Online Privacy Statement

Respecting your privacy is important

Effective: July 9, 2024

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, collectively referred to in this Statement as the “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 consent to the terms of the Online Privacy Statement in effect at the time.

Relation to Other Notices
This Statement supplements, but does not supersede, the following:

  • The Terms of Use applicable to www.first.bank (“Website”).  In the event of a conflict between the Online Privacy Statement and Terms of Use, the Online Privacy Statement will govern with respect to the matters addressed therein.
  • 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 non-personal 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 identification information such as your name, address, telephone number, email address, 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.  For more information, refer to the Cookies and Other Tracking Technologies section, below.

Information Collected from Third Parties
We collect information from third parties, such as our service providers who assist us in providing the Online Services, security, fraud prevention, and payment processing.

Cookies and Other Tracking Technologies
We use cookies, pixel tags, logs, and similar mechanisms (“Tracking Technologies”) to automatically collect information about your online activities on our site and across third-party websites or other online services. More information about the types of Tracking Technologies we use may be found in our Cookie Statement.

We and our service providers may use Tracking Technologies to:
  • Provide the Online Services to you;
  • Enable us to distinguish between users;
  • Help us optimize, personalize, and otherwise improve your experience on the Online Services;
  • Provide security for the Online Services;
  • Collect information about how visitors use the Online Services;
  • Assist us in improving the performance of the Online Services; and
  • Enable online advertising delivered to you to be more relevant.
We may use Personal Information collected from Tracking Technologies to serve you with targeted advertisements based on your interests as determined by your browsing activities on third-party websites and other online services (“Targeted Interest-Based Advertising”).  Our advertising service providers may promote our products and services through Targeted Interest-Based Advertising on third party websites and mobile applications. For information about how you can opt out of Targeted Interest-Based Advertising, see Choices About How We Use and Disclose Your Personal Information.

Third Party Use of Tracking Technologies
Third parties may place Tracking Technologies in the Online Services and use them to collect information about your activity in the Online Services.  Advertising networks we participate in may place Tracking Technologies in our Online Services for the purpose of Targeted Interest-Based Advertising and may share information obtained through the Tracking Technologies with advertising network members. 

Our Online Services may contain videos and embedded content from First Bank’s YouTube channel, which is hosted by YouTube. YouTube may collect data about how you interact with this content, including any videos you watch. 

Our social media providers, including Facebook, Linked In, and YouTube, may use Tracking Technologies to collect or receive information from websites you visit and other internet information to provide targeted advertising and performance measurement services.  

We do not control third party 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 exercise your right to opt-out of collection of this information from our site, see Choices About How We Use and Disclose Your Personal Information.  Please note that if you opt out of collection from our web banner, that will not block other sites you visit from collecting this 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 online 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.

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.
  • To enforce or apply the Website Terms of Use, the eBanking Services Agreement, and other agreements that govern the products and services you have with us.
  • 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:
  • Analytics Services. We use a tool called Google Analytics to help us better understand how users use our Website. Google Analytics uses cookies to collect information such as how often users visit the Website, what pages they visit, and what other sites they visited prior to visiting the Website. Google, acting on our behalf, uses this information to evaluate your use of our Website and compiles reports on user activity for us. Google Analytics collects the IP address, mobile device identifier, or similar information assigned to you on the date that you visit the Website, but does not have your name. Information collected through the use of Google Analytics is not combined with other personal information that we have about you. To learn more about how Google Analytics collects and processes data and your right to opt-out of the collection and use of your data, visit http://www.google.com/policies/privacy/partners/.
If you would like to opt out of Google Analytics, you can do so by opting out of analytics cookies via our cookie banner or by downloading and installing the opt-out browser add-on developed by Google for your web browser. For more information, visit  https://support.google.com/analytics/answer/181881?hl=en
  • Tracking Technologies and Advertising. You can opt-out of Tracking Technologies used for Targeted Interest-Based Advertising through our web banner or by enabling the Global Privacy Control on your browser. If you opt-out using the web banner, please note you will need to manage your cookie settings for each device and browser that you use to access the Online Services. You may also set your browser to refuse all or some cookies, to alert you when cookies are being set, or you can use your browser’s privacy settings to place an ad blocker on your device. You can also opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website
  • Social Media Sites. You can manage YouTube’s access to your data by visiting Google’s Data & Privacy settings page. You can manage Facebook data through the Ad Preferences setting in your Accounts Center in Meta.  You can manage LinkedIN data through the Advertising Data settings in the Settings menu.
  • Do Not Track and Other Opt Out Signals. Some browsers contain a “Do Not Track” feature that, when enabled, tells websites you visit that you do not want your online activities to be tracked.  Because there is not a uniform standard for “Do Not Track” signals, we do not recognize them. We recognize the Global Privacy Control and other opt-out mechanisms meeting California requirements.
  • 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.
Please note that if you opt out of Targeted Interest-Based Advertising, you may still see First Bank online ads that are not based on your browsing activity across different websites and online channels. For example, we might place an ad for our mortgage products on a site that displays mortgage rates for local banks.  This ad placement is determined solely by the content on the site, and not on any user’s browsing activity.  Likewise, we might also place an ad for savings accounts on first.bank that appears after a user has browsed our savings products and moved to a different part of the first.bank site. This ad placement is determined based solely on a user’s activity within our site and does not consider browsing history elsewhere. 

If you disable certain cookies relating to the Website’s functionality, some parts of the site may be inaccessible or not function properly. You may not opt out of essential cookies, as they are necessary for the site’s operation.

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. 

Data Security
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.  Please 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 transmitted online, 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 your 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. 

The social media sites that First Bank participates in are owned by third parties and are not affiliated with First Bank; therefore, your activity and any content you post are governed by each site’s terms of use, privacy and security policies. We encourage you to familiarize yourself with each social media site’s terms of use, privacy and security policies for your own protection.

We may collect Personal Information about you from your interactions with our social media sites for the purposes and uses described in this Statement. If we disclose terms of use on our social media sites, you will also be subject to those terms when you interact with those sites.

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 email us at [email protected] or contact the First Bank Service Center at 800-760-2265.

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”) for Personal Information you provide to us in the context of the following relationships:
  • 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
  • Contact persons at business entities, such as a corporation or LLC
  • 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 (other than a First Bank employee) in a 401(k) or pension plan that First Bank sponsors or is a trustee or fiduciary of.
  • Individual interacting with our website who does not have a relationship with us.
If you are a California resident who has obtained a financial product or service for personal, family, or household purposes, please refer to our Consumer Privacy Notice.

CATEGORIES OF PERSONAL INFORMATION THAT WE COLLECT
We believe it is important that you know and understand the types of Personal Information we collect, the purposes for collection, and our practices relating to the disclosure and retention of your Personal Information. 

During the past twelve (12) months, we collected the following categories of Personal Information:
  • Identifiers, such as name, address, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, and passport number.
  • Personal Information (as defined by the California Customer Records Act), such as name, signature, driver’s license number, date of birth, telephone number, and account names and numbers.  
  • 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 payable.
  • Protected Classification Characteristics under California or Federal Law, such as your age, ethnicity, race, citizenship, source of income, or veteran status.
  • Internet/Other Electronic Network Activity Information, such as your IP address, device identifier, browser and operating system used, date and time you visit the Online Services, and web pages viewed. 
  • Geolocation Data, such as your location when you use an Online Service.
  • Audio, Electronic, Visual, or Similar Information, such as photographs of events, including attendees, security footage, images submitted to our social media sites, recordings of telephone calls, and electronic information, such as email correspondence and information entered on our Online Services.
  • Biometric Information, such as fingerprints, faceprints, and iris or retina scans.
  • Professional/Employment-Related Information, such as detail regarding your current and/or past employment, salary and professional credentials.
  • Education Information, such as your educational history, the names of educational institutions you attended and any degrees conferred.
  • Sensitive Personal Information. We collected the following types of Sensitive Personal Information:
    • Social Security, driver’s license, state identification card, or passport number;
    • Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing account access;
    • Precise geolocation;
    • Racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership;
    • The contents of an individual’s mail, email, and text messages, unless First Bank is the intended recipient;
    • Biometric information that is processed for the purpose of uniquely identifying an individual;
    • Personal information collected and analyzed concerning a consumer’s health or sexual orientation.
  • Profile Inferences. Inferences drawn from any of the categories of Personal Information collected to create a profile reflecting a person’s preferences, characteristics, predispositions, behavior, and attitudes.  For example, we collect information about your account usage and payment history to determine the likelihood of default, and we collect information about products and services you have obtained from us, along with other personal information to determine products and services that may be of interest to you and to market those products and services to you.
SOURCES OF PERSONAL INFORMATION
We collected Personal Information from the following sources:
  • You, or your authorized representative
  • Our employees
  • Our service providers
  • Employers
  • Educational institutions
  • Our marketing and advertising providers
  • Data brokers
  • Our website, social media pages, and other online services
  • Security cameras and photographs from bank events
  • Government entities
  • Other financial institutions
OUR PRACTICES REGARDING THE SALE AND SHARING OF PERSONAL INFORMATION
The CCPA considers any disclosure of Personal Information or Sensitive Personal Information to a third party for monetary or other valuable consideration to be a sale.  Information sharing is defined as the disclosure of Personal Information or Sensitive Personal Information to a third party for the purpose of Targeted Interest-Based Advertising.

Categories of Personal Information that We have Sold or Shared in the Past 12 Months
We do not sell or share Sensitive Personal Information.  We do not sell Personal Information; however, we do share the following categories of Personal Information with our marketing service providers and their advertising networks for the purpose of serving you Targeted Interest-Based Advertisements: Personal Identifiers, Personal Information, and Internet/Other Electronic Network Activity. For information on how you can opt-out of Targeted Interest-Based Advertisements, please refer to the section titled “Right to Opt Out of the Sale/Sharing of Your Personal Information.”  

Sale or Sharing of Personal Information of Persons under 16 Years of Age
We do not sell or knowingly share Personal Information or Sensitive Personal Information of persons under the age of sixteen.  As such, we do not have actual knowledge that we sold or shared Personal or Sensitive Personal Information for those under the age of sixteen within the past 12 months.

RECENT INFORMATION COLLECTION AND DISCLOSURE PRACTICES
We collect, use, and disclose your Personal Information and Sensitive Personal Information to manage your banking relationship, including determining your eligibility for products and services and processing transactions on your accounts. The categories of third parties who may receive your Personal Information and Sensitive Personal Information for business purposes are:
  • Service Providers – unaffiliated companies that assist us in performing our business operations by providing certain services or by processing data and/or transactions related to our bank operations or our relationship with you; fraud prevention and security; and those who assist us in managing our business and regulatory risk, such as our external auditors, insurance providers, and legal counsel.
  • Government Entities – our federal and state regulators, federal and state agencies, state and local law enforcement, and federal and state courts.
  • Authorized Parties – persons you have authorized in writing to receive your Personal Information and/or Sensitive Personal Information or act on your behalf, such as a designated contact, your authorized agent for CCPA requests, and a person to whom you have given a power of attorney.
Our service providers are required to maintain the confidentiality of your Personal Information and Sensitive Personal Information and are restricted from using or disclosing this information other than as needed to perform their contractual obligations with us or as otherwise allowed by the CCPA.  

In the past twelve months, we collected and disclosed the following categories of Personal Information to third parties for the business and commercial purposes specified below:

Personal Identifiers and Personal Information (as defined by the California Customer Records Act)  were collected and disclosed for the following business and commercial purposes:
  • To verify your identity and authenticate transactions you initiate
  • Fraud prevention and security
  • To perform services on your behalf, such as processing transactions related to your accounts
  • To evaluate your creditworthiness or eligibility for products and services
  • To contact you
  • To inform you of other products and services that we believe would be beneficial to you
  • Regulatory reporting
  • To comply with applicable laws and regulations
  • Risk management and mitigation, including audit, insurance, compliance, legal, and Investigation functions
Personal Identifiers and Personal Information (defined by the California Customer Records Act) were disclosed to the following categories of third parties:  Service Providers, Government Entities, and Authorized Parties.

Commercial Information was collected and disclosed for the following business and commercial purposes:
  • To perform reviews of your existing products and services
  • Fraud prevention and security
  • To evaluate your eligibility for bank products and services
  • To inform you of other products and services that we believe would be beneficial to you
  • Regulatory reporting
  • To comply with applicable laws and regulations
  • Risk management and mitigation, including audit, insurance, compliance, legal, and Investigation functions
Commercial Information was disclosed to the following categories of third parties:  Service Providers, Government Entities, and Authorized Parties.

Protected Classification Characteristics were collected and disclosed for the following business purposes:
  • To comply with applicable laws and regulations, including federal and state antidiscrimination laws
  • To provide reasonable accommodations due to a disability
  • Risk management and mitigation, including audit, insurance, compliance, legal, and investigation functions.
Protected Classification Characteristics were disclosed to the following categories of third parties:  Service Providers, Government Entities, and Authorized Parties.

Biometric Information was collected and disclosed for the following business purposes:
  • To verify your identity and authenticate transactions you initiated
  • Fraud prevention and security
  • Risk management and mitigation, including audit, insurance, compliance, legal, and investigation functions.
Biometric Information was disclosed to the following categories of third parties:  Service Providers and Government Entities.

Internet/Other Electronic Network Activity Information was collected and disclosed for the following business and commercial purposes:
  • To verify your identity and authenticate transactions you initiated
  • To process transactions and account maintenance functions
  • Fraud prevention and security
  • Analysis of your site usage to determine improvements to the site’s functionality
  • To serve relevant advertisements to you based on your browsing history on websites and other online channels
  • To market our products and services to you
  • Risk management and mitigation, including audit, insurance, compliance, legal, and investigation functions
Internet/Other Electronic Network Activity Information was disclosed to the following categories of third parties:  Service Providers, Advertising Networks, and Government Entities.

Geolocation Data was collected and disclosed for the following business purposes:
  • To direct you to nearby First Bank locations
  • Fraud prevention and security
Geolocation Data was disclosed to the following categories of third parties:  Service Providers and Government Entities.

Audio, Electronic, Visual, or Similar Information was collected and disclosed for the following business and commercial purposes:
  • Audio and visual information is collected for quality control monitoring, transaction verification, authentication, and security purposes
  • Visual information is collected for promotional purposes, such as photos publicizing a bank event
  • For fraud prevention, investigation, and security purposes
  • For risk management and mitigation, including audit, insurance, compliance, legal, and investigation functions.
Audio, Electronic, Visual, or Similar Information was disclosed to the following categories of third parties:  Service Providers and Government Entities.

Professional/Employment Information was collected and disclosed for the following business and commercial purposes:
  • Verification, credit underwriting, and transaction authentication purposes
  • Risk management and mitigation, including audit, insurance, compliance, legal, and investigation functions.
  • To inform you of other products and services that we believe would be beneficial to you
Professional/Employment Information was disclosed to the following categories of third parties:  Service Providers and Government entities

Education Information was collected and disclosed for the following business and commercial purposes:
  • Verification, credit underwriting, and transaction authentication purposes
  • Risk management and mitigation, including audit, insurance, compliance, legal, and investigation functions.
  • To inform you of other products and services that we believe would be beneficial to you
Education Information was disclosed to the following categories of third parties:  Service Providers and Government Entities

Sensitive Personal Information was collected and disclosed for the following business purposes:
  • To verify your identity and authenticate transactions you initiate
  • Fraud prevention and security
  • For risk management and mitigation, including audit, insurance, compliance, legal, and investigation functions

Sensitive Personal Information was disclosed to the following categories of third parties:  Service Providers, Government Entities, and Authorized Parties.

Profile Inferences were collected and disclosed for the following business and commercial purposes:

  • Credit underwriting
  • For risk management and mitigation, including audit, insurance, compliance, legal, and investigation functions
  • To serve relevant advertisements to you based on your browsing history on websites and other online channels
  • To inform you of other products and services that we believe would be beneficial to you
  • To enhance our marketing efforts

Profile Inferences were disclosed to the following categories of third parties:  Service Providers and Government Entities

OUR PRACTICES RELATING TO SENSITIVE PERSONAL INFORMATION

We only collect, use, or disclose Sensitive Personal Information as necessary to perform services or provide products reasonably expected by an average individual who requests the products or services, for fraud prevention and information security, to perform services such as maintaining and servicing accounts, to ensure the physical safety of our employees and clients, or as otherwise authorized by the CCPA and its implementing regulations.  We do not use or disclose Sensitive Personal Information for any purpose that enables an individual to exercise a right to limit our use or disclosure of Sensitive Personal Information under California law.  Should we change our practice, we will notify you and provide you with the right to limit.

RETENTION OF PERSONAL INFORMATION

The length of time that we retain each category of Personal Information depends on the following criteria: (1) the length of time we need the Personal Information in order to accomplish the purposes for which it is collected, used, or disclosed; (2) our corporate standards for record retention; (3) the length of time we are required to retain Personal Information to comply with applicable federal and state laws and regulations; and (4) whether the Personal Information is subject to a dispute, investigation, or legal hold.

YOUR CCPA REQUEST RIGHTS

The CCPA gives you the right to make the following requests pertaining to your Personal Information:

Request to Know what Personal Information We Have Collected
You have the right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, and the specific pieces of Personal Information we have collected about you.

Request to Delete Your Personal Information
You have the right to request that we delete Personal Information we have collected from you, subject to certain exceptions.  For example, we may deny your request if we need your Personal 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 allowed by the CCPA.

Request that We Correct Inaccurate Personal Information
You have the right to request that we correct inaccurate Personal Information that we maintain about you.  We may require you to submit documentation to substantiate your request if we believe our records are accurate and you did not produce documentation with your request.  We will accept, review, and consider any documentation you provide in connection with your request to correct, and will only use and maintain your documentation for the purpose of processing and responding to your request and to comply with CCPA recordkeeping requirements.  We may deny your request if we determine that the contested Personal Information is more likely than not accurate based on all of the information available to us.

HOW TO MAKE CCPA REQUESTS

You may make a Request to Know, Correct, or Delete by submitting the request using the Data Request Form, emailing your request to [email protected], or by calling the First Bank Service Center at 800-760-2265.

To protect your privacy and the security of your Personal Information, we will verify your identity prior to completing your request.  We do this by matching information you provide to information we have on file.  We may ask you to provide a valid government-issued photo identification, such as a driver’s license, as part of the verification process.  We may deny your request if we are unable to verify your identity.

Requests Submitted by Authorized Agents
You may authorize an individual or business to submit a Request to Know, Correct, or Delete 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 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 “How to Make CCPA Requests” paragraph, above.

OUR RESPONSE TO YOUR REQUESTS

We will provide you with confirmation of your request within ten (10) business days of the date the request is received.  We will generally respond to your request within forty-five (45) calendar days of the date we received the request.  In some cases, we may take up to another forty-five (45) calendar days to respond.  If this occurs, we will notify you before the end of the first forty-five (45) day period and provide you with the reason(s) why we need additional time to complete your request.

If you submit a Request to Delete or Request to Correct, when we respond we will tell you whether or not we were able to complete your request, and if not, the reason.  If we delete or correct your Personal Information, we will also notify any service providers that maintain the information and instruct them to delete or correct the information, as applicable. 

Please note that the CCPA prohibits us from disclosing certain Personal Information, such as Social Security or driver’s license numbers, account numbers, health or medical identification numbers, or confidential account information, such as a password or security questions and answers.  When we respond to a Request to Know pertaining to such information, we will provide you with a description of the Personal Information we collected.   

Your Personal Information may be subject to data privacy laws other than the CCPA.  For example, the Gramm-Leach-Bliley Act regulates the privacy of consumer financial information that is collected when an individual obtains a bank product or service for personal, family, or household purposes. If we receive a Request to Know, Correct, or Delete that involves Personal Information that is subject to another privacy law, we may deny part or all of your request relating to that information as it is exempt from the CCPA.  We will inform you of this in our response to your request.

OTHER CCPA RIGHTS

Right to Non-Discrimination for Exercising Your CCPA Rights.
You have the right not to be discriminated against for exercising your privacy rights under the CCPA.  First Bank will not discriminate against you for exercising any of your CCPA rights.

Right to Opt Out of the Sale/Sharing of Your Personal Information
The CCPA gives you the right to opt out of the sale and sharing of your Personal Information and Sensitive Personal Information.  First Bank does not sell Personal Information or Sensitive Personal Information or share Sensitive Personal Information; however, we do share certain Personal Identifiers and Internet/Other Electronic Network Activity information collected by Tracking Technologies to serve you with Targeted Interest-Based Advertising. You have the right to opt-out of Targeted Interest-Based Advertising and may do so by either (1) implementing an opt-out preference signal that complies with California law, such as the Global Privacy Control, on a supported web browser or browser extension, or (2) selecting your cookie preferences in the Preference Center settings menu. If you implement the Global Privacy Control, or other opt-out preference signal that meets California legal requirements, the signal will be read when you first interact with our Website and you will immediately be opted out of sharing for Targeted Interest-Based Advertising.  We process the Global Privacy Control, and other approved opt-out preference signals in a frictionless manner, which means that we will not (1) charge a fee or require you to provide any valuable consideration, (2) change your experience with any products or services you have with us, or (3) display a pop-up, text, or other online content in response to the Global Privacy Control, other than a confirmation that we have recognized the Global Privacy Control and you have been opted out of information sharing for Targeted Interest-Based Advertising. Please note that you will need to manage your cookie settings for each device and browser that you use to access the Online Services.  

Right to Limit Use and Disclosure of Sensitive Personal Information
The CCPA gives you the right to request that we limit our use and disclosure of Sensitive Personal Information to the purposes detailed in the CCPA and its implementing regulations. For more detail, please refer to the section titled “Our Practices Relating to Sensitive Personal Information”.  We limit our use and disclosure of your Sensitive Personal Information to the allowed purposes set forth in the CCPA and its implementing regulations. 

UPDATES TO THIS PRIVACY NOTICE

This Privacy Notice was last updated on July 9, 2024. We reserve the right to make changes to both our Personal Information practices and this Privacy Notice at any time.  Please return to this site frequently to determine if changes have been made.  If we make significant changes to this Notice, we will place a message on the first.bank homepage informing you of the change.

FOR MORE INFORMATION

If you have any questions about this Privacy Notice or First Bank’s privacy practices, or if you need to access this Privacy Notice in an alternative format due to having a disability, please contact us at [email protected] or 800-760-2265.