Online Privacy Notice

Independence Bank Online Privacy Notice

Last updated January 4, 2021

Your privacy is important to us. This Online Privacy Notice (“Notice”) describes how Independence Bank manages personal information about you when you interact with us online through our websites, mobile applications, and social sites (“Sites and Mobile Apps”).

If you have a financial product or service with us, we will use and share any information that we collect from or about you in accordance with our Privacy Policy, which offers you certain choices with respect to the use and sharing of your personal information.

This notice explains

• How we collect personal information when you visit, use, or interact with us online, and through our ads displayed through online services operated by us or non-affiliated third parties
• How we may use or share personal information collected to deliver products and services to you and for advertising purposes

By using the Sites and Mobile Apps, you agree to the terms and conditions of this Notice.

Updates to this Notice

This Notice is subject to change. Please review it periodically. If we make changes to this Notice, we will revise the Last updated date on this page.

Our Online Privacy Practices

We are committed to transparency about your personal information. We ask for your consent when required, otherwise by using our Site and Mobile Apps, you consent to the collection, use and sharing of your personal information subject to and consistent with applicable laws and other notices you may have received based on your relationship with us.

Linking to other sites 

We may provide links to non-affiliated third-party sites, such as credit bureaus, service providers or merchants. If you follow links to sites not affiliated with or controlled by Independence Bank, you should review their privacy and security policies and other terms and conditions, as they may be different from those of our Sites and Mobile Apps. Independence Bank does not guarantee and is not responsible for the privacy or security of these sites, including the accuracy, completeness, or reliability of their information.

Protecting your personal information 

To protect personal information from unauthorized access and use, we use security measures that comply with applicable federal and state laws. These measures may include device safeguards and secured files and buildings as well as oversight of our third-party service providers to ensure personal information remains confidential and secure. In the event of a data breach, we provide timely notification, in accordance with applicable laws. We also recognize the importance of protecting privacy where children are involved. Our Sites and Mobile Apps are not directed to individuals under the age of 13, and we request that these individuals do not provide personal information through our Sites and Mobile Apps. We do not knowingly collect personal information from children under 13.

Making sure personal information is accurate 

Keeping your personal information accurate and up to date is very important. If your personal information is incomplete, inaccurate, or not current, please use the Contact Us option on our Sites and Mobile Apps or call or write to us at the telephone numbers or appropriate address for changes listed on your account statements, records, online or other account materials. You can also speak to a customer representative at any one of our locations.

Personal Information We Collect

How do we collect personal information online?

We collect personal information about you through your computer, smartphone, tablet, or other mobile device using cookies and similar tracking technologies as well as personal information you provide when you visit or use our Sites and Mobile Apps, for example when you:

• Apply for or open a new account;
• Register for a new product or service, or request information about a product or service; or,
• Complete a survey, contest or sweepstakes or other promotion.

We may use service providers and vendors to process personal information for business purposes on our behalf. Service providers and vendors are contractually obligated to comply with our policies to protect information we share with them or they collect on our behalf.

The personal information we collect is limited to what is required to provide our products or services and to support legal and risk requirements. For additional information, please review the How do we use your personal information section of this Notice.

Types of personal information we collect online 

The type of personal information we collect from and about you online will depend on how you interact with us and may include:

• Contact Information such as name, mailing address, email address, telephone, and mobile number(s).
• Account Application information such as credit and income information.
• Identifiers such as Social Security number, account number(s), driver’s license number (or comparable) or other information that identifies you for ordinary business purposes.
• Access Authorization such as username, alias, PIN and Passcode and security questions and answers.
• Information from your computer, smartphone, tablet, or other mobile device, such as:
  
  • Unique device identifiers (for example Media Access Control (MAC) and Internet Protocol (IP) addresses).
  • Browser type, version, language, and display/screen settings. Information about how you use and interact with our Sites and Mobile Apps (for example page visited or links clicked).
  • Responses to advertisements on the Sites and Mobile Apps where we advertise.
  • Log information such as your search and voice to text queries in the mobile app.
  • Search engine referrals.
  • Geo-location information with consent, for example ATM or financial center location, debit/credit card fraud prevention.
  • Social media preference.

How We Use and Share Personal Information

How do we use your personal information?

Personal information collected from and about you online, described in this Notice, may be used for many purposes such as:

• Delivering products and services to you by verifying your identity (for example when you access your account information); processing applications for products or services such as to prequalify for a mortgage, apply for a credit card, or to open a retirement account, investment account or other financial product; processing transactions; finding nearby ATMs, financial centers, and other specialized location-based services near your location.
• Personalizing your digital and mobile experience by enhancing overall Sites and Mobile Apps organization and design and analyze data to create relevant alerts, products, or services.
• Providing advertising on our Sites and Mobile Apps as well as non-affiliated third-party sites and through off-line channels like direct marketing (for example email, mail, and phone).
• Detecting and preventing fraud, identify theft and other risks to you or Independence Bank.
• Performing analytics concerning your use of our online services, including your responses to our emails and the pages and advertisements you view.
• Complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations, and our policies.
• Allowing you to use features within our Sites and Mobile Apps when you grant us access to personal information from your device such as contact lists, or geo-location when you request certain services that requires such access, for example locating an ATM or fraud prevention on a debit or credit card.

We retain personal information for a period as required by laws and regulations and the necessary business purpose. We securely delete personal information as soon as legally permitted.

With whom do we share your personal information?

We may share the personal information we collect from and about you online described in this Notice (and subject to other legal restrictions and notices you may have received depending on your relationship with us) with:

• Service Providers, Vendors and Third-Party Providers who have contracts with Independence Bank
• Government Agencies as required by laws and regulations

Aggregated / De-identified information

Collected personal information may be aggregated and/or de-identified (we remove any details that identify you personally). We may share this aggregated and/or de-identified information with service providers, vendors, and third-party providers to help deliver products, services and content that are better tailored to the users of our online services and for our own business purposes where permissible under applicable laws and regulations.

Understanding Cookies, Web Beacons and Other Tracking Technologies

We, or our service providers, and other companies we work with may deploy and use cookies, web beacons, local shared objects, and other tracking technologies for various purposes, such as fraud prevention and monitoring our advertising and marketing campaign performance. Some of these tracking tools may detect characteristics or settings of the specific device you use to access our online services.

• “Cookies” are small amounts of data a website can send to a visitor’s web browser. They are often stored on the device you are using to help track your areas of interest. Cookies may also enable us or our service providers and other companies we work with to relate your use of our online services over time to customize your experience. Most web browsers allow you to adjust your browser settings to decline or delete cookies but doing so may degrade your experience with our online services.
• Clear GIFs, pixel tags or web beacons—which are typically one-pixel, transparent images located on a webpage or in an email or other message—or similar technologies may be used on our sites and in some of our digital communications (such as email or other marketing messages). They may also be used when you are served advertisements, or you otherwise interact with advertisements outside of our online services. These are principally used to help recognize users, assess traffic patterns, and measure site or campaign engagement.
• Local Shared Objects, sometimes referred to as “flash cookies” may be stored on your hard drive using a media player or other software installed on your device. Local Shared Objects are like cookies in terms of their operation but may not be managed in your browser in the same way.
• Some Mobile Apps periodically collect, transmit, and use geolocation information to enable features that prevent fraudulent card use and send alerts, but only if the End User expressly authorizes collection of such information. Geolocation information can be monitored on a continuous basis in the background only while the Solution is being used or not at all, depending on the End User’s selection. End Users can change their location permissions at any time in their device settings.

Online Advertising

In our online advertising endeavors, Independence Bank may use Google Analytics, Google AdWords, the Google Display Network, and other third-party sites which place cookies on a browser across the Independence Bank website. This cookie placement helps us increase the website’s general effectiveness for visitors. This practice is known as remarketing and is a tool that Google offers to businesses. If you would like to know more about this advertising or to find out how to opt-out of receiving advertising like this from Google, you can learn more here.

Additional Information

Aggregation Services

Some companies may offer aggregation websites and services that allow you to consolidate your account information from different sources (such as your accounts with us or with other financial institutions) so that you can view it in one location or perform actions related to your accounts using their services (a “Provider”). To do this, a Provider may request you to authorize access to your Independence Bank accounts by providing your Independence Bank username and passcode or by providing your information-sharing consent directly to Independence Bank through your Online Banking account.

• The Provider may access, on your behalf, information about yourself, your Independence Bank relationship, and your accounts at Independence Bank.
• You should use caution and ensure that the Provider has appropriate policies and practices to protect the privacy and security of any personal information you provide or to which they are gaining access.
• Use of your personal information by the Provider is governed by your agreement with them, not by Independence Bank.
• We are not responsible for the use or disclosure of any personal information accessed by any company or person to whom you provide your username and passcode.
• If you share your Independence Bank username and passcode or other information about your accounts with others, we will consider that you have authorized any transaction or action initiated by using the access information you provide.
• If you decide to revoke the authority you have given to a Provider, we strongly recommend that you change your Independence Bank passcode to ensure that the Provider cannot continue to access your account.
• You may revoke your consent for certain Providers through the Security Center within Independence Bank Online Banking.

Social Media

Independence Bank engages with customers on social media platforms such as Facebook^® and Instagram^®.

Any content you post on official Independence Bank managed social media pages, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms, is subject to the Terms of Use and Privacy Policies of those respective platforms.

• When interacting with official Independence Bank social media pages, Independence Bank’s privacy notices, Social Media User Terms and Community Guidelines may apply.
• Please review the privacy policy for the specific social media service you are using to better understand your rights and obligations regarding such content.

We may allow certain non-affiliated third-party widgets (for example social share buttons) on our sites that enable users to easily share information on another platform, such as a social media platform. The non-affiliated third parties that own these widgets may have access to information about your browsing on pages of our Sites and Mobile Apps where these widgets are placed.