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Last Revised: March 2022

This Privacy Policy describes how Bread Financial Holdings, Inc. family of companies, including Comenity Bank, Comenity Capital Bank, and Lon Operations LLC (d/b/a Bread and Bread Operations) (collectively referred to as “Bread Financial”, “we”, the “Bank”), collects, uses, shares, and retains data collected from its websites, including the websites located at www.breadfinancial.com and direct.comenity.com, from when you interact with us (for example on our Social Media Pages), and from the Services we offer to our customers.

If you are visiting us from a location outside of the United States, please keep in mind that we are U.S.-based. This Policy governs the information collected by or on behalf of our sites irrespective of where you are located when you access, browse, or interact with it. If you are a California resident, please see the “California Residents Only” section below which supplements this Privacy Policy.

1. Personal Information We Collect

“Personal Information” refers to information that identifies you directly or can reasonably be associated with you using other information. Such personal information may include your name, Social Security number, date of birth, email address, postal address, or telephone number. Generally, you may provide us with two types of personal information when you interact with our Sites:

Information You Provide Directly To Us
We collect personal information from you online whenever you provide it directly to us.  This includes when you send us an email, fill out an application, complete a “Contact Us” form, enter your zip code to find a store, and submit a resume.

We do not knowingly collect, use, or maintain personal information from users under 16.

Information Automatically Collected About Your Device
We, and other parties, such as our analytics and advertising service providers, will automatically collect personal information about your online activities over time and across different websites when you use our Sites. This includes navigational and/or other device-specific information like IP address, browser type, hardware model, and Unique Device Identifier.

Please refer to the “Online Tracking” and “Online Behavioral Advertising” sections of the Policy for additional details.

2. How We Use and Share Your Personal Information

How We Use Your Personal Information
We may use personal information collected at our Sites for servicing, marketing, security, fraud prevention, other internal business purposes, or for any other purpose permitted by law.

How We Share Your Personal Information
We may share your personal information with third party service providers to perform services on our behalf. In addition, we will also share your information throughout our family of companies and with unaffiliated third parties: (i) as required for legal or regulatory compliance, (ii) to protect our rights and property or the rights and property of other parties, (iii) in the event we sell or transfer all or a portion of our business assets, your information may be one of the business assets that are transferred as part of the transaction, (iv) during a bankruptcy proceeding, (v) for servicing, (vi) for internal business purposes, (vii) for fraud prevention, (viii) for marketing and/or to promote additional products, services, and special offers, as permitted by law, (ix) for any purpose you may request, or (x) for any other purpose that may be required or permitted by law.

3. Online Tracking

We, and certain service providers operating on our behalf, may collect information using tracking technologies, including:

Browser Cookies
Cookies are small text files that are stored directly on your device web browser. We use browser cookies to personalize your visit and improve our Sites and other services. Depending on your browser version, you may be able to block or erase browser cookies. Please be aware that some features of our Sites may be unavailable to you if your browser cookies are blocked or erased.

Pixel Tags
Pixel tags (also known as web beacons, web bugs, or clear GIFs) are nearly invisible pixel-sized graphic images in an email message or on a web page. Pixel tags in emails help us confirm the receipt of and response to our emails, the time our email is viewed, and “click-through” information such as where you click email links. Pixel tags on web pages operate similarly to pixel tags in emails in that they help us understand how you interact with our Sites. Please note that pixel tags are often used in conjunction with browser cookies, which are described above.

“Do Not Track” Browser Signals
Our Sites will continue to operate as described in this Policy, whether or not a “Do Not Track” signal or other similar mechanism is received from your web browser.

Location Based Services
Your IP address is a number assigned to your device by your Internet Service Provider and is captured automatically in our server files. If you consent, we may also collect your actual physical coordinates when a location-based service is used, such as GPS signals sent to us when you are searching for a nearby store on a mobile device. We use location information to improve our Sites and service offerings and administration of our Sites.

Retail Application: Location Based Services
For those customers that choose to utilize our retail applications, Bread Financial may collect, use, and share precise location data, including the real-time geographic location of your device. This location data is collected anonymously in a form that does not personally identify you and is used by Bread Financial to provide and improve location-based products and services. For example, we may share geographic location with application providers when you opt in to their location services.

4. Online Behavioral Advertising

Online behavioral advertising (“OBA” or “interest-based advertising”) involves the tracking of your online activities in order to deliver tailored advertising of goods and services that are likely to be of interest to you. We permit third party advertising companies to serve advertisements on our behalf on our Sites and those websites and mobile apps not affiliated with us. This Policy does not cover the privacy practices of the third party sites on which we may have advertisements. Please review their privacy policies and terms of service if you have any questions about their privacy practices.

Opting Out of OBA
Behavioral advertisements will feature an AdChoices Icon (also known as the “Advertising Option Icon”), that when clicked, provides more information about how the advertisement was delivered to you and also provides the ability to opt-out from future OBA by the third parties listed. To opt-out of OBA from all Digital Advertising Alliance (“DAA”) participating companies, please visit http://www.aboutads.info/choices/.

Please note that if you opt-out of OBA, you may still receive online advertising from us on third party sites. Opting out from third party advertising companies means that the advertisements you receive will not be based on your preferences or behavior. Further, opting out does not prevent other parties from tracking your online activity for other uses as described in this Policy.

5. Social Media Pages

From time to time, we may create and manage social media pages that include, but are not limited to, a Twitter or Instagram account or a Facebook page (“Social Media Pages”). With your consent, personal information like your name, profile picture, gender, networks, user ID, list of friends, birthday, likes, education history, work history, current city, hometown, interests, relationship status, and any other information you have shared on a social media site may be collected by us. This Policy does not cover the privacy practices of the social media sites on which we may have Social Media Pages. Please review their privacy policies and terms of service if you have any questions about their privacy practices.

6. International Users

If you are visiting us from a location outside of the United States, please keep in mind that we are U.S.-based. This Policy governs the information collected by or on behalf of our Sites irrespective of where you are located when you access it, browse it, or interact with it.

With respect to personal information, you provide to us on the Social Media Pages, once received from the social media sites, it is maintained and processed by us on servers and internal systems located in the United States. This means your personal information may be stored outside of the province, state, and/or country in which you reside, and processed by us or a third party as described in this Policy. Moreover, governmental bodies that have jurisdiction over us in the United States (e.g., courts and law enforcement agencies) may be entitled to access your personal information.

7. How Your Personal Information is Protected

Your privacy is important to us. We have implemented physical, technical, and administrative security measures to safeguard the personal information that we maintain.

8. Accuracy of Your Personal Information

We strive to maintain accurate personal information about you. If you are a Bread Financial cardholder and believe that our records contain inaccurate or incomplete information about you, please contact the Customer Care phone number listed on your billing statement or on the back of your credit card. Customers with a registered online account may review their personal information by logging in to our secure account management service. For more information, please locate your card on the Card Search page.

9. Links to Other Sites

We may provide links on our Sites to external websites not owned or operated by us as a convenience to you. This Policy does not apply to the data collection, use, and protection practices of these websites. Please read and understand a linked website's privacy policy before using such a website.

10. Changes to this Policy

From time to time, we may modify this Policy. Should there be a material change to our information collection, use, or disclosure practices, it will be applied only to personal information collected on a going forward basis, and we will update this Policy accordingly.

11. Contact Us

If you have additional questions about this Policy, please contact us at privacy@comenity.net.

12. California Residents Only

The California Consumer Privacy Act (CCPA) defines “Personal Information” as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.

A California resident has the following rights:

1. The right to request what personal information we collect, use, disclose and sell including:

• The categories of personal information.
• The categories of sources from which the personal information was collected.
• Our business or commercial purpose for collecting or selling personal information.
• The categories of third parties with whom the business shares personal information.
• Specific pieces of personal information we have collected about you.

In the past 12 months, we collected the following categories of personal information:

• Identifiers (e.g. name, address, social security number) – Identifiers are collected for servicing your credit card account.
• Commercial information (e.g. products or services purchased) – Commercial information is collected for servicing and marketing purposes.
• Internet or other electronic network activity (e.g. information concerning your interaction with a website) – Internet or other electronic network activity is collected for marketing purposes.
• Geolocation data – Geolocation data is collected for marketing purposes.
• Professional or employment-related information – Professional or employment-related information is collected for servicing your credit card account.
• Conclusions drawn from any of the information (e.g. predicted purchasing behavior) – Conclusions drawn from any of the information is collected for servicing and marketing purposes.

The above data was collected from you and data resellers for the marketing or servicing of a financial product. We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the Personal Information was collected We share the above data with the retailer listed on your card, services providers, vendors, advertising partners and data analytics providers.

In the past 12 months, we sold internet or other electronic network activity for business purposes. However, we did not sell personal information of minors under 16 years of age.

2. The right to request that we delete your personal information if we do not need it or are entitled by law to retain it.

3. The right to request information that we have sold or disclosed to our business partners, including:

• The categories of personal information that we collected about you.
• The categories of personal information that we sold about you and the categories of third parties to whom we sold it.
• The categories of personal information that we disclosed about you for a business purpose.

4. The right to direct us not to sell your personal information.

5. The right to not be discriminated against because you exercised any of the rights described above.

6. The right to designate an authorized agent to make a request under CCPA on your behalf.

In order to exercise your right(s) please go to https://calprivacy.comenity.com or dial 1-877-655-5391 (TDD/TTY: 1-800-695-1788). In order to verify your identity you will be required to provide: your first name, last name, address, phone number, date of birth and email address. Once you have provided your data you will be asked a series of questions to confirm your identity.

Contact for More Information: 1-877-655-5391 (TDD/TTY: 1-800-695-1788) 

7. CCPA Requests Handled July 1, 2020 through June 30, 2021

• Request to Know: 703 Requests Received, 406 Requests Verified, 406 Verified Requests Answered, 297 Verified Requests Denied
• Request to Delete: 140 Requests Received, 84 Requests Verified, 84 Verified Requests Answered, 56 Verified Requests Denied
• Request to Opt Out*: 2,474 Requests Received, N/A Requests Verified, 2,474 Verified Requests Answered, 0 Verified Requests Denied

*Requests are passed to our service providers.

• During this period, our median time within which we sent responses was 2.24 days.

NFL Extra Points Rewards Program Terms

Important note: These program terms are subject to the jury trial waiver and arbitration provision in your credit card account agreement that limit our liability to you, eliminate your right to a trial by jury, require you to resolve disputes with us on an individual basis and not as a part of any class or representative action, and through final and binding arbitration.

Please read these Program Terms carefully for important information about your rights and obligations in the NFL Extra Points Visa Credit Card Rewards Program (“Program”). By participating in the Program, you agree to these Program Terms.

The Program is provided by Comenity Capital (“Bank”). Comenity Capital Bank is solely responsible for Program operation and may withdraw the Program or change the terms of the Program at any time. The purpose of the Program is to reward customers for certain uses of their NFL Extra Points Visa Credit Card (“Card”.) The Program Terms may be supplemented with additional terms, conditions, and disclosures, including but not limited to applicable terms related to any promotional offers provided to you for use with the Program.

For the most up-to-date terms, please visit MyNFLExtraPoints.com/visa

General Information

The Program allows you to earn points (“points”) on the amount you spend as described in the “Earning Points” section below, using your NFL Extra Points Visa Credit Card Account (your “Account”). You can then redeem points for certain Rewards Catalog Items (“Rewards”) as described in the “Issuing Rewards and Redemption” section below. You can redeem points for Rewards through the Account Center at MyNFLExtraPoints.com/visa (“Account Center”).

These Program Terms are separate from your NFL Extra Points Visa Credit Card Account Agreement (your “Account Agreement”), which governs the use of your Account. In the event of any conflict between these Program Terms and your Account Agreement, these Program Terms will control in any matter relating to the Program. By using your Account, you agree to be bound by these Program Terms.

All information collected about you in connection with the Program is subject to Comenity Capital Bank’s and NFL's privacy policy. Comenity Capital Bank’s privacy policy can be obtained at MyNFLExtraPoints.com/visa and the NFL privacy policy can be obtained at https://www.nfl.com/legal/privacy/.

Earning Points

You will earn points when you, or an authorized user, make eligible purchases of goods and services for personal, family and household purposes using your Account, minus any returns, refunds or credit adjustments (“Net Eligible Purchases”). Starting June 20, 2022 point earn is rounded to the nearest whole point value using standard rounding. Earning calculations that end in .5 will round up to the next whole point value. For example, earn calculated to 1.5 points rounds to 2 points. All calculations that result in less than .5 will round down. For example, calculated earn of 1.4 points would round to 1 point. Prior to June 20, 2022, points are earned according to bankers rounding on transactions Purchases that are not a whole dollar amount will be rounded to the nearest whole dollar amount to determine the amount of points earned. Purchases that end in $0.50 is rounded to the nearest even whole dollar amount. Example: $2.50 rounds to $2.00 where as $3.50 rounds to $4.00

Using your NFL Extra Points Visa Credit Card you will earn:

• 3% back in Rewards for each $1 of Net Eligible Purchases made at com, NFL Team Retail Stores, NFL Team Online Stores, NFL Team Stadiums and qualifying NFL Game Ticket Purchases made at NFL Team Ticket Offices, Ticketmaster, StubHub and SeatGeek. 3% back in Rewards is calculated as points earned, where 3% back earned is equal to 3 points per $1 spent.

• 2% back in Rewards for each $1 of Net Eligible Purchases made at bars and restaurants, and on groceries, food delivery and fitness purchases such as memberships and gyms, as identified by Merchant Classification Codes as described in the Bonus points for Special Offers 2% back in Rewards is calculated as points earned, where 2% back earned is equal to 2 points per $1 spent.
• 1% back in Rewards for each $1 of Net Eligible Purchases made everywhere Visa is 1% back in Rewards is calculated as points earned, where 1% back earned is equal to 1 point per $1 spent.

Points are earned on taxes, shipping & handling, gift cards on purchases through the NFL and teams. Points are not earned on unauthorized or fraudulent charges, charges that violate the terms of your Account Agreement, balance transfers, cash advances, transactions treated similar to cash advances, interest charges, and fees of any kind.

Comenity Capital Bank may temporarily prohibit you from earning points, using points, or using any features of the Program if: your Account becomes delinquent; Comenity Capital Bank suspects that you or any authorized user has engaged in fraudulent activity related to your Account or the Program; or the National Football League™ suspects that you misused the Program in any way.

Points awarded for purchases that do not remain Net Eligible Purchases will be deducted from your Point balance. Returned items may result in credits being applied to your Account, which will reduce or may eliminate accumulated Points and may result in a negative Points balance. If your Points balance goes negative, you must first earn Points to bring your Points balance to zero before earning any Points eligible for redemption. The National Football League and Comenity Capital Bank reserve the right to verify and adjust Points, as applicable, at any time.

Bonus Points for Special Offers

From time to time, Comenity Capital Bank may make bonus offers to earn additional Points (“Bonus Points”). Read each offer carefully, as there may be important conditions or limitations, such as blackout periods, Bonus Points limits, or exclusions. You may have to register to qualify for the offer. Comenity Capital Bank may change or withdraw an offer at any time without notice. Any such change or withdrawal will not affect Bonus Points already earned. Certain offers may only be communicated via email. Tax and shipping charges are excluded from specials offers and bonuses.

Reward Merchant Classification Codes: Merchants who accept Visa are assigned a merchant classification code (“MCC”), which is determined by the merchant or its processor in accordance with Visa procedures based on the products and/or services they primarily sell. Comenity Capital Bank and the National Football League do not control the assignment of these codes and are not responsible

for incorrectly coded purchases. Even though a merchant or some of the items it sells may appear to fit within a certain Rewards category, the merchant may not have a code in that category. Purchases made with third-party payment accounts, including but not limited to PayPal and Venmo, will not earn additional points.

Expiration

Important note: Points will expire 5 years after the date that they are posted to your Points balance.

Termination and Forfeiture

Important note: Subject to any requirements or limitations of applicable law, Comenity Capital Bank may at any time for any reason change or terminate the Program and these Program Terms without notice.

Comenity Capital Bank reserves the right to terminate you from the Program. If the Program terminates, Comenity Capital Bank terminates you from participating in the Program, or you voluntarily cancel enrollment in the Program, all Points will be forfeited.

Points will be forfeited if any of the following occur: your Account is closed; you terminate your participation in the Program; you or any authorized user engages in any fraudulent activity or misuse related to your Account or the Program, or engage in any activity deemed to be abusive or gaming conduct, as determined by Comenity Capital Bank. Misuse includes, but is not limited to, obtaining or using an Account to maximize Points earned in a manner that is not consistent with typical consumer activity as determined in Comenity Capital Bank’s sole discretion.

Issuing Rewards and Redemption

You may redeem Points for Rewards on the Program Catalog Website accessible through Account Center at MyNFLExtraPoints.com/Visa. Points will be redeemed on a “first in, first out” basis, such that the first Points earned will be the first Points redeemed. Once you’ve redeemed Points for a Reward or statement credit, your Points balance will be reduced by the number of Points used to obtain the Reward or statement credit and will appear on Account Center. Rewards are issued for reward purposes only.

We contract with PrizeLogic and MKTG, non-affiliated third parties, who are solely responsible for the administration of the Program with respect to goods or services offered on the Program Catalog. To contact PrizeLogic or MKTG call1-855-917-5473or email extrapointsloyalty@prizelogic.zendesk.com PrizeLogic and MKTG may establish procedures related to fulfillment of Rewards. The procedures will be disclosed prior to redeeming Points for Rewards from PrizeLogic or MKTG. Your redemption types are statement credit, catalog merchandise, gift cards, experiences, and game tickets. See details below. Redemption value of Points is variable based on the reward you choose to redeem for.

Redeeming Points for Statement Credits

You may redeem Rewards Points as a credit to your Account. The amount available to redeem, starting at $1 (for 200 points), is based on your Rewards balance. For every 200 Points = $1 Statement Credit.

Once redeemed, Statement credits redemptions may take up to 3 business days to post to your account. Statement credits lower the account balance and do not count towards your minimum monthly payment. Your minimum monthly payment will not be required if your statement credit is equal to or greater than your statement balance. Once you request a Statement Credit, your request cannot be changed or returned. Important Notice: Statement credits are only available up to the current balance on your account.

Redeeming Points for Merchandise

You may use Points to obtain Rewards through the Rewards Catalog. Merchandise orders will be confirmed by an email generated on behalf of the merchant by PrizeLogic.

Redeeming Points for Gift Cards

You may redeem Points for gift cards. Gift cards may be requested by you.

Except as required by law, gift cards will not be replaced or replenished if it is lost, stolen, destroyed, used without the intended recipient’s permission or used in a manner inconsistent with any law. Digital gift card orders will be confirmed by an email generated on behalf of the merchant by PrizeLogic.

Redeeming Points for Experiences

You may redeem Points for Experiences ("Experiences") through PrizeLogic, a non-affiliated third party, who is solely responsible for the administration of the Program with respect to goods or services offered on the Program Catalog.

All redemptions are for a pair of experience passes (2), unless otherwise noted. You will be notified either by telephone call or email communication for further arrangements and details. Substitutions may be necessary as Rewards are based on availability and are subject to change at any time and unless otherwise noted do not include travel to or from the experience and in some cases may require game day tickets. By redeeming Points for Experiences, you must abide by any terms and conditions in conjunction with the Experience. Experience passes are limited to personal use only and cannot be resold. Experiences are available on a first-come, first-served basis and are limited to two redemptions per cardmember, per experience and are from limited inventory. Experience passes (if required) will ship via FedEx or UPS to the address that you provide. We will not ship to a P.O. Box. Experiences could be canceled by the NFL or participating Team dependent on the current COVID guidelines of the NFL, the current policies of the NFL or participating Team, or local and State authorities. The NFL or participating Team have the right to refuse entry, or remove guests not adhering to their current guidelines. Children must be at least 10 years old and accompanied by someone 18 years or older to attend, unless stated otherwise.

Redeeming Points for Game Tickets

All redemptions are for a pair of tickets (2), unless otherwise noted. Game Tickets are limited to personal use only and cannot be resold. Ticket sections and seats will be determined by order date and are available on a first-come, first-serve basis. Ticket redemptions are limited to two redemptions per cardmember, per game and are from limited inventory, subject to availability. Game tickets do not include travel to or from the game. By redeeming Points for Game Tickets, you must abide by the terms and conditions in conjunction with the Game Tickets. Points required to redeem for NFL tickets may be subtracted in advance of gameday. If you redeem for NFL tickets at a higher points value and the points required for redemption are later lowered, a points refund will not be provided. Tickets will ship via FedEx or UPS to the address that you provide or for digital delivery, to an email address that you provide. We will not ship to a P.O. Box. Ticket redemptions made prior to late August will be held and processed in late August when Comenity Capital Bank receives the tickets from the NFL. Tickets will then be shipped/delivered within 24 hours of availability. Redemptions processed from September forward will be delivered within 3-5 business days of redemption.

Other Terms

Points may not be sold, transferred or altered in any way by you. Points you earn may not be combined with Points earned on any other credit account or earned by anyone else (other than your Authorized User).

You may review your Points balance via Account Center. It may take up to two billing cycles for Points to post. The amount of Points earned is based on the date your purchase was made, which may be different than the date the transaction posts to your Account. For mail order, special order, online, and other purchases, your transaction may not post to your Account until items have shipped.

Communications and Customer Service

Comenity Capital Bank and the National Football League may send communications regarding the Program by mail, phone, email or other methods, including through online Account Center or mobile app. By providing your mobile phone number, Comenity Capital Bank may contact you about all of your accounts and this Program.

If you have any questions about the Program or to update your contact information, please contact :1-888-232-1512 or TDD/TTY: 1-888-819-1918 or visit Account Center. You can review your Program activity at MyNFLExtraPoints.com/visa or on your billing statement.

Points Disputes

If Points you believe were earned have not timely posted to your Points balance, you may dispute your Points balance (“Points Dispute”) [by calling 1-888-232-1512 or TDD/TTY: 1-888-819-1918 or by writing to Comenity Capital Bank. Comenity Capital Bank will use reasonable efforts to investigate your Points Dispute if you notify us within 90 days of the posting date. If you do not notify us within that period, you waive your right to make a Points dispute with respect to that purchase. Comenity Capital Bank may require you to provide written confirmation of the dispute and the applicable purchase receipt and may decline to investigate further if you do not provide the requested confirmation or a valid receipt. Upon completion of the investigation, Comenity Capital Bank will have no further responsibilities if you later reassert the same Points Dispute.

Limited Liability

Unless otherwise required by law, the National Football League, neither Comenity Capital Bank, nor any of its affiliates, officers, directors, employees, service providers, including PrizeLogic and MKTG, or agents will be liable to you, or anyone making a claim on your behalf, in connection with the Program or these Program Terms, including but not limited to, use of the Program and any redemption for or purchase of products or services through the Program.

Important note: Notwithstanding the foregoing, any liability that Comenity Capital Bank may have to you in connection with the Program shall be limited to the amount of any Points you have earned in accordance with these Program Terms. In addition, unless otherwise required by law, you and we each waive the right to seek punitive or exemplary damages against the other.

No Warranties

The National Football League, the Bank and all of each of such company’s respective subsidiaries and affiliates make no warranty, express or implied, including but not limited to, any warranties of merchantability or fitness for a particular purpose with respect to the Program or any products or services related to such Program. Such companies do not guarantee the performance of Rewards, or products or services obtained through the Program, nor do they operate or control the merchandise, gift certificates, or gift cards offered as Rewards.

Taxes

You are responsible for any tax liability that may result from participation in the Program. Consult your tax advisor concerning such tax consequences.

Cancelling Program Participation

You may cancel your participation in the Program at any time by calling Comenity Capital Bank at 1-888-232-1512 or TDD/TTY: 1-888-819-1918. If you cancel your participation in the Program, you will no longer earn Points and you will forfeit your unused and unexpired Points. Your cancellation will not affect any previously redeemed Rewards.

Governing Law; Assignment

The Program and these Program Terms are governed by federal law and, to the extent state law applies, the laws of the State of Utah. You may not assign your rights or obligations under these Program Terms to any other person or entity. Important note: You and Comenity Capital Bank agree that each of us may bring claims arising from or relating to these program terms only on an individual basis and not as a plaintiff or class member in any purported class or representative action or proceeding.

“Claim,” as used in these Program Terms means any claim, dispute or controversy that in any way arises from or relates to these Program Terms.

Complete Agreement; Severability; Conflicts; No Waiver

These Program Terms supersede any previous terms and conditions governing the Program. The Program is not available where and to the extent prohibited by law. If any part of these Program Terms conflict with applicable law, that provision will be deemed severed from these Program Terms and the remainder of the Program Terms will remain in effect. Comenity Capital Bank will not lose our rights under these Program Terms because Comenity Capital Bank chooses to delay or not enforce them.

Licensing

The NFL Extra Points Visa Credit Card is issued by Comenity Capital Bank, pursuant to a license from Visa Inc.