Personal Information We Collect. We collect the following personal information: • Identifiers, such as name, alias and government issued identifier such as Social Security Number, Driver’s License Number, and Passport Number; • Personal Information, such as contact information (e.g. address, telephone number, email address); • Personal financial information, such as payroll stubs, personal financial statement, tax returns, records of personal property, real estate owned and business interests. • Characteristics of protected classifications such as marital status and sex; • Commercial information such as transaction information and purchase history; • Biometric information, such as fingerprints and voiceprints; • Internet or Network activity information, such as browsing history and interactions with our Bank website; • Geolocation data, such as device location and Internet Protocol (IP) address; • Audio and visual recordings, such as recorded call information and Branch Office/ATM video camera recordings; • Professional or employment-related information, such as work history, professional designations and prior employer; • Education information, such as student records; and • Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.
We obtain this personal information from the following sources: • Information you provide to us when applying for a loan or opening a deposit account, or any related services; • Information from service providers such as third-party identification services, consumer data resellers and other third parties • Information received from credit reporting agencies; • Information from search engines, including social media, mobile app activity and website • Information from Corporate Customers about individuals associated with those Corporate Customers, such as their employees and owners; • Information from Customer directed third parties, such as CPAs and attorneys. • Job Application with us, and; • Government entities
Personal Information We Sell. We do not sell personal information.
Personal Information We Disclose for Business or Commercial Purpose. We disclose the following personal information for a business or commercial purpose: • Identifiers, such as name, alias and government issued identifier such as Social Security Number, Driver’s License Number, and Passport Number; • Personal Information, such as contact information (e.g. address, telephone number, email address); • Personal financial information, such as payroll stubs, personal financial statement, tax returns, records of personal property, real estate owned and business interests. • Characteristics of protected classifications such as marital status and sex; • Commercial information such as transaction information and purchase history; • Biometric information, such as fingerprints and voiceprints; • Internet or Network activity information, such as browsing history and interactions with our Bank website; • Geolocation data, such as device location and Internet Protocol (IP) address; • Audio and visual recordings, such as recorded call information and Branch Office/ATM video camera recordings; • Professional or employment-related information, such as work history, professional designations and prior employer; • Education information, such as student records; and • Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.
We disclose personal information only with those vendors providing the servicing of your products and services, and we require them not to sell, share, or use your information for any other purpose. The categories of users with whom we share this information include: • Vendors and Service Providers who provide services, such as data analysis, payment processing, information technology and related infrastructure, customer service, email delivery, auditing, credit card issuance, marketing and marketing research. • Third Parties who provide services such as investment products, credit cards, payment, banking and communication infrastructure, storage, legal expertise, auditors. • To approve or decline loan or deposit account applications; • To consider your job application for hiring; • To provide institution risk analysis and risk mitigation from consultants and auditing firms. • To detect security incidents. • Government Agencies, as required by laws and regulations.
Personal Information We Collected Within the Past 12 Months
We must disclose the personal information we have collected, sold, or disclosed for a business or commercial purpose within the past 12 months.
Personal Information We Collected. We collected the following personal information:
• Identifiers, such as name, alias and government issued identifier such as Social Security Number, Driver’s License Number, and Passport Number; • Personal Information, such as contact information (e.g. address, telephone number, email address); • Personal financial information, such as payroll stubs, personal financial statement, tax returns, records of personal property, real estate owned and business interests. • Characteristics of protected classifications such as marital status and sex; • Commercial information such as transaction information and purchase history; • Biometric information, such as fingerprints and voiceprints; • Internet or Network activity information, such as browsing history and interactions with our Bank website; • Geolocation data, such as device location and Internet Protocol (IP) address; • Audio and visual recordings, such as recorded call information and Branch Office/ATM video camera recordings; • Professional or employment-related information, such as work history, professional designations and prior employer; • Education information, such as student records; and • Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.
Personal Information We Sold. We did not sell personal information in the past 12 months.
Personal Information We Disclosed for Business or Commercial Purpose. We disclosed the following personal information for a business or commercial purpose: • Identifiers, such as name, alias and government issued identifier such as Social Security Number, Driver’s License Number, and Passport Number; • Personal Information, such as contact information (e.g. address, telephone number, email address); • Personal financial information, such as payroll stubs, personal financial statement, tax returns, records of personal property, real estate owned and business interests. • Characteristics of protected classifications such as marital status and sex; • Commercial information such as transaction information and purchase history; • Biometric information, such as fingerprints and voiceprints; • Internet or Network activity information, such as browsing history and interactions with our Bank website; • Geolocation data, such as device location and Internet Protocol (IP) address; • Audio and visual recordings, such as recorded call information and Branch Office/ATM video camera recordings; • Professional or employment-related information, such as work history, professional designations and prior employer; • Education information, such as student records; and • Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.
We did not share your personal information except as is permitted by law. We disclosed personal information only with those vendors providing the servicing of the products and services you selected, and we require them not to sell, share, or use your information for any other purpose. The categories of users with whom we have shared this information include: • Vendors and Service Providers who provide services, such as data analysis, payment processing, information technology and related infrastructure, customer service, email delivery, auditing, credit card issuance, marketing and marketing research. • Third Parties who provide services such as investment products, credit cards, payment, banking and communication infrastructure, storage, legal expertise, auditors. • To approve or decline loan or deposit account applications; • To consider your job application for hiring; • To provide institution risk analysis and risk mitigation from consultants and auditing firms. • To detect security incidents. • Government Agencies, as required by laws and regulations.
Your Rights Regarding Your Personal Information
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Collection of Personal Information. You have the right to request the following information about the personal information that we have collected about you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- The purpose for collecting your personal information.
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Disclosure of Personal Information. You have the right to request the following information about the personal information that we have disclosed for a business purpose about you:
- The categories of personal information we collected about you. (above)
- The categories of third parties with whom we disclosed your personal information.
- The categories of personal information we disclosed about you and the purpose for disclosure, if applicable.
- Deletion of Personal Information. You have the right to request us to delete any personal information that we have collected about you. Subject to certain exceptions, we will delete the personal information that we have collected about you from our records, and we will direct any service provider to whom this information has been disclosed to delete your personal information from their records as applicable.
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Non-Discrimination. We will not discriminate against you for exercising any of these rights and we will not do any of the following if you exercise any of your rights listed above unless permitted by the CCPA:
- Deny you goods or services;
- Charge you different prices or rates for goods or services, including through the use of discounts or other benefits or imposed penalties;
- Provide you a different level or quality of goods or services; or
- Suggest that you may receive a different price or rate for goods or services of a different level or quality.
How to Submit a Request Regarding Your Personal Information
To exercise your rights set forth above, you can submit a verifiable request to us by any of the following methods:
Your request to us must be a verifiable request, meaning we must be able to verify your identity and that the personal information that we collected relates to you. We will respond with 45 days once we receive your request. If we need more time, we will inform you of the reason for the delay during this time period and may extend the time to respond up to an additional 45 days. We will provide a written response free of charge to you, and we will deliver the response to your account or, if you choose, by mail or electronically.
Special Notice for State Residents
For Vermont Customers. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing without your authorization, and we will not share personal information with affiliates about your creditworthiness without your authorization.
For Alaska, Illinois, Maryland and North Dakota Customers. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing – without your authorization.
For Massachusetts, Mississippi and New Jersey Customers. We will not share personal information from deposit or share relationship with nonaffiliates either for them to market to you or for joint marketing – without your authorization.
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