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California Consumer Privacy Act (CCPA) Notice at Collection

Last updated January 1, 2024

Applicable to California Residents Only

Liberty Bank, N.A. ("Liberty," the "Bank," "we," or "our") respects your privacy and is committed to the proper handling of the personal information collected or processed in connection with your relationship with the Bank.

The California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the "CCPA"), requires that we disclose categories of personal information we may collect about California residents, the categories of sources from which we collect it, and the business or commercial purpose for its collection.

COLLECTION OF PERSONAL INFORMATION

We may collect the following categories of personal information and categories of sensitive personal information:

"Categories of Personal Information" the categories of personal information we may collect include the following:

  • Identifying Information is information that identifies an individual, such as an individual's name, alias, birthdate, account name, or other similar unique identifier.

  • Associated Information is information that relates to, describes, or can reasonably be associated with a particular individual, such as a signature, postal or email address, telephone number, insurance policy number, bank account or card number, or any similar information.

  • Characteristic Information is information related to characteristics of protected classifications under state or federal law, such gender or marital status.

  • Commercial Information is information of a commercial nature, such as records of personal property, products or services purchased or considered, or other purchasing histories.

  • Biometric Information is information related to the measurement or analysis of unique physical or behavioral characteristics, such as a fingerprint or voice pattern.

  • Internet Activity Information is information related to internet or other electronic network activity, such as a search or browsing history, or interactions with a website.

  • Geolocation Information is information or data related to a geographical location, such as a device or Internet Protocol (IP) location.

  • Audio Visual Information is audio, visual, electronic, or similar information.

  • Employment Information is professional or employment-related information, such as employment history or status.

  • Education Information is personally identifiable education information that is not publicly available.

  • Inference Information is inferences drawn from any other category of personal information to create a profile about an individual reflecting potential or probable preferences, behavior, abilities, or other similar predispositions.

"Categories of Sensitive Personal Information" the categories of sensitive personal information we may collect include the following:

  • Identification Numbers are any information that reveals an individual's social security number, driver's license number, state identification card number, or passport number.

  • Financial Account Information and Credentials are any information that reveals an individual's account login number, financial account number, such as a loan number or deposit account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials, which would allow someone to gain access to the account.

  • Precise Geolocation Data is any data that is derived from a device and that is used or intended to be used to locate an individual within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet.

  • Background Information is any information that reveals an individual's racial or ethnic origin.

  • Personal Messages are the contents of an individual's mail, email, and text messages if the individual is an employee of the Bank, and where the Bank is not the intended recipient of the communication.

  • Health Information is any personal information collected and analyzed concerning an individual's health if the individual is an employee of the Bank.

PURPOSES FOR WHICH WE COLLECT PERSONAL INFORMATION

We may collect the categories of personal information and categories of sensitive personal information identified above for the following business or commercial purposes:

  • Providing our products and services: Performing services, including maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, or providing financing.

  • Marketing/Prospecting: Performing services, including providing advertising or marketing services, providing analytic services, or providing similar services (except we do NOT use any of the Categories of Sensitive Personal Information we collect to advertise or market products or services to consumers).

  • Fraud Prevention: Performing services, including protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

  • Improving our products and services: Undertaking activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance the service controlled by the Bank.

  • Research: Undertaking internal research for technological development.

  • Legal Compliance/Legal Proceedings: Complying with laws, regulations, and with other legal processes and law enforcement requirements, including any internal policies based on or reflecting legal or regulatory guidance, codes, or opinions. Supporting audit and investigations, legal requests, and demands from regulatory authorities.

  • IT Operations: Detecting security incidents and debugging to identify and repair errors that impair existing intended functionality.

  • Financial Management: Performing accounting, monitoring, and reporting.

  • Security: Ensuring security and integrity to the extent the use of Personal Information is reasonably necessary and proportionate. To help maintain the safety, security, and integrity of our mobile application or website, products and services, databases, and other technology assets.

  • Operation of company websites: To provide, support, personalize, and develop our website or mobile application, products, and services.

  • Investigations: To provide you with support and to respond to your inquiries, including investigating and addressing your concerns, as well as monitoring and improving our responses.

  • Human Resource Management: Identifying and processing employment applicants, including conducting background checks and verifying qualifications for employment. Administering employee services, including pay/compensation, and providing benefits to employees and dependents, including healthcare and retirement plans. Managing the health and safety of our employees.

RETENTION OF PERSONAL INFORMATION

Under the CCPA, the terms "share" and "sale" refer to providing information to a third party for the purposes of advertising and targeted marketing. We do not share or sell information as contemplated by the CCPA.

Personal information collected by us will be retained as required to provide services and comply with regulatory and legal obligations.

CCPA PRIVACY POLICY

For more information on our collection of personal information, refer to our CCPA Privacy Policy on our website.

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