Privacy Policy

Last Updated: May 2026

Protecting the Privacy of Our Customers

Tier 1, LLC and its affiliated companies (“Tier 1,” “we,” and “us”) are committed to protecting your privacy and implementing technology that gives you a powerful online and mobile app experience. We maintain physical, electronic, and procedural safeguards to transmit and store information about you. We are regularly evaluating new advances in security technology and techniques to provide protection for information about you. In addition, we permit only authorized employees who have a job-specific purpose to have access to your information.

Scope

This Privacy Policy applies to information that we collect when you use or access the Tier 1 website or the Tier 1 mobile app (“Mobile App”). It also applies when you otherwise interact with Tier 1 and to Tier 1 services (collectively the “Services”) that display or link to this Privacy Policy.

Tier 1 partners with banks and other lenders who originate loans, provide deposit accounts, and offer other Services obtained through Tier 1. By using our Services, you establish a direct customer relationship with both Tier 1 and the applicable bank or lending partner(s).

If you utilize our Services, we will use and share any information that we collect from or about you in accordance with our Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information.

Information We Collect About You

We collect several types of information about you, including the following:

  • Personal information that you provide through online or Mobile App forms, application and registration forms, surveys, and/or other entries or communications, such as your name, address, telephone number, driver’s license number or other government issued photo ID number, social security number, email addresses, assets, and income;
  • Information collected or inferred from your device, internet browser, or mobile carrier, including location and technical information, such as web page HTTP headers, home server domain names, device IDs, IP addresses, type of mobile device or computer, and type of web browser;
  • Information from web analytics services regarding our website, including but not limited to mouse clicks, mouse movements, scrolling activity, and text that you type into our website;
  • Email addresses of visitors that communicate with us via email;
  • Information about your transactions with us, our affiliates, or others, such as payment history and loan balances;
  • Information we receive from third parties, such as consumer reporting agencies, lenders, and certain vendors, regarding creditworthiness, credit history, fraud risk, and/or criminal background information.

To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. What this means for you: when you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.

How We Collect Information

There are several ways we may obtain information about you. Tier 1 collects information from you (a) that you choose to share with us when using our Services and when you otherwise interact with us, (b) that we collect automatically when you use our Services, and (c) that we receive from third parties such as business partners, affiliates, or sources that help us maintain the accuracy of the information we collect, improve your experience with the Services, and for internal business analysis or other business purposes.

How We Use Information We Collect

The information we collect about you is used to provide Services to you and to contact you regarding administrative matters. We may also use your information to resolve disputes, troubleshoot problems, and enforce our agreements with you. We may use your contact information to send you information about our company and promotional material from our partners. We may also use your personal, demographic, and profile data to improve our service, for research purposes, and for the marketing/promotional purposes of our advertisers. Information collected by us may be added to our databases and used for future emails or postal mailings regarding website updates, new products and services, upcoming events, and/or status of orders placed online, unless prohibited by law. Information may also be used to identify fraud and secure our Services and systems in an effort to protect you and our other customers.

Parties to Whom We Disclose Information

You authorize Tier 1 and our applicable bank or lending partner(s) to share your personal information with each other. You understand that Tier 1 and the applicable bank or lending partner(s) will each process any shared information according to their respective privacy policies and notices.

In addition, we reserve the right to share data we collect with our affiliates, as well as to share, rent, sell, or otherwise disclose data we collect with nonaffiliated third parties, including but not limited to magazine publishers, retailers, and direct marketers. Any nonaffiliated third party we share, rent, sell, or otherwise disclose data to will be prescreened by us, determined by us to be reputable, and will use the data for marketing products and services which we determine, in our sole judgment, that you might find of interest.

Information we share with affiliates: Some of our Services are provided using our affiliates, and we share non-public personal information with them in order to fulfill the services you have requested and as required or permitted by law.

Information we share with third parties: We use certain nonaffiliated third parties as service providers, and we share non-public personal information with them in order to fulfill the services you have requested and as required or permitted by law. This also includes companies that help us with fraud detection.

Information we share with financial institutions: We may disclose information we collect to financial institutions such as banks or other financial service providers with which we have a joint marketing and/or servicing agreement.

We may also share information if we think we have to in order to comply with the law, such as disclosing information in response to a subpoena or government agency request. All of the data sharing disclosures above exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties except for our applicable bank and lending partner(s).

Contact and Marketing Preferences

Subject to applicable law, we may contact you by several contact methods, including but not limited to writing you via U.S. postal service and/or email and calling you via telephone at any address or number you have provided to us. We may also contact you via text messaging or other mobile communications method if you have previously requested or agreed to this type of communication. We may use any one or all of these methods to contact you about the status or approval of your credit card account, to inform you about special promotions and services we believe may be of interest to you, to remind you of upcoming payments, and to communicate with you regarding collections and other issues related to your account with us.

You may manage your contact information and preferences by calling us at (800) 988-7782 or emailing us at help@Tier1Credit.com. Notwithstanding the above, we reserve the right to contact you to inform you of technical services issues related to a service you have requested. You will not be able to choose to unsubscribe from these communications, as they are considered an essential part of the service you have requested. In addition, subject to applicable law, we reserve the right to contact you regarding your account status, collection matters, changes to subscriber agreements, this Privacy Policy, or any other policies or agreements relevant to you and/or your account with us using any contact method described above.

Third Party Websites and Content

The Services may have links to third-party websites. We are not responsible for the practices of these websites, nor does our Privacy Policy apply to other websites. We have no control over the information that is collected, stored, or used by third-party websites, so please refer to each website’s privacy policy.

Additional Security Precautions

You also have a significant role in protecting your information. If you use our website or Mobile App, you are responsible for maintaining the confidentiality of your account and your password and for restricting access to your computer. Do not share your login and password with others. You agree to accept responsibility for all activities that occur under your account and password.

“Cookie” Policy

To ensure that we are publishing content that customers need and want, our website www.tier1credit.com collects aggregated site visitation statistics using cookies. When a customer visits our website, a cookie is placed on the customer’s hard drive (if the customer accepts cookies). If you choose to not have your browser accept cookies from our website, you will not be able to subscribe to the service offerings on our website. Also, your computer must have JavaScript turned on in order for you to subscribe to service offerings on our website.

Children and the Internet

We respect the privacy of children and we comply with the Children’s Online Privacy Protection Act (“COPPA”). We do not knowingly collect or retain personally identifiable information from consumers under the age of thirteen (13). You must be at least eighteen (18) years of age to obtain services from us.

Notice to Residents of California

This Notice explains certain rights that California residents have under the California Consumer Privacy Act, as amended by the California Privacy Act (the “CCPA”). The CCPA requires that businesses provide California residents with information pertaining to the collection, use, disclosure, sale, sharing, and retention of personal information as well as the rights of California residents regarding their personal information and how to exercise them. This section of the Privacy Policy is intended solely for residents of California. If you are not a California resident, this section does not apply to you.

Under the CCPA, personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. This information is referred to in this Notice as “Personal Information.” Personal Information does not include publicly available, de-identified or aggregated information or lawfully obtained, truthful information that is a matter of public concern.

Please note that the CCPA, and this Notice, do not apply to information covered by other federal and state privacy laws, including the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act and certain other laws. Because we are subject to those laws and regulations, much of the Personal Information that we collect is exempt from the CCPA. Your choices and rights with respect to our use and sharing of that information are subject to our Privacy Notice.

Categories of Personal Information That We May Collect

We collect Personal Information in a variety of contexts. We collect, or have collected in the 12 months prior to the last updated date of this Privacy Policy, the following categories of Personal Information:

  • Personal Identifiers: real name; alias; Social Security number, driver’s license number; other government issued number; postal address; telephone number; email address; account name or login; unique personal identifier; online identifier; device identifier; Internet Protocol (IP) address, or other similar identifiers
  • Characteristics of Protected Classifications Under California or Federal Law: age; marital status; military or veteran status
  • Customer Records: signature; bank account or bank card number(s); other financial information
  • Commercial Information: records of properties; information about transactions or purchases
  • Biometric Data: physiological or behavioral characteristics that can be used to identify an individual, such as voice recordings, keystroke patterns
  • Professional or Job-Related Information: employment history; employment records
  • Internet or Other Electronic Network Activity Data: browsing history; search history; information on a consumer’s interaction with our website, Mobile App, or advertisement, and the contents of any mail, email, and text messages sent or received for customer support or similar purposes
  • Audio and Visual Information: audio, electronic, or similar information we capture through your communications with us, such as call recordings, emails and text messages
  • Inferences Drawn From Personal Data: inferences drawn from any of the information identified above that can be used to create a consumer profile that reflects preferences, characteristics, attitudes, or trends

Sources of Personal Information

We have collected in the past 12 months Personal Information described above from one or more of the following sources:

  • Directly from you when you provide this information to us, when you request information, apply for products or services from us, use our website or Mobile App, respond to surveys, contact us, or otherwise interact with us
  • From persons you have authorized or directed to share information with us on your behalf
  • From our affiliates, partners and other related parties
  • From other online and offline sources, such as public databases, social media platforms, and other third parties
  • From our vendors who provide services on our behalf, such as communication services, software providers, fraud prevention services, data providers, and data analytics providers

Use of Personal Information

We may use or disclose Personal Information that we collect for one or more of the following business purposes:

  • Providing you with, or evaluating your eligibility for, products and services that you request from us
  • Communicating with you
  • Processing transactions and payments
  • Verifying your identity
  • Detecting, preventing, and investigating fraud
  • Protecting against possible security risks
  • Conducting analytics and research
  • Managing the operation of our website, Mobile App, and IT systems
  • Optimizing or improving products and services, as well as enhancing the customer experience
  • Advertising and marketing
  • Performing compliance-related activities, such as complying with applicable federal, state, and local laws
  • Performing legal activities, such as responding to lawsuits, regulatory actions, investigations, subpoenas, exercising our rights or defending against legal claims
  • Engaging in risk management activities, including audits
  • Reporting to credit bureaus
  • As otherwise disclosed to you at or before the point of collecting your Personal Information

Disclosure of Personal Information

We have disclosed in the past 12 months the above categories of California residents’ Personal Information to some or all of the following categories of recipients:

  • You and, where appropriate, your family, your associates and your representatives
  • Our affiliates
  • Our bank partner
  • Fraud prevention service providers
  • Other service providers, such as payment service providers and marketing partners
  • Accountants, lawyers, financial advisors, auditors and other outside professional advisors, subject to confidentiality provisions
  • Government agencies or similar authorities, upon request or where required
  • Other third parties in order to comply with legal requirements such as responding to subpoenas and court orders, to enforce our rights or applicable policies, to address fraud or security issues, to respond to an emergency, or otherwise to protect the rights, property or security of our customers or third parties
  • Any relevant third-party acquirer, in the event we sell or transfer all or any relevant portion of our business or assets
  • Any other parties to whom you have specifically directed us to disclose your Personal Information or have consented to such disclosure

Retention of Information

In accordance with applicable laws, and consistent with our retention policies, we will retain Personal Information for as long as reasonably necessary for the purposes set forth in this Privacy Policy. When determining our retention policies, we take into account the length of time Personal Information is required to be retained to (a) provide the Services; (b) satisfy legal and compliance obligations; (c) conduct appropriate audits; (d) address any complaints regarding the Services; and (e) defend or bring potential legal claims.

Requests Under the CCPA

If you are a California resident, you have the right to request that we:

  • Disclose to you the following information covering the 12-month period prior to your request:
    • the categories of Personal Information we collected about you and the categories of sources from which we collected the Personal Information;
    • the business purpose for collecting the Personal Information about you;
    • the categories of recipients with whom we disclosed your Personal Information; and
    • the specific pieces of Personal Information we have collected about you.
  • Delete Personal Information we collected.
  • Correct inaccurate Personal Information that we have about you.
  • Opt you out of the sale or sharing of Personal Information.

You also have the right not to be discriminated against for exercising any of the rights provided by the CCPA.

Please note that in some instances, we may not be able to honor your request. For example, we will not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual. Additionally, we will not honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another California resident or where the Personal Information that we maintain about you is not subject to the CCPA’s access or deletion rights. In those cases, your choices and rights with respect to our use and sharing of that information is subject to our Privacy Notice.

How to Make Requests

If you are a California resident and you wish to make any of the requests listed above, you may do so by:

Our Process for Verifying a Request

If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a password-protected account with us.

If you maintain a password-protected account, we may verify your identity through existing authentication practices available through your account. Prior to disclosing or deleting the Personal Information, we will ask you to re-authenticate yourself with respect to that account.

If you do not maintain a password-protected account, or if you are an account-holder but we suspect fraudulent or malicious activity with your account, we will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. We may ask you to provide us with your name, contact information, social security number, and date of birth.

Right to Opt-Out of the Sale or Sharing of Personal Information

California residents may have a right to opt out of the sale or sharing of Personal Information for cross-contextual behavioral advertising purposes. To facilitate this right, we recognize Global Privacy Control (GPC) opt-out preference signals. If you are using a browser setting or plug-in that sends an opt-out preference signal to each website you visit, we will treat that as a valid request to opt out. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Another means to opt out is by clicking the Do Not Sell or Share My Personal Information link in the footer of our website.

Deletion of Tier 1 Mobile App Data

Users of the Mobile App who wish to delete the Mobile App from their device may also request to have their associated user data deleted. To submit such a request, users will need to complete the request form found at https://www.tier1credit.com/delete-my-data. Data needed for legitimate purposes related to security, fraud prevention, loan servicing, and/or compliance with applicable laws and regulations will be retained pursuant to Tier 1’s data retention policies.

Changes to This Privacy Policy

Because circumstances and technologies change, we reserve the right to change this Privacy Policy at any time by notifying you of the existence and location of the new or revised Privacy Policy or by posting changes online at our website.

Our Contact Information for Questions

If you have any questions about this Privacy Policy or the practices of Tier 1, please contact us by sending a letter to: Tier 1, LLC, Attn: Privacy Department, 725 E. Covey Lane, Suite 200, Phoenix, AZ 85024. You may also email us at help@Tier1Credit.com or call us at (800) 988-7782.