HSBC's Commitment To You

At HSBC Bank USA, National Association, we are committed to protecting your privacy. To keep your personal, non-public information both personal and private, we have established the following policies:

1. We never sell your personal information to other companies for their independent marketing purposes.
2. We maintain physical, electronic and procedural safeguards to prevent unauthorized access to your personal information, and to protect you against the criminal misuse of that information.
3. We restrict access to your account(s) to only those employees involved in providing the services you’ve requested. All HSBC employees are required to keep your personal information confidential.
4. We honor your preferences about the information we share within the HSBC family of companies for marketing purposes. If you have already notified us of your privacy preferences, you don’t need to contact us again unless you want to change your preferences.

Why Do We Collect Information?

We collect information about you for two important reasons:

1. To identify you when you are conducting financial transactions, so we can help prevent unauthorized access to your personal and financial information.
2. To offer you preferred interest rates, special discounts and other services that can help you achieve your financial goals.

What Kind Of Information Do We Collect?

When meeting your financial needs, we collect the following non-public personal information about you:

1. When you fill out forms and applications for HSBC products and services, we may collect information such as your name, address, age, income, and assets.
2. When you make transactions with the HSBC family of companies or others, or through online services such as Bill Pay, we may collect information on your account balances, payment history, account usage and employment history.
3. When you apply for credit, we may collect account information and credit history from third parties such as credit bureaus.

Why Do We Share Information Within The HSBC Family Of Companies?

To help us offer you valuable financial services, HSBC may share the types of information described above in "What Kind Of Information Do We Collect?" within the HSBC family of companies. The HSBC family includes banking, consumer finance, insurance, mortgage, and brokerage companies. Some examples include companies doing business under the names HSBC or Household. If you don’t want us to share application and third party credit-related information within the HSBC family of companies, please call us toll-free at 1-877-394-HSBC (1-877-394-4722). Your request may take four to six weeks to take effect. If you ask us not to share your information it will prevent you from receiving certain offers and discounts from HSBC and the HSBC family of companies. It will not prevent unwanted solicitations from other companies that received your information from other sources. Within the HSBC family of companies, we may continue to share information relating to your account transactions and our experiences with you.
We may also use the other companies in the HSBC family as service providers to perform services relating to the operations of your accounts (such as data processing). These HSBC companies may be located in countries other than where you reside, including but not limited to, the United Kingdom.
If your accounts are held jointly with other individuals, we treat a do-not-share request by one accountholder as applying to that accountholder only, unless you notify us you’re acting on behalf of the other accountholder(s). If you would like HSBC to limit its mail, e-mail, and telephone contacts with you for marketing purposes, please call us at 1-877-394-HSBC (1-877-394-4722).
How Do We Share Information Outside the HSBC Family Of Companies?

We may share the kinds of information described above in "What Kind Of Information Do We Collect?" with non-affiliated third parties contracted to perform services necessary for the routine operation of your account(s), such as check printing, data processing, loan servicing, and fraud prevention.
We may also share this information with service providers performing marketing services on our behalf, and with other financial institutions with whom we have joint marketing agreements, or as permitted by law or with your consent. Whenever we share information outside the HSBC family of companies, all non-affiliated third parties are required to maintain the confidentiality of that information. In some cases, we are required or permitted by law to provide information about you to third parties without your consent. Examples include responding to a subpoena or similar legal process, providing information to consumer reporting agencies, or providing information in connection with a proposed or actual sale of your account to another financial institution.
How Do We Protect Your Privacy Online?

To help us learn which products, services and sections of our Web site interest you, and to improve your experience, we sometimes use "cookies." A cookie is a small file that our web server places on your hard drive to track activity on the site during a browsing session, and across multiple sessions.
We also use a cookie to "remember" which online service you last logged into, so that we can pre-select that service on your next visit. The cookies we set do not identify you individually, contain no personal information, and are not shared with anyone. They can only track activity on our Web site, and cannot be read by any non-HSBC Web sites. We may also use online profiling to help us better understand your individual financial needs. This information does not identify you personally unless you voluntarily give us personal information while online.
We also work with Yahoo! and other third parties to learn more about activity on our Web site. These vendors use "web beacons," "tracking pixels," "third party cookies" and other similar technologies to gather user demographics and usage patterns, which help us improve the effectiveness of our marketing and of our Web site design. These vendors do not share any personally identifiable information about you. If you prefer that your Web site visits are not tracked or analyzed in these ways, please visit http://us.hsbc.com/inside/webtracking to learn more about these technologies, and about ways to opt-out. Privacy for EasyView Users

In order to provide the EasyView Service, we will collect information about the accounts and relationships with the companies and institutions you designate to be included in your EasyView Service, in addition to the types and sources of information described above in HSBC’s Privacy Policy. The personal information includes:

• Information you provide to us on EasyView registration pages, such as your name and e-mail address.
• Information about the accounts you have designated for EasyView Services, such as account balances, transactions, transaction histories, e-mail information, bills, payment history and other account activity. We obtain this information as your agent, from the providers of the accounts you designate for EasyView Services, which may include the HSBC family of companies as well as other online account providers.

This Privacy Policy only applies to the EasyView website, and not to the sites that are accessed through EasyView. You should be careful to review any privacy policies posted on other web sites before registering for or using the services.

If you use our EasyView service, we collect information about the accounts and relationships included in your EasyView service, including registration information such as your name and e-mail address. We also collect information about the accounts you have designated for the EasyView service, such as account balances, transactions, transaction histories, e-mail information, bills, payment history and other account activity.

We will not disclose any information about you, that we obtain solely through EasyView, to any third party outside the HSBC family of companies, except as needed to provide your EasyView service, or as required or permitted by law.
This Privacy Policy is also available online at us.hsbc.com. It does not apply to other sites you may access through us.hsbc.com. You should review any privacy policies posted on those Web sites before you sign up or use them.
Special Notice For Private Banking Customers

Non-public personal information is closely guarded when we act as trustee or fiduciary. Please contact your Private Banking relationship manager for more information.
Special Notice For Residents Of Vermont and North Dakota

HSBC does not share your information within the HSBC family of companies, other than information relating to your account transactions and our experiences with you.

This Privacy Policy has been adopted by HSBC Bank USA, National Association (including Domestic Private Banking), HSBC Mortgage Corporation (USA), HSBC Insurance Agency (USA) Inc., HSBC Securities (USA) Inc., and Auto Holdings Inc. It covers your current or former consumer banking and financial services relationships with these HSBC companies.

Revised: July, 2004