Effective: September 25, 2023
At First Bank your privacy is important to us.
First Bank (“we”, “us” or “our”) is committed to the responsible use and protection of your Personal Information. This online privacy statement (“Online Privacy Statement” or “Statement”) describes how we collect, use, and disclose Personal Information collected by and through our website, eBanking services, including mobile applications, and other online interfaces or platforms that are owned or controlled by First Bank (“Online Services”) and the types of Personal Information we collect from you when you visit our Online Services.
Please read this Statement carefully to understand our policies and practices regarding your Personal Information. If you do not agree with our policies and practices, you should not use our Online Services. By accessing or using our Online Services you agree to the Online Privacy Statement in effect at the time.
Relation to Other Notices
This Statement supplements, but does not supersede, the following:
- The Consumer Privacy Notice, which explains our practices surrounding the collection, use, and sharing of your Personal Information when you obtain a financial product or service for a personal, family, or household purpose. You should read the Online Privacy Statement along with the Consumer Privacy Notice. In the event of a conflict between the Online Privacy Statement and Consumer Privacy Notice, the Consumer Privacy Notice will govern with respect to information that is “nonpublic personal information” as defined in Title V of the Gramm-Leach-Bliley Act and its implementing regulations.
- The “CALIFORNIA PRIVACY RIGHTS” section of this Statement, which applies to California residents who are not clients of First Bank or who have certain business relationships with us. In the event of a conflict between the terms of the Online Privacy Statement and the terms of the California Privacy Rights disclosure, the terms of the California Privacy Rights disclosure will govern with respect to the California residents noted above.
Information We Collect About You and How We Collect It
When you are using the Online Services, we may collect Personal Information about you. “Personal Information” is information that identifies or relates to you as an individual or that, along with other information, could identify you. We collect the following types of Personal Information:
Information You Provide
We collect information such as your name, address, telephone number, social security number, and birthdate, when you open an account online. We also collect your username, password, passcode, and account information when you use the Online Services.
We collect contact information, such as your name, email address, and telephone number, when you complete a “Contact Us” form, email or message the First Bank Service Center, register to attend a Bank event, subscribe to Bank newsletters, or enter one of our contests or promotions.
Information We Collect Automatically
We use automatic data collection technologies, such as cookies, as you navigate through and interact with our Online Services, to collect information about your equipment and browsing actions, such as your Internet Protocol (“IP”) address, device identifier, the operating system for the computer or device used to access the Online Services, the browser you are using, and usage data. We also collect information relating to details of your visits to our Online Services, including traffic data, location data, and activity logs.
Information Collected from Third Parties
We collect information from third parties, such as our service providers who assist us in providing the Online Services, and companies that provide us with information relating to your use of the Online Services, such as companies that send you electronic bills through the Online Services.
Cookies and Other Tracking Technologies
We use certain tracking technologies to collect information about your online activities over time and across third-party websites or other online services.
The information we collect automatically is generally analytic and statistical data that is not associated with other Personal Information about you, such as your name, address, and account information. We may associate data collected automatically with other Personal Information we have about you for security purposes, including fraud prevention and detection. Personal Information collected automatically that is used to serve advertisements to you is not associated with other Personal Information that we have about you, such as your name and email address.
Personal Information obtained by tracking technologies helps us improve our Online Services by enabling us to:
- Recognize you when you return to and move within our Online Services.
- Detect potential fraudulent interactions and transactions.
- Estimate our audience size and usage patterns.
- Speed up your searches.
- Serve you with relevant advertisements relating to First Bank products and services.
- Web Beacons. Our Online Service pages and email communications may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that enable us to count users who have visited those pages, opened an email from us, and to compile statistics related to the Online Services (for example, recording the popularity of certain website content and verifying system and server integrity).
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that browser cookies use. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted online advertising from third parties, see Choices About How We Use and Disclose Your Information.
How We Use Your Personal Information
We use Personal Information that we collect about you or that you provide to us to improve the Online Services and for our business purposes, including the following:
- To present the Online Services and their contents to you.
- To process your application for bank products and services.
- To respond to your inquiries and requests.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
- To notify you about changes to our Online Services or any products or services we offer or provide though them.
- To process your transactions and payments made through the Online Services.
- To authenticate your identity and for fraud prevention and detection purposes.
- For our business purposes, such as data analysis, audits, site enhancements, and identifying usage trends.
- In any other way we may describe to you when you provide the Personal Information.
- To contact you about products and services that may be of interest to you that are offered by us or by us and another financial services company, jointly.
- For any other purpose with your consent.
Please note that we also place advertisements that are not based on your online activities over time and across different websites. For example, we might place an ad for our mortgage products on a site that displays mortgage rates for local banks. Because these ads are placed without the use of tracking over time and across different sites, opting out of targeted advertising will not block them.
How We Disclose Your Personal Information
We may disclose Personal Information that we collect or you provide:
- To service providers, contractors, and other third parties who assist us in providing the Online Services and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
- To fulfill the purpose for which you provide it. (For example, if you make a payment to someone using Pay People, we will transmit information to that person with details about the payment and who it is from.)
- For any other purpose disclosed by us when you provide the information.
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of First Bank, our customers, or others. This includes disclosure of Personal Information for fraud prevention and detection purposes.
- With your consent.
Choices About How We Use and Disclose Your Personal Information
We strive to provide you with choices regarding the Personal Information you provide to us. You can exercise your choices regarding the use of your Personal Information as described below:
- Promotional Email Messages. If you do not wish for us to contact you by email about promotions for our products and services or jointly marketed products and services, you can opt-out by clicking the opt-out link in the footer of the email. This opt-out will not apply to information we send you by email relating to your existing relationship and accounts with us.
- Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver online targeted advertisements, you can opt-out by using your browser’s privacy features to place an ad blocker on your device.
- Third Party Tracking. We do not control third parties' collection or use of your information to serve interest-based advertising. These third parties may provide you with choices regarding collection and use of your information. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
- Do Not Track Signals. We do not recognize “Do Not Track” signals.
Children’s Online Privacy
Our website and social media sites are not intended for or directed to minors under 13 years of age. We do not knowingly solicit or collect online Personal Information from individuals under the age of 13.
We have implemented commercially reasonable measures designed to secure your Personal Information from unauthorized access, use, alteration, and disclosure. However, the safety and security of your Personal Information also depends on you. You are responsible for keeping your login credentials used to access Online Services and account information, such as account numbers, confidential. Visit our Security Hub for additional information about steps you can take to keep your accounts safe.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of Personal Information, which is at your own risk. You should not use email to communicate sensitive or confidential information (such as your bank account or social security numbers) to us. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website.
Accessing and Updating Your Personal Information
It is important that you keep your account information accurate and up to date. You can access, review and change your email address and telephone numbers by logging into the Online Services and visiting your Profile page. You may also contact the First Bank Service Center at 800-760-2265 or visit your local branch to update your address, telephone numbers, or email address. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Social Media Policy
First Bank’s purpose in having a presence in various social media sites is to engage with our current and potential clients. By sharing over 100 years of experience and knowledge, our goal is to build a stronger relationship with our clients and the communities that we serve.
Although we post information about First Bank, our employees, products, and events on our social media pages, our social media sites are NOT intended to serve as a client service channel. If you post a comment on any of our social media sites, the First Bank Service Center may contact you to address any concerns regarding your experience with us. For your own protection, you should never post an account number, telephone number, or any other confidential Personal Information on a social media site.
We do not tolerate inappropriate comments from users on our social media sites and reserve the right to remove any posts or comments that we in our own discretion deem inappropriate.
Changes to the Online Privacy Statement
We reserve the right to make changes to the Online Privacy Statement and the privacy practices disclosed therein, at any time. Your continued use of our Online Services after we make changes to the Statement constitutes your acceptance of those changes. You are responsible for periodically visiting our Website and the Online Privacy Statement to check for any changes. If we make material changes to our information practices governed by the Online Privacy Statement, we will notify you by posting a notice on our Website home page or as otherwise provided by applicable law. The Effective Date identified at the top of the page is the date that the Online Privacy Statement was last revised.
For More Information
If you have any questions or concerns about this Statement or First Bank’s privacy policies and practices, please contact the First Bank Service Center at 800-760-2265 or email [email protected].
CALIFORNIA PRIVACY RIGHTS
If you are a California resident with one of the following relationships, please read this section carefully as it provides information regarding your rights under the California Consumer Privacy Act (CCPA):
- Individual with a business relationship, such as a sole proprietorship or d/b/a account
- Individual who is an authorized signer on a business account
- Individual who is a guarantor on a business or commercial loan
- Non-client of First Bank who has interacted with the Bank’s webpage or social media sites
- Trustee for a trust
- Beneficiary for a trust for which First Bank is trustee
- Participant in a 401(k) or pension plan that First Bank sponsors or is a trustee or fiduciary of.
Right to Know
You have the right to know what Personal Information we collect, sell and disclose. We do not sell Personal Information. You have the right to request that we disclose the Personal Information that we have collected, used, disclosed and sold in the preceding twelve (12) months. We have not sold Personal Information in the preceding twelve months. At present, business-to-business transactions that we engage in are exempt from most CCPA requirements. However, because we believe transparency is important, we are disclosing the types of information that we collect, use, and disclose, in typical transactions. Likewise, the CCPA presently exempts Personal Information relating to employees from most requirements. We disclose the categories of Personal Information we collect and the reasons for doing so to the individuals with business transactions noted above and to applicants for employment. For other individuals described above, we will disclose your specific information, upon request and after we confirm your identity by matching information you provide to information we have on file. We may ask you to provide a government-issued photo identification, such as a driver’s license, as part of the verification process; however, we will not retain information from your identification, other than the state or country of issuance.
In order to request the information noted above, use our web form or call (800) 760-2265.
Right to Request Deletion of Your Personal Information
You have the right to submit a request asking us to delete your Personal Information. We may deny your request if we need your information to provide you with a product or service, comply with federal or state laws or regulations, detect security incidents, for fraud prevention, or for certain other internal uses. We must verify your identity prior to deleting your information. We do this by matching information you provide to information we have on file. We may ask you to provide a government-issued photo identification, such as a driver’s license, as part of the verification process. We will not retain information from your government-issued identification, other than the state or country of issuance. If your request is denied, we will tell you the reason for denial. We may deny your request if we are unable to verify your identity.
To request deletion of your Personal Information, please call the First Bank Service Center at 800-760-2265 or visit any First Bank branch.
Requests Submitted by Authorized Agents
You may authorize an individual or business registered with the California Secretary of State to submit a request on your behalf. In order for us to process the request, we must have a written document, signed by you, giving your authorized agent permission to make the request on your behalf. In order to protect your Personal Information, we may also verify your identity and/or confirm that you gave the authorized agent permission to submit the request(s). Your authorized agent may make a request by following the instructions in the “Right to Know” and “Right to Request Deletion of Your Personal Information” paragraphs, above.
Right to Opt Out of the Sale of Your Personal Information
The CCPA gives you the right to opt-out of the sale of your Personal Information. First Bank does not sell Personal Information.
Right to Non-Discrimination for Exercising Your CCPA Rights.
You have the right not to receive discriminatory treatment for exercising your privacy rights under the CCPA. First Bank will not discriminate against you for exercising any of your CCPA rights.
First Bank’s Recent Information Collection and Sharing Practices
We believe it is important you know and understand the types of Personal Information we collect and share and our reasons for doing so. We have outlined below our practices regarding the collection, use and sharing of Personal Information in the preceding twelve months:
Categories of Personal Information we collected:
- Identification Information, such as your name, address, email address, driver’s license number, social security number, date of birth, telephone number, and account name(s) and number(s).
- Commercial Information, such as the type, terms, and balances of products and services you have with us or that you applied for, financial information, such as your cash and account balances, property owned, and the balances of outstanding loans and bills payable.
- Demographic information, such as your age, ethnicity, race, citizenship, source of income, or veteran status.
- Internet/Other Electronic Network Activity Information, such as your IP address, browsing and search history, comments on any of the Bank’s social media pages, and information such as your User ID and information about payees in our Bill Pay and other online payment services.
- Geolocation Data, such as your location when you used an online service.
- Audio, Electronic, Visual, or Similar Information, such as photographs of events, including attendees, security footage, and images submitted to our social media sites, and electronic information, such as email correspondence and information entered on our website and other online services.
- Professional/Employment-Related Information, such as detail regarding your current and/or past employment and professional credentials.
- Education Information, such as your educational history, the names of educational institutions you attended and any degrees conferred.
- Profile Inferences. Information about your account usage, payment history and demographic information, such as your age and income.
Personal Information was collected from the following sources:
- You, or your authorized agent, when you completed an application or other required form
- Our employees
- Our service providers
- Your employer(s)
- Your educational institution(s)
- Our marketing service providers
- Our social media, website, and other online services
- Consumer reporting agencies
- Government entities
- Other financial institutions
- To verify your identity and authenticate transactions you initiated
- To process your applications for Bank products and services and to service your accounts with us
- To perform services on your behalf, such as processing transactions related to your accounts
- To review your use of our products and services
- To document our compliance with antidiscrimination laws and regulations
- To contact you when necessary
- To evaluate your creditworthiness and report to consumer reporting agencies, such as credit bureaus
- To file required reports with federal and state agencies
- For fraud prevention and investigation
- To perform quality assurance monitoring
- To create profile information to predict future account performance
- In our online channels, to assist you in locating our nearest branch
- For risk management and security purposes
- To inform you of other products and services that we believe would be beneficial to you
- To create profile information to enhance our marketing efforts
We disclosed the categories of Personal Information listed above for business purposes. Disclosure was made to the following categories of third parties:
- Our service providers
- Third parties that you authorized us to disclose your information to
- Consumer reporting agencies
- Government agencies
- Law enforcement
We did not sell any categories of Personal Information for business or commercial purposes. As such, we do not have actual knowledge that we have sold Personal Information of consumers who are under 16 years of age.