Recognition of Customers’ Expectations of Privacy
Our customers' trust is our most important asset. We understand that a key to maintaining that trust is meeting our customers’ concerns about the privacy of nonpublic personal financial information. Nonpublic personal financial information is non-publicly available information about an individual who applies for or receives a financial product or service from us for personal, family or household purposes. We recognize that our customers are concerned about the confidentiality and security of nonpublic personal financial information and expect us to obtain, keep and use the information in an appropriate and responsible fashion. Doing so is a responsibility we take seriously.
Obtaining, Keeping and Using Information
Obtaining, keeping and using information is the core of our business because we must do those things to serve our customers in their financial relationships with us. We obtain, keep and use many types of information, including nonpublic personal financial information. But we limit the obtaining, keeping and use of nonpublic personal financial information to lawful information we believe useful in conducting our business, complying with applicable law, providing quality service to consumers and offering products, services and opportunities to consumers.
Maintenance of Accurate Information
We recognize that it is important to our customers that we maintain the accuracy of information concerning their financial relationships with us, and we have established procedures to maintain the accuracy of the information in accordance with reasonable commercial standards. The procedures include responding in a timely manner to a request from one of our customers to correct any information concerning his or her financial relationships with us that he or she believes is incomplete, not current or otherwise inaccurate and taking steps to correct the information if we determine it to be inaccurate.
Limiting Employee Access to Information
We educate our employees on the importance of maintaining the confidentiality and security of nonpublic personal financial information. We limit access by our employees to nonpublic personal financial information to employees who have a business reason for knowing the information and who have been trained in the proper handling of the information. We have established procedures to protect against unauthorized access to nonpublic personal financial information by our employees. Under the procedures, any of our employees who obtain unauthorized access to nonpublic personal financial information is subject to appropriate disciplinary procedures.
Protection Against Unauthorized Access to Information
We recognize the importance of providing safeguards on access to nonpublic personal financial information. Consequently, we have established security procedures and physical and electronic measures to protect against unauthorized access to nonpublic personal financial information.
Restrictions on Disclosure of Information
We do not disclose nonpublic personal financial information to nonaffiliated third parties (including government agencies) except as allowed by and in accordance with applicable law. Examples of circumstances in which we may disclose nonpublic personal financial information of a consumer to a nonaffiliated third party are:
- For purposes of credit reporting, credit verification, risk management or dispute resolution;
- To complete a transaction requested or authorized by the consumer;
- As authorized to by the consumer;
- To protect the confidentiality or security of records relating to the consumer, an account of the consumer or a transaction involving the consumer;
- To prevent fraud or an unauthorized transaction;
- To comply with applicable law in connection with a legal proceeding or governmental investigation or examination; and
- As described below in the section entitled “Maintaining Customer Privacy in Business Relationships With Nonaffiliated Third Parties.”
Maintaining Customer Privacy in Business Relationships With Nonaffiliated Third Parties
To serve customers in their financial relationships with us, we occasionally contract with nonaffiliated third parties (for example, check-printing and data processing companies) to perform services for us. We disclose nonpublic personal financial information to those nonaffiliated third parties but only to the extent necessary for them to perform those services, and we require them to keep and use the information only as we intend it to be kept and used and to disclose it only as allowed by and in accordance with applicable law.
No Disclosure of Information for Marketing Purposes
We do not disclose any nonpublic personal financial information to nonaffiliated third parties for marketing purposes.