Commitment to Safeguarding Consumer Privacy
We recognize that our relationship with you is based on trust, and the protection of your private financial information merits the highest priority. That’s why we have taken stringent measures and established corporate-wide procedures that ensure the confidentiality of all of your confidential information, whether we have received it directly from you or from a third party.
This policy outlines those procedures, and will be provided to you each year as long as you maintain an ongoing relationship with us.
Our Business Practices
We collect only the information we need in order to serve you and conduct our business.
We treat all personal and financial information about you in a confidential manner. This information may be obtained directly from you, or may be collected from other sources, or may result from applications you process with us.
We maintain physical, electronic and procedural safeguards to protect customer information. We utilize state-of-the art technology for this purpose and upgrade, when appropriate, to improve our privacy protection performance.
We limit access to your personal and financial information to those of our employees, agents and service providers that are required to have access to it in order to meet your financial needs or conduct our business.
All of our employees, agents and service providers are responsible for compliance with the policies and procedures we have established to safeguard your personal and financial information.
Our employees are governed by a Code of Conduct, which expressly requires the confidentiality of customer information, and our employees receive training in the importance of adhering to the procedures we’ve established to assure that confidentiality.
Our data processing and electronic operations are performed in a secure technical environment that is accessed only by authorized personnel to transact legitimate business operations.
We maintain electronic safeguards to protect customer privacy on our websites. This assures that when you conduct your business with us from your home or office, the privacy of your relationship and the information you furnish us online is protected.
We carefully monitor our compliance with applicable laws and regulations and our internal security policies and procedures.
Information we collect and use
We collect and use various forms of information to open and service your accounts with us. We may also use this information to determine if other products or services might be of interest to you.
We collect and use nonpublic personal and financial information about you from the following sources:
- Information we receive from you on applications or other forms
- Information about you and your transactions with us, our affiliates, or others
- Information we receive from a consumer reporting agency, medical sources, security firms, inspections of your properties or interviews with you or persons as directed by you
Information we receive about you from third parties may include credit bureau reports from consumer reporting agencies, or verifications received from other companies, in connection with insurance applications or other transactions you have requested.
Sharing Information with Other Companies that do word for us
The law permits us to share all of the personal and financial information we collect, as described above, about our customers or former customers, with companies that do work for us, including our affiliates, as necessary to or in connection with:
- Effecting, administering or enforcing a transaction that you have requested or authorized
- Servicing or processing a financial product or service that you have requested or authorized
- Maintaining or servicing your account with us
- A transaction that necessitates the sharing of such information when such sharing is permitted by law
These companies may include financial services providers, non-financial service providers and others. All of these companies act on our behalf, and are contractually obligated to use the information that we provide to them only to provide the services that we have contracted with them to perform. Each company is required to keep all such information strictly confidential, and is prohibited from making any of this information available to any other entity.
The law also permits us to disclose personal and financial information in other circumstances, but we do not disclose any personal and financial information about our customers or former customers to anyone, except as permitted by law. This may include information provided:
- With your consent or direction
- To comply with federal, state or local laws or other legal requirements, or a subpoena, summons, or judicial process, or to federal, state or local authorities, to the extent authorized by applicable law and regulation, including the Right to Financial Privacy Act
- To protect the confidentiality or security of records pertaining to you, or a service, product or transaction pertaining to you
- To protect against fraud, unauthorized transactions, claims or other liability
- To a fiduciary on your behalf, or to your attorney or accountant, as authorized by you
- Under other circumstances authorized by law or regulation
Sharing Information with our Affiliates
The law permits us to share all of the personal and financial information we collect, as described above, about our current and former customers, with our affiliates, each of which provides financial products and services.
In addition, the law permits us to share other information that we collect about you with our affiliates, including information we obtain from:
- A third party to verify representations made by you
- A third party regarding their employment, credit or other relationship with you such as a verification of your employment or credit history