Overview
The Bank understands that our customers are concerned about their personal information. Because of this, our customers' privacy has always been, and always will be, one of our most important concerns. We subscribe fully in this Privacy Policy and we strive to protect customers' information according to not only federal and state laws, but even more importantly, according to our own strict standards. If you have any questions about this Privacy Policy issues regarding customer privacy, please consult with the Bank's Compliance Officer.
Our Personal Privacy
Technology and new marketing practices have increased the amount of customer information collected and shared in today's marketplace. The Bank is sensitive to the importance of these concerns. We want to serve consumers as effectively and conveniently as possible, and such service involves making use of technology and customer information. But we also want our customers to be confident that their relationship with the Bank is treated with the appropriate confidentiality. We therefore commit to customers that we will take reasonable steps to protect the privacy of the information shared with us.
To understand the public's sentiment, financial institutions can merely peer outside the banking world to appreciate these concerns. We should first realize that privacy is something we all desire to safeguard our innermost feelings and thoughts. Our privacy means our identity. Our private hopes, fears, and wishes are things we own. We believe these things should not be shared, unless we inititate the sharing.
Further, the march of technology increasingly challenges the public in containing information that it holds most dear, such as finances and health records. Technology has advanced the ability of businesses to collect, store, analyze, and disseminate more and more customer data than ever before. The widespread use of the Internet by business has expanded the delivery methods of products and services for benefit of both customers and business.
The Internet has also, however, created another avenue for those who wish to exploit customer data in the name of commerce. For instance, the public is understandably afraid at the prospect of a marketer's surreptitious collection of personal information, then making assumptions of character on an individual's buying behavior. Consumers then fear the possibility of relentless marketing campaigns of unwanted or embarrassing products, targeting their households using the phone, mail, or e-mail. It is also felt that the loss of identity or privacy will likely increase in the future in spite of all attempts to stop it.
Information Collection
Information about consumers is accumulated from a variety of sources. Some information is provided to the Bank directly by customers themselves. Other data is developed by the Bank as a function of providing a product or service to a customer. Still other information is obtained from outside sources. We will limit the use and collection of information about our customers to that which is necessary to adminster our business, provide superior service, and offer opportunities that we think will be of interest to customers. This means that we will use information to help us identify and mitigate potential risks or loss to the Bank. We will use information to help identify additional products or services that we believe customers might want to know about. We will use this information only in accordance with the principles set out in this policy.
Information Accuracy
Equally important, we will strive to ensure that the information concerning our customers is accurate. Customers are protected by the Fair Credit Reporting Act, which requires us to notify customers whenever consumer reports from third parties have been used to solicit business from them. We may also use such reports only for the purpose of prescreening business prospects when a customer or potential customer has authorized a consumer reporting agency to furnish us a report, or when making a customer or potential customer a firm offer of credit, insurance, or employment. Consumers are entitled to request credit reporting agencies to remove their names from lists supplied to us.
Sharing Information within the Bank
We are permitted to share our entire organization information concerning a customer's account history and experiences with the Bank; but we cannot share nonexperience information with any affiliates the Bank now has or may have in the future (unless there is clear and conspicuous disclosure to the customer that information may be shared among affiliate entities and, secondly, the consumer must be given the opportunity, before the information has been communicated, to direct that the information not be communicated among entities). In some situations, a person might disclose or authorize the disclosure of medical information as part of an application for a specific product such as credit life insurance. We will share any such medical information only wth those who need to know this information in order to process the application to be used elsewhere within the organization for any other purpose.
Sharing Information with Oursources, 3rd Party Participants, and Vendors
Sometimes specific customer information has to be shared with companies we hire to provide operational support, companies that participate with us in supplying products and services to customers, and companies that promote products and services on our behalf. Except in unusual situations (where they might be governed by federal or state laws to the contrary), these companies are not permitted to use our customer information for purposes other than the provision of the services intended. We will share customer information with these companies only if they agree to treat it confidentially.
Occasionally, the Bank makes a decision to sell a particular line of business (for example, mortgage servicing rights). Ususally, an integral part of that business is its customer database. The Bank reserves the right, in these unusual circumstances, to transfer ownership of such customer databases to the purchaser.
Sharing Information with Consumer Reporting Agencies and Other Companies
We will exchange information about our customers with reputable information reporting agencies and financial institutions in accordance with standard banking industry practice, so we can verify the existence and condition of customer's accounts. We do not share specific personal customer information with independent companies for any other purpose without the customer's consent.
Sharing Information with the Government
The Bank Secrecy Act, Internal Revenue Codes, the Right to Financial Privacy Act, the Welfare Reform Act, and various other laws and regulations require us or our contractors, under certain circumstance, to provide certain customer information to government agencies. We will only disclose customer information to the government or others when we are required to do so by such laws, regulations, or by court order. State and federal laws impose certain mandatory disclosures or customer information by financial institutions. We must comply with laws that require mandatory production or disclosure.
Sharing Information with 3rd Party Litigants
If a customer is involved in a legal proceeding, both federal and state law provide parties to the litigation the right to compel the production of records and information from banks and other third party record keepers in certain situations. We will only disclose customer information to third party litigants when we are required to do so by lawful judicial process or by court order.
Removal from Lists
Consumers may request to be excluded from any telephone or other solicitation by the Bank and third party providers working with the Bank. Persons who do not wish to receive such telephone calls may inform the person calling them accordingly and they will be placed on a list of persons we may not solicit by phone. While this may mean consumers might not receive product information of interest to them, we will also respect anyone's wish not to receive promotional mail solicitations (ie., mailings independent of routine statement and other customer service mailings) if so requested.
"Phishing"
Phishing is the practice of sending fraudulent e-mail messages to addresses requesting them to supply confidential information.
Citizens Bank & Trust, Inc. will not solicit confidential or sensitive information from our customers via e-mail. When we communicate with our customers via e-mail, in other than a mass-mailing advertising type communication intended solely to inform our customers of products, services, or regulatory changes, we will personalize the e-mails using their names. (June '04)
Privacy and the Internet
We understand that customers may have special privacy concerns regarding the Bank's use of the Internet. In particular, customers might be anxious to ensure that their information is secure, that such information is also covered by our Privacy Policy. Citizens Bank & Trust, Inc. is equally concerned about privacy in the Internet world and is committed to its protection.
Citizens Bank & Trust, Inc. is committed to protecting user privacy and our website is maintained consistently with banking industry privacy principles. We do not accept electronic applications, nor do we provide on-line transactions, from our website at this time. You can be assured that you can visit our website without identifying yourself or giving us any information that identifies you personally unless you specifically choose to provide such information to us. Our website does not collect personal identifying information about site users, except for information knowingly provided by the user who posts e-mail messages or inquiries. (Since general e-mail is not encrypted, we recommend that you not send confidential information, such as social security or account numbers, via un-encrypted e-mail messages.). Any on-line banking transaction or application features that we add to our website in the future will employ encryption; in other words, the transmission will be scrambled en route and decoded when it reaches Citizens Bank & Trust, Inc.
Also, our website is directed at customers and potential customers that are adults. However, children may access our website and provide information in the ways previously explained in this policy statement. They may request information concerning certain products and services. Should children access our website, we are confident that parents will not judge any of the information provided as objectionable for viewing by their children. Parents can avail themselves of various software packages that are available to prevent their children from accessing websites that they deem to be inappropriate.
Lastly, we may provide external links to websites that contain information on topics that may be useful to users of our website. Although we provide these external links as a benefit to our customers, it does not mean that we endorse the use or content of these websites.
