Effective January 1, 2019
By visiting or using any of our online services or interacting with one of our advertisements displayed through third-party online services, you accept and consent to the data collection, use and sharing practices described in this Policy. If you do not accept and consent to the data collection, use and sharing practices described in this Policy, please do not use our online services.
When you visit or use our online services, we may collect information that can be directly identified with you, which we refer to in this Policy as “personal information.” Any information that we collect through our online services, or those offered by third parties, which does not by itself reveal your specific identity or relate directly to you, such as aggregated, de-identified or demographic statistical data, is “non-personal information.”
We may collect personal information directly from you through our online services, such as online forms, data entry fields, cookies or mobile applications. Additional personal information from or about you may also be collected and used in other ways, including your communications with us or through reference to information from third party sources. For example:
If you have a financial product or service with us, we will use any personal information that we collect from or about you in accordance with our privacy notice. (What does Sunwest Bank do with your personal information?)
When you visit or use our online services, or those offered by third parties, we and third parties may collect non-personal information from your computer or mobile device. These third parties include non-affiliated third parties that provide services on our behalf, including our non-affiliated advertising partners (collectively, our “service providers”). For example:
When you use one of our mobile applications, we and our service providers may collect, use and share personal and non-personal information as described in the sections above. We and our service providers may also collect, use and share other non-personal information from your mobile device for various purposes, such as to enable application functionality.
To enable locator tools within our mobile applications, we and our service providers collect, use and share the location of your mobile device (GPS coordinates), unique device identifier, operating system and settings. When you use our mobile applications, we or our service providers collect and use this information to enable you to locate our retail branches and ATMs. If you have a financial product or service with us, we associate this information with an internal identifier that identifies you as our customer. When you request directions through one of these mobile applications, we or our service providers may share this information with third party map applications on your mobile device.
How We Use the Information We Collect
All financial companies need to share customer information for their everyday business purposes. We may share personal information that we collect about you, and non-personal information that we collect from your computer(s) and mobile device(s), including information relating to your web-browsing activities and other online behavior, for such purposes with:
• Other individuals or entities, when we believe that disclosure is necessary to report suspicious activities, prevent physical harm, financial loss, or violations of our agreements and policies.
• Regulators and other organizations or individuals who are legally entitled to receive such information.
If you have a financial product or service with us, we will share any personal information that we collect from or about you in accordance with the notice. (What does Sunwest Bank do with your personal information?)
Cookies, Tags and Other Tracking Technologies
We and our service providers may collect non-personal information relating to your visit or use of our online services through various means, such as cookies and tags.
A cookie is a small text file containing information (data) that is created and downloaded to your computer or mobile device when you visit a website. Cookies can be helpful in several ways, including allowing a website to recognize your device when you visit, keep track of the pages you visit, and remember your preference choices.
We and our service providers use three common types of cookies: session cookies, persistent cookies and flash cookies:
• Session cookies expire at the end of your browser session and are not written onto your hard drive.
Session cookies are used on our websites to help determine, among other things:
• What pages you visit and actions you take.
Session cookies are also used on our websites as a type of digital signature to identify your current session to our website servers. On secure pages on our websites, session cookies may also be used temporarily to store your account number in order to identify multiple user IDs associated with one account number. Cookies containing account numbers are protected through encryption and are used to enable you to load a new secure page on our websites during the same session without having to enter your password.
Our websites use persistent cookies to collect information about you, your computer or mobile device and/or your web browser. For example:
• When you visit one of our websites, we may ask you to select your state of residence. We may store this information in persistent cookies on your computer or mobile device to ensure that appropriate regional information and rates are displayed when you visit the website in the future.
Persistent cookies (and visitor identifiers and customer identifiers contained in the cookies) may be used on our websites to:
• Remember your language preferences and city, state and country selection to enable optimization of our websites and a more personalized experience.
Both session and persistent cookies are used on our websites to:
• Aid in identifying and addressing application support issues and to aid in fraud prevention and investigations.
You may be able to control your acceptance of cookies and similar technologies on a website, and most devices and browsers offer their own privacy settings for cookies. You will need to manage your cookie settings for each device and browser you use. If you do not accept cookies, you may experience some inconvenience in your use of some sites and online products. For example, a website may not be able to recognize your device and you may need to answer challenge questions or provide additional information each time you log on. Deleting cookies does not delete Flash objects. You can learn more about Flash objects including how to control and disable them on the Adobe website.
Tags and Other Tracking Technologies
We and our service providers may also use small images encoded with tags (known as tags or web beacons) and other tracking technologies through our online services for various purposes, including the following:
• To deliver cookies, to count users who have visited certain pages on our websites, and to help us compile aggregated usage statistics to monitor usage patterns and monitor inbound traffic to our websites.
Industry standards are currently evolving and we may not separately respond to or take any action with respect to “do not track” signals transmitted by web browsers or similar mechanisms.
Third-Party Sites and Services
Our online services may contain links to third-party websites and other online services, which are not governed by this Policy. As such, we encourage you to learn about the privacy and security practices of those third parties. We are not responsible for the privacy or security of such websites and other online services, nor the online collection, use or sharing of personal or non-personal information by third parties.
Accuracy of Your Information
The accuracy of your account and other personal information is important. If you have a financial product or service with us and you find that any personal information we have or have reported to another party does not appear to be accurate, please contact us as follows:
Please include your account number, if available.
Protecting Children’s Online Privacy
This website is not directed to children. We do not market to children, nor do we knowingly collect or retain personally identifiable information from children.
We do not intentionally collect any information from anyone under the age of 13. We request that such individuals do not provide us with any information. If a parent or guardian becomes aware that their child has provided us with information without consent, promptly contact us and we will delete such information from our files.
The Children’s Online Privacy Protection Act (“COPPA”) protects children under the age of 13 from the online collection of personal information. For more information about the COPPA, visit the Federal Trade Commission (FTC) website at www.ftc.gov.
Visitors Residing Outside the United States
If you visit or use our online services, your personal and non-personal information may be collected, stored, used and processed in and transferred to, from and within the United States. In such instances, applicable U.S. federal and state laws shall govern. If you are a non-U.S. resident, such laws may not provide the same level of protection as the laws of the country of your residence.
We reserve the right to update this Policy from time to time to comply with applicable laws and to reflect changes in our online services. For this reason, we encourage you to periodically review this Policy. If we make changes to this Policy, we will revise the “Effective/Revised” date shown at the top of the Policy and post the revised Policy on www.sunwestbank.com and through our other online services. The changes will become effective when we post the revised Policy. Your visit or use of any of our websites or other online services following such posting means that you accept the revised Policy.