Special Note: The Sites are general audience sites and are not designed or intended to target children younger than 16. We do not knowingly target or collect personal information from any person younger than 16.
What Information Do We Collect?
Information We Collect Automatically. If you use the Sites, read or download information, your web or mobile browser may automatically send us your internet or other network activity, including one or more of the following (collectively, “Network Information”):
- Your internet protocol (IP) address, registration date, and one or more cookies that may uniquely identify your browser; Your internet domain and the specific path, actions, and navigation choices;
- The internet address of the site from which you linked the Sites, and the time and date you accessed the Sites;
- Your browsing history, search history, information on your interaction with the Sites or other websites and applications or advertisements; and
- Your browser software, operating system and browser language, and information about your location and mobile device, including a unique identifier for the mobile device.
Information You Give To Us and Information We Collect From Others. If you are a customer, or you otherwise use or purchase our Services, we receive and store information you enter on the Sites. We may also collect personal information from third parties that operate (a) portions of the Sites on our behalf or (b) independent websites. When we obtain personal data from third parties, we will treat the acquired information like the information that we collect ourselves. Depending on the Services we provide to customers and/or the services being provided to us by other third parties, we may collect (and over the previous 12 months have collected) the following information about you from you and/or others:
- Network Information;
- Personal information and identifiers, such as name, postal address, email address, telephone numbers, account name, social security number, driver’s license or state identification card number, passport number or other similar information, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information (collectively, “Personal Information and Identifiers”);
- Protected classification information, such as race, color, ancestry, marital status, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status (collectively, “Protected Class Information”);
- Commercial information, such as the Services purchased, obtained or considered, or other purchasing or consuming histories (collectively, “Commercial Information”);
- Biometric and identifying information, such as fingerprints or faceprints (collectively, “Biometric Information”);
- Sensory data, such as audio, electronic, visual, thermal, olfactory or similar information (collectively, “Sensory Information”);
- Geolocation data, such as physical location or movements (collectively, “Geolocation Information”);
- Professional or employment-related information, such as work history and job descriptions with current and prior employers (collectively, “Employment Information”);
- Education information, such as student financial information, class lists and other records related to a student maintained by an educational institution or party acting on its behalf (collectively, “Education Information”); and
- Inferences drawn from any of the personal information listed above to create a profile or summary, such as, for example, an individual’s preferences, abilities, aptitudes, predispositions, and characteristics (collectively “Profile Information”).
Why We Collect: We collect this information for business and commercial purposes, including in order to:
- To create, maintain, customize, and secure your account with us;
- To personalize your experience on the Sites and to deliver content and Services relevant to your interests and requests through our Sites (with your consent as required by law);
- To process your requests, purchases, transactions, and payments and to prevent financial fraud and other illicit activity;
- For testing, research analysis, and product development, including to develop and improve the Sites and Services.
- Initiate, assess, develop, maintain, or expand a business relationship, including negotiating, contracting, and fulfilling obligations under contracts;
- Perform due diligence regarding an individual’s qualifications and eligibility for the Services, including verifying the identity, qualification, authority, and creditworthiness of the individual and obtaining publicly-available information from third parties (such as publicly-available sanction lists from screening companies);
- Manage a database of email information, phone information or other information and send transactional communications (such as requests for information, responses to requests for information, orders, confirmations, training, and service updates);
- Manage accounts, including for accounting, finance, and dispute resolution purposes (such as accounts receivable, accounts payable, account reconciliation, cash management, or money movement) and for consolidated management and reporting;
- Assure quality control and to enforce the Bank’s standards and policies;
- Manage and mitigate risk, including for audit and insurance functions, and as needed to meet our obligations and to protect assets;
- Manage security, including monitoring individuals with access to the Sites, applications, systems, or facilities, investigation of threats, and as needed for any data security breach notification;
- Monitor and analyze web traffic and online behavior for search engine optimization and social media marketing;
- Host data files that enable the Sites to function, be distributed, and to provide specific features or parts of the Sites;
- Manage relationships with current and potential customers and for marketing purposes, including sending marketing, promotional, product and service, and customer communications and surveys and other communications to individuals who have not objected to receiving such communications;
- Anonymize or de-identify the personal information;
- View and incorporate content hosted on external sites;
- Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- Process payment information and transactions; and
- Report to credit bureaus.
Do We Share Information With Third Parties?
Over the previous 12 months, we have shared the following categories of personal information with third parties: Personal Information and Identifiers, Protected Classification Information, Commercial Information, Network Information, Sensory Information, Geolocation Information, Employment Information, Education Information, and Profile Information.
If you are a customer of the Bank and have a financial product or service with us, we will use and share information we collect from you or about you in accordance with the Bank’s Consumer Privacy Notice.
Your Consent. We may share personal data with your consent.
Disclosure For Legal Reasons. We may release personal data to third parties: (1) to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order; or (2) in special cases, such as a physical threat to you or others, a threat to homeland security, a threat to our system or network, or cases in which we believe it is reasonably necessary to investigate or prevent harm, fraud, abuse, or illegal conduct. We may also disclose personal data where needed to affect the sale or transfer of business assets, to enforce our rights, protect our property, or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions.
Links To Other Sites. The Sites may contain links to other websites and resources located on servers maintained by third parties. These links are provided for your convenience and information only and, as such, you access them at your own risk. When you click on one of those links, we will not provide any personal information about you, but may let the site know that you came from the Bank’s Sites. We do not control the privacy practices and policies of other sites. Please read their privacy policies in order to understand what information they collect about you and how they use it.
Aggregated, Non-Personal Information. We may share aggregated, non-personal information about you with third parties. This is information that is combined with the non-personal information of other users and does not allow you to be identified or contacted. Depending on the circumstances, we may or may not charge third parties for this aggregated information. We also may not limit the third parties’ use of the aggregated information.
Does the Bank Sell Your Personal Information?
How and Where Do We Process and Store Data?
How Do We Protect Personal Data?
The Bank protects data using administrative, technical, and physical safeguards. When we use third-party service providers, we ask those providers to implement similar safeguards. However, we cannot guaranty that your information is completely secure either within the Bank or on the systems of third party service providers.
How Long Do We Keep Your Personal Data?
We retain personal data we collect from you when we have an ongoing legitimate business need to do so (i.e., to provide you with the Services you have requested or to comply with applicable legal requirements). When we no longer have an ongoing legitimate business need to process your personal information, we will physically destroy, delete or anonymize it or, if this is not possible, then we will securely store your personal data and isolate it from any further processing until deletion is possible.
If you are a resident of California, please read the California Privacy Notice for more information regarding your privacy protections and privacy rights pursuant to the California Consumer Privacy Act of 2018.
How To Contact Us
Telephone Number: 1-800-815-2265
Email Address: firstname.lastname@example.org