You may want to consider revising the privacy notice. As to joint marketing agreements, your disclosure should include a “a separate statement of . . . the categories of third parties with whom you have contracted.” 12 CFR 1016.6(a)(5). The instructions for the model privacy notice suggest that this disclosure should be stated as follows: “Our joint marketing partners include [list categories of companies such as credit card companies].” Appendix A to Part 1016. Because the model privacy notice instructions suggest that you use specificity when listing the categories of third parties with whom you have contracted (using the example of “credit card companies”), it may be prudent to use the term “credit card companies,” instead of using a generic term (“financial services companies”).
Our current privacy notice states that “our joint marketing partners may include financial services companies.” If we will be marketing credit card services under a joint marketing agreement, is that disclosure specific enough?
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