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#1376162 - 04/19/10 02:11 PM Change to Privacy Policy
Iszy_theBug Offline
100 Club
Joined: Nov 2006
Posts: 115
We have always used the short form because we do not share to affiliates or non-affiliates. Now my bank wants to work to do a joint marketing with the Credit Card Co. we work with. I've been reading the reg and am hoping I understand correctly:

So we need to update our Privacy Policy to state that we do share for purposes of joint marketing. But we do not need to include the "Opt-Out" portion in the Policy...

Am I correct in my thinking??
Once I get this straight...then we'll work on the new model! Yeah!

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#1376180 - 04/19/10 02:27 PM Re: Change to Privacy Policy Iszy_theBug
Ted Dreyer Offline
Diamond Poster
Ted Dreyer
Joined: Apr 2001
Posts: 2,245
Yes, you have it right. Sharing for joint marketing purposes must be disclosed before you can do the sharing, but you don't need to provide an opt-out.

Since you are revising your policy anyway, you might want to use the new Model form for your annual mailing this year, if you have not sent it out already. That way you could give the disclosure of your new policy to your customer base, do your annual mailing, and switch over to the new form all at once.

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