Issuer Privacy Policy

1. Introduction

Third National Corporation ("Third National," "Issuer," "we," "us," or "our") issues the Helios Card pursuant to a license from Visa U.S.A. Inc. This Privacy Policy explains our practices regarding the collection, use, and disclosure of your information in connection with your card account.

2. Information We Collect

2.1 Personal Information

We collect personal information provided during the card application process, including:

• Name, email address, phone number, and date of birth
• Social Security Number or Tax Identification Number
• Government-issued identification documents (driver's license, passport)
• Physical and mailing addresses
• Employment information and annual income
• Cryptocurrency wallet addresses associated with your account

2.2 Company Information (if applicable)

For business accounts, we may collect:

• Company name, address, and formation documents
• Tax ID and registration numbers
• Beneficial ownership information

2.3 Transaction Information

We collect information about your card transactions, including:

• Transaction amounts, dates, and times
• Merchant names and categories
• Payment and repayment history
• Account balances and credit limits

2.4 Automatically Collected Information

We automatically collect certain information when you use our services, including:

• Browser type and device information
• IP address and approximate location
• Usage patterns and interaction data
• Session replay data for troubleshooting and improvement

2.5 Information from Third Parties

We may receive information about you from third parties, including:

• Credit bureaus and credit reporting agencies
• Identity verification and fraud detection services
• Data providers and aggregators
• Public records and databases

3. How We Use Your Information

We use your information to:

• Verify your identity and assess eligibility for card products
• Process transactions and manage your account
• Communicate with you about your account
• Detect, prevent, and respond to fraud and security threats
• Comply with legal and regulatory requirements
• Improve our products and services
• Conduct internal operations and analysis

4. How We Share Your Information

We may share your information with:

4.1 Service Providers

Third parties that provide services on our behalf, including payment processors, identity verification providers, customer support, and technology providers.

4.2 Program Partners

Helios Card, Inc. and other program partners who help deliver the card services to you.

4.3 Card Networks

Visa and other payment networks for transaction processing and fraud prevention.

4.4 Merchants

Merchants where you make purchases, as necessary to process transactions.

4.5 Regulatory and Legal

Government agencies, regulators, and law enforcement when required by law or to protect our rights.

5. Aggregated and Anonymized Information

We may aggregate or anonymize your information so that it cannot reasonably be used to identify you. We may use and share such information for any purpose.

6. Analytics and Advertising

We use analytics services, including Google Analytics, to understand how our services are used. We may also use advertising technologies to deliver relevant content. You can manage your preferences through your browser settings.

7. Data Security

We maintain reasonable administrative, technical, and physical safeguards to protect your information. However, no security measures are completely secure, and we cannot guarantee the absolute security of your information.

8. Data Retention

We retain your information for as long as necessary to provide services, comply with legal obligations, resolve disputes, and enforce our agreements. Retention periods vary based on the type of information and applicable legal requirements.

9. Do Not Track Signals

Our services do not currently respond to "Do Not Track" signals from web browsers.

10. International Data Transfers

Your information may be transferred to and processed in the United States. By using our services, you consent to this transfer. Please note that U.S. law may not provide the same level of data protection as the laws of your country.

11. Your Choices

You have certain choices regarding your information:

• Opt out of marketing communications by following unsubscribe instructions
• Manage cookie preferences through your browser settings
• Request access to or correction of your personal information

12. State-Specific Rights

Nevada Residents

Nevada residents may request that we not sell their personal information. To submit such a request, please contact us using the information below.

California Residents

California residents have additional rights under California law, including the right to request disclosure of information shared with third parties for direct marketing purposes ("Shine the Light" law).

Brazil Residents

Residents of Brazil have rights under the Lei Geral de Proteção de Dados (LGPD), including rights to access, correct, delete, and port personal data.

13. Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children.

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy and updating the "Last Updated" date.

15. Contact Us

For questions about this Privacy Policy or to exercise your privacy rights, please contact: