This privacy statement discloses the privacy practices for services provided by NECC. Our customer's information is important to us and we are committed to maintaining professional standards of confidentiality.

INFORMATION COLLECTION AND USE

NECC collects only the information needed to administer our business and to provide customers with our products and services. We will not give, sell, shall or rent this information to others, except as disclosed in this statement.

CLIENT PROFILE INFORMATION

A client may be asked to provide information on an application form that may be electronic or paper. This information may include information on contacts, business name, principle's name, expected transaction volumes, business financial data, bank accounts, addresses, URL's, telephone numbers and/or email addresses. This information is used to set up the customer for the services requested by them. NECC may validate this information or request additional information from credit bureaus or other third parties, to assist us in underwriting the session. Information obtained from third parties is kept confidential under the terms of the agreements with those third parties.

DATA ACCESS

All data access is based on a need-to-know basis. The secure protected area of our Web services site(s) may allow our customers, using a unique username and password, to access account information and transaction reporting and to initiate or process transactions directly from the Web site, depending on their entitlements and account setup. Only employees who need information to perform a specific job are granted access to personally identifiable information. Every quarter, as well as any time new policies are added, our employees are notified and/or reminded about the importance we place on privacy and the steps they should take to protect our customers information.

SHARING

When we partner to provide specific services we share only the contact information that is necessary for the third party to provide such services. Third parties are not authorized to use personally identifiable information except for the purposes of providing those services.

LINKS

Some of our Web sites may contain links to other sites. NECC is not responsible for the privacy practices of other sites. We encourage our users to be aware that they are leaving our site and to read the privacy statements of each Web site that collects personally identifiable information. This privacy statement applies solely to information collected by NECC through NECC Web sites.

SUPPLEMENTAL INFORMATION

NECC is committed to using state-of-the-art technology, methodology and services to protect customers, consumers and NECC itself from credit risks, fraud and operational compromise. In addition to collecting and archiving applications and transaction data from customers and consumers, NECC also retrieves supplemental data from third parties to facilitate credit and operational decisions and monitoring. These third parties may include national and regional consumer and business credit bureaus, check verification services, address verification services and other third party transaction processors. Once the information is retrieved from third parties, it is archived in a secure environment. This data may be used to build proprietary databases or develop statistically based credit, fraud or marketing models.

NOTIFICATIONS OF CHANGE

Changes to the privacy policy will be posted on this Web site.