This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS (the “Notice”) will be effective as of January 1, 2020 and supplements the information contained in the Privacy Statement of BankMobile, a Division of Customers Bank, Member FDIC (“we” or “us”) and applies solely to visitors, contacts, accountholders, and others who reside in the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other applicable California privacy laws. Any terms defined in the CCPA have the same meaning when used in this Notice.
As a financial institution we are obligated to comply with the federal Gramm-Leach-Bliley Act (Public Law 106-02) and its implementing regulations (collectively “GLBA”), which govern the collection, use, protection, and disclosure of personal financial information. This includes all nonpublic personal information that we may collect from you in connection with obtaining a financial product or service from us. Personal information that is collected, processed, sold, or disclosed pursuant to the GLBA or the California Financial Information Privacy Act (Division 1.4, commencing with Section 4050 of the Financial Code) is not included within the scope of this Notice. For more details on how we treat this information, as well as a summary of your rights with respect to this information, please see our privacy notice here.
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).
“Personal information” does not include:
We have collected the following categories of personal information* (as defined above) from consumers within the last twelve (12) months:
*Please note that the categories of personal information we collect about consumers will vary based on our relationship or interaction with those individuals.
We obtain the categories of personal information listed above from the following categories of sources:
We may use or disclose the personal information we collect for one or more of the following business purposes:
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
We disclose your personal information for a business purpose to the following categories of third parties:
We do not and will not sell personal information. In the preceding twelve (12) months, we have not sold any personal information.
The CCPA provides consumers who are California residents with specific rights regarding their personal information. This section describes your CCPA rights as a California resident and explains how to exercise those rights.
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you (as applicable):
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
On or after January 1, 2020, to exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
Your verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. To accomplish this, we may need to contact you to provide additional information to us to verify your identity.
Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response through your account with us. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding receipt of the verifiable consumer request. 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 without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request. However, if your request is excessive, repetitive, or manifestly unfounded, in particular because of its repetitive character, we may refuse to act on the request and notify you of the reason for refusing the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, or your choices and rights regarding such use, please do not hesitate to contact us at:
Postal Address: BankMobile, 115 Munson St, New Haven, CT 06511
Effective Date: 1/1/2020