required by state and/or federal law and will remove any information from our files within a reasonable period of time.

HOW TO OPT OUT OR STOP CERTAIN DISCLOSURES ABOUT YOU

At this time, we do not intend to disclose non-public personal information other than as noted above. If in the future, Grand Castle, Inc. intends to disclose non-public information other than the above, Grand Castle, Inc. will provide an additional notice, and provide an opportunity to opt out if applicable. The opt out does not apply to disclosures that are legally permitted or required or to disclosures that Grand Castle, Inc. makes to companies that perform services on our behalf or to other financial institutions that have joint marketing agreements with

HOW WE PROTECT YOUR INFORMATION

We restrict access to non-public information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your non-public personal information

WHAT CUSTOMERS CAN DO TO HELP

Grand Castle, Inc. is committed to protecting the privacy of its customers. You can help

by following these simple guidelines:

• Protect your account numbers, card numbers, PINs (personal identification numbers) and passwords. Never keep your PIN with your debit or credit card as it can provide access to your accounts if your card is lost or stolen.
• Use caution when disclosing your account numbers, social security numbers, etc., to other persons. If someone calls you, explains the call is on behalf of Grand Castle, Inc. and asks

for your account number, you should beware. Official staff of Grand Castle, Inc. will have access to your information and will not need to ask for it.

• Keep your information current. It is important that we have current information on how to reach you. If we detect potentially fraudulent or unauthorized activity or use of an account, we will attempt to contact you immediately. If your address or phone number changes, please let us know.
• Let us know if you have any questions. Please do not hesitate to call us - we are here to serve you. Flagstar Bank, FSB, 5151 Corporate Drive, Troy, Michigan 48098. Call or write us at, Grand Castle, Inc. 667 Brea Canyon Rd, Walnut, California 91789. (855)558-BANK(2265)

This notice is provided pursuant to Title V of the Gramm-Leach-Bliley Act (GLBA) of 1999, 12 CFR 40.