Privacy Policy

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 CRBT, 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. CRBT 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 a banking center, your Financial Advisor or account representative.

How do we collect personal information online?

We collect personal information about you through your computer, smartphone, tablet or other mobile device by the use of cookies and similar tracking technologies (see our Cookies and Tracking Technologies Guide for details) as well as personal information you provide when you visit or use our Sites and Mobile Apps, for example when you:

• 1. Apply for a new account;
• 2. Register for a new product or service, or request information about a product or service;
• 3. Complete a survey, contest or sweepstakes or other promotion; or,
• 4. Use aggregation services such as My Portfolio™ and My Financial Picture™ in order to consolidate your financial account or information at one online location.

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:

• 1. Contact Information such as name, mailing address, email address, telephone and mobile number(s),
• 2. Account Application information such as credit and income information,
• 3. 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
• 4. Access Authorization such as user name, alias, PIN and passcode and security questions and answers
• 5. 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, 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
• - Geolocation information with consent, for example ATM or financial center location, fraud prevention)
• - Social media preference

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:

• 1. 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; and consolidating your financial account information at one online location with services such as My Portfolio™ and My Financial Picture™.
• 2. 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.
• 3. Providing advertising on our Sites and Mobile Apps as well as non-affiliated third party sites and through off-line channels like financial centers, call centers and direct marketing (for example email, mail and phone).
• 4. Detecting and preventing fraud, identify theft and other risks to you or CRBT.
• 5. Performing analytics concerning your use of our online services, including your responses to our emails and the pages and advertisements you view.
• 6. Complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies.
• 7. 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.

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

Individual health information

To the extent that we receive, maintain or process an individual's health information, CRBT may use and disclose that information as authorized by and in accordance with applicable federal and/or state law.

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:

• 1. Affiliates and Subsidiaries of CRBT
• 2. Service Providers, Vendors and Third Party Providers who have contracts with CRBT
• 3. 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.