A. Information We Collect
We collect information that identifies, relates to, references, describes, or is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or device (”personal information”). In particular, We have collected the following categories of information in the last 12 months:
- Personal Identifiers (which may include Your name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number or other similar identifiers);
- Personal information categories listed in the California Customer Records statute, Cal. Civ. Code § 1798.80(e) (which may include a name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial, medical, or health insurance information);
- Protected classification characteristics under California or federal law (which may include Your age, race, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex. veteran or military status);
- Commercial information (which may include records of personal property, products, or services purchased, obtained or considered, or other purchasing or consuming history or tendencies);
- Biometric information (which may include voice recordings, fingerprint, keystroke patterns and rhythms);
- Internet or other similar network activity (which may include browsing history, search history, information on Your interaction with a website, app, or advertisement);
- Geolocation data (any information used to identify Your physical location);
- Sensory data (which may include audio, electronic, visual, thermal, olfactory, or similar information);
- Professional or employment-related information (which may include current or past job history);
- Education information (which may include the details of Your education and qualifications); and
- Inferences drawn from other personal information (which may include a profile reflecting a person’s preferences, characteristics, behavior, and attitudes).
For purposes of this section, personal information does not include publicly available information, de-identified or aggregate consumer information, or information excluded from the CCPA’s scope (such as (1) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data or (2) personal information covered by sector specific laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act(“GLBA”), the California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994.
B. Sources of Personal Information
We obtain the personal information listed above from the following categories of sources:
Directly from You;
Automatically collected information;
Indirectly from employers, either employee listings, or employment verification related to the extension of credit;
Activity on Our website, such as from submissions through Our chat, message center, or online banking system;
Directly through recording of interactions with digital or live service agents; and
From third-parties that provide services for the transactions and products that We provide, such as loan servicing providers, collection agencies, credit reporting agencies, document providers, and other providers.
C. Use of Personal Information
We may use and/or process the personal information We collect about You for one or more of Our legitimate business purposes. For example, We may use Your information:
- To provide You with information, products and services You request from Us;
- For regulatory compliance purposes (i.e. Bank Secrecy Act, Home Mortgage Disclosure Act, Flood Act, etc.);
- To provide You with alerts and other notices related to Your transactions;
- To recommend products or services that may be of interest to You;
- To improve products, services and channels that may be of benefit to You;
- To respond to law enforcement requests and as required by applicable law, court order, or government regulations;
- To evaluate or conduct a merger, or other sale of assets, such as selling mortgage loans to Federal National Mortgage Association (FNMA), in which personal information held by Us is among the assets transferred; and
- As described to You when collecting Your personal information or as otherwise set forth in CCPA.
D. Disclosure of Personal Information
We may share information about You, including personal information, with subsidiaries who are subject to this California Consumer Privacy Notice or follow practices at least as protective as those described here, or with Our third party service providers with whom We have entered into contracts that require personal information be kept confidential and prohibit the retention, use, or disclosure of personal information for any purpose other than the services specified. We do not share or disclose Your personal information for commercial purposes without Your separate consent, except as described below:
You and, where appropriate, Your family, Your associates, and Your representatives;
Third Party Service Providers;
Government, legal, regulatory, or other similar authorities and/or agencies, when requested or required;
Any relevant third parties if We purchase other businesses or their assets, sell Our business assets, or are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets; and,
Other third parties, when We believe it is appropriate to comply with the law, it is necessary to protect Our interests, to prevent fraud or other illegal activity, and to protect the safety of any person; but, nothing in this California Consumer Privacy Notice is intended to limit any legal defenses or objections that You may have to a third party’s, including a government’s, request to disclose Your information; and
We may disclose de-identified, aggregated, non-personal data received from providing the Websites with certain trusted business partners, without restriction.
In the preceding twelve (12) months, We have not sold any personal information. We will not sell Your personal information.
E. Your Rights and Choices
The CCPA gives California residents specific rights about their personal information. These rights include:
- Access to Specific Information and Data Portability. You have the right to ask Us about what personal information We have collected about You over the past 12 months and how We have used or disclosed that information, including: (1) the categories of personal information We collected about You; (2) the categories of sources for the personal information We collected about You; (3) Our business or commercial purpose for collecting that personal information; (4) the categories of third parties with whom We share that personal information; and (5) the specific pieces of personal information We collected about You (also called a Data Portability Request).
- Deletion Request. You have the right to ask Us to delete any of the personal information that We collected from You over the past 12 months and still retain, subject to certain exceptions. Once We receive and confirm Your verifiable consumer request (see below) We will delete the applicable information from Our records, unless an exception applies or it is necessary for Us or Our service providers to: (1) complete the transaction for which We collected the personal information, provide a product or service that You requested, or take actions reasonably anticipated within the context of Our ongoing business relationship with You; (2) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (3) comply with applicable state and federal regulations or comply with a legal obligation or otherwise using the personal information, internally, in a lawful manner; (4) enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us; or (5) for a purpose otherwise contemplated by Cal. Civ. Code Section 1798-105(c)-(d) and as amended.
F. Exercising Your Rights
To exercise Your rights above, please submit a verifiable consumer request to Us by either: (1) emailing Us at CustomerSupportDept@firstbankrichmond.com and providing Your full name and email address and the request that You are making (e.g., right to access, portability or deletion); or (2) mailing Your request to the address in the Contact Us section, below. You don’t need to create an account with Us to make a verifiable consumer request; but, if You do have an account with Us, We may require You to use it to make Your request.
Only You, or someone legally authorized to act for You, may make a verifiable consumer request about Your personal information. You (including Your authorized representative) may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative.
- Describe Your request with sufficient detail that allows Us to properly understand and respond to it.
We cannot respond to Your request or provide You with personal information if We cannot verify Your identity or authority to make the request.
G. Format of Response and Timing
We will let You know whether We received Your request within 10 days will try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If We require more time, We will inform You of the reason and extension period. If You have an account with Us, We will deliver Our written response to that account. If You do not have an account with Us, We will deliver Our written response by mail or electronically. Any disclosures We provide will only cover the 12-month period preceding the request's receipt. The response We provide will also explain the reasons We cannot comply with a request, if applicable. For data portability requests, We will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity.
We do not charge a fee to process or respond to Your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If We determine that the request warrants a fee, We will tell You why We made that decision and provide You with a cost estimate before completing Your request.
We will not discriminate against You for exercising any of Your CCPA rights. Unless permitted by the CCPA, We will not: provide You a different level or quality of goods or services; suggest that You may receive a different price or rate for goods or services or a different level or quality of goods or services; deny You goods or services; or, charge You different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
We may offer certain financial incentives permitted by the CCPA that could result in different prices, rates, or quality levels. The incentive will reasonably relate to Your personal information's value to Us and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires Your prior opt in consent, which You may revoke at any time.
By email: CustomerSupportDept@firstbankrichmond.com
By phone: (765) 962-2581
First Bank Richmond
P.O. Box 937
Richmond, IN 47375-0937