COMMUNITY BANK INNOVATION CONSORTIUM PRIVACY POLICY
Last updated December 07, 2022
This Privacy Policy for CBIC, LLC, doing business as Community Bank Innovation Consortium ("CBIC," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use any of our On-line Services (as defined in our Terms of Use) or when you engage with us in person, by telephone, by mail or otherwise.
If you do not agree with our policies and practices, please do not use our On-line Services. If you still have any questions or concerns after reading through this Policy and our Terms of Use, please feel free to contact us at the contact details provided at the end of this Privacy Policy.
We reserves the right to change this Privacy Policy at any time in our sole discretion. Each time you access or use of any the On-line Services, such access or use shall be subject to the Privacy Policy posted on this website at the time of such access or use. Any changes to this Privacy Policy will be posted on this website. You agree that no other notification of changes to this Privacy Policy is required and that all changes will apply to your access or use of the On-line Services on and after such changes are posted. If you do not agree to the changed terms, then you must immediately stop using the On-line Services and request that we close any account you may have created on the On-line Services.
1. What Information Do We Collect?
Personal information You Give to Us. We collect personal information that you voluntarily provide to us when you register for any On-line Services, express an interest in obtaining information about us or our services, when you participate in activities on the On-line Services, or otherwise when you contact us. You may choose whether to provide certain information, but you may not be able to utilize all aspects of the On- line Services if you choose not to provide certain information.
Types of Personal Information We Collect. The personal information that we collect depends on which of the On-line Services you interact with, the choices you make, and the features you use. The personal information we collect may include some or all of the following:
• names
• phone numbers
• email addresses
• mailing addresses
• job titles
• usernames
• passwords
• contact preferences
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information Automatically Collected. We may automatically collect certain information when you visit, use, or navigate the On-line Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our On-line Services, and other technicalinformation. This information is primarily needed to maintain the security and operation of our On-line Services, and for our internal analytics and reporting purposes.
The information we or our service providers automatically collect may include:
Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers or service providers may automatically collect when you access or use our On- line Services and which may be recorded in log files. Depending on how you interact with us, the log data may include your IP address, device information, browser type, and settings and information about your activity in the On-line Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
Device Data. We may collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Location Data. We may collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services.
Cookies. We may use cookies, pixels, and other technologies (collectively, "cookies") to recognize your browser or device, learn more about your interests, and provide you with certain features of our On-line Services and for additional purposes, including:
Recognizing you when you sign-in to use our On-line Services (if sign-in is required).
• Keeping track of your specified preferences.
• Conducting research and diagnostics to improve our content, products, and services.
• Preventing fraudulent activity.
• Improving security.
• Delivering content relevant to your interests on our On-line Services.
• Measuring and analyzing the performance of our On-line Services.
Third parties such as search engines, providers of measurement and analytics services, and social media networks may also use the cookies. Third parties use cookies in the process of delivering content relevant to your interests, to measure the effectiveness of our On-line Services, and to perform services on behalf of us.
You can manage browser cookies through your browser settings. The 'Help' feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to block cookies, and when cookies will expire. If you block all cookies on your browser, neither we nor third parties will transfer cookies to your browser. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some features and services may not work.
Information Collected From Other SourcesIn order to enhance our ability to provide relevant information regarding our services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, data providers, social media platforms, your website, your marketing and advertising materials, and from other third parties. This information may include mailing addresses, job titles, email addresses, phone numbers, Internet Protocol (IP) addresses, social media profiles, social media URLs for purposes of providing you with relevant marketing materials and event promotion. If you interact with us on a social media platform using your social media account (e.g., Facebook or Twitter), we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account's privacy settings.
2. For What Purposes Do We Use Your Personal Information?
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to an account on one or more of our On-line Services, as well as keep your account in working order.
To deliver and facilitate delivery of services to the user, provide support or respond to inquiries. We may use your information to provide you with the requested service or information, provide you with support in using our On-line Services or to respond to your inquiries.
To send information to you. We may process your information to send you details about our services, changes to our terms and policies, and other similar information.
To protect from harm or to comply with legal requirements. We may process your information when necessary to prevent harm to any person or entity or to comply with any applicable legal requirements.
3. Do We Share Your Information?
Information about our clients is an important part of our business, and we are not in the business of selling our client’s personal information to others. We may need to share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). We may obtain and store on your device ("cache") your location. You may revoke your consent anytime by contacting us at the contact details provided at the end of this Privacy Policy.
Third Party Service Providers. We may employ other companies and individuals to perform functions on our behalf. Examples include analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing payments, transmitting content, creating, modifying or hosting our On-line Services. These third-party service providers have access to personal information needed to perform their functions, but may not use it for other purposes.
Affiliates and Business Partners. We may share your information with our affiliates or business partners in connection with providing services to you, responding to your inquiries or providing you with marketing materials or information.
To protect from harm or to comply with legal requirements. As noted above, we may share your information when necessary to prevent harm to any person or entity or to comply with any applicable legal requirements.Information shared with third parties will be subject to the privacy policies of such third parties.
4. How Secure Is My Information?
We have implemented commercially reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we use reasonable commercial efforts to protect your personal information, transmission of personal information to and from our On-line Services is at your own risk. You should only access the On-line Services within a secure environment.
5. Are Minors Allowed to Use the On-line Services?
We offer services to commercial banks, savings and loans and other commercial lenders and do not knowingly solicit data from or market to children under 18 years of age. By using the On-line Services, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will, as applicable, deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at the contact details set forth at the end of this Privacy Policy.
6. Opting out of marketing and promotional communications.
You can unsubscribe from our marketing and promotional communications at any time by contacting us using the contact details provided at the end of this Privacy Policy. You will then be removed from our marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
7. Account Information.
If you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact details at the end of this Privacy Policy. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
8. Additional Privacy Rights?
Some jurisdictions (e.g, the EU, Canada and the State of California), provide you with certain rights under applicable data protection or privacy laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request correction or deletion of your personal information; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details set forth at the end of this Privacy Policy. We will consider and act upon any request in accordance with applicable data protection and privacy laws.
9. California Residents’ Privacy Rights.
Residents of the State of California have additional rights under the California Consumer Privacy Act, as amended from time to time (the “CCPA”). Certain other jurisdictions have adopted similar data protection and privacy laws or are in the process of doing so. We offer our services to commercial banks, savings and loans and other commercial lending institutions only within the United States and no On-line Services or other services are intended for residents of any jurisdiction outside the Unites States.
California Civil Code Section 1798.83, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact details provided at the end of this Privacy Policy.
CCPA Privacy Notice
What categories of personal information do we collect?
In the past twelve (12) months, we have collected the categories of personal information described in Section 1, “What Information Do We Collect?” We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of responding to your inquiries, discussing doing business with you or providing services to you.
Will your information be shared with anyone else?
Our policies with respect to sharing your personal information are set forth in Section 3, “Do We Share Your Information?”We have not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.
Right to Request Access or Deletion of Personal Information.
As a California resident, you have the right under the CCPA to request information about the collection of your personal information by us, or access to or deletion of your personal information. Upon receiving your request, we may need to verify your identity to determine you are the same person about whom we have the information in our system. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.
Other privacy rights
• You may object to the processing of your personal information.
• You may request correction of your personal data if it is incorrect or no longer relevant, or ask torestrict the processing of the information.
• You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
• You may request to opt out from future selling of your personal information to third parties. Uponreceiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
Right to Non-Discrimination for the Exercise of Rights Under the CCPA. We will not discriminate against any California resident for exercising any rights under the CCPA.
To Exercise Rights Under the CCPA or For Questions About This Privacy Policy. To exercise any rights under the CCPA as a resident of the State of California, or if you have any questions regarding our Privacy Policy, you may contact us at the contact details set forth at the end of this Privacy Policy.
10. How Can You Contact Us?
If you have questions or comments about this notice, you may contact our Data Protection Officer, Mike Dektas, at:
CBIC, LLC
4770 Duke Drive, Suite 100 Mason, OH 45040
Attention: Mike Dektas
Email: mikedektas@cbic.zone
Telephone: 1-513-266-3590
4859-0434-6690.1
