California Consumer Privacy Act (CCPA) Privacy Policy

Last updated on January 1, 2024

Applicable to California Residents Only

PERSONAL INFORMATION RIGHTS

At Liberty Bank, N.A., respecting the privacy of your personal information is important to us. This notice is adopted to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2022 (“CCPA”). The CCPA and this notice apply solely to individuals who are California residents. This notice does not apply to personal information that is either exempted or not covered by the CCPA (e.g., personal information collected or disclosed pursuant to the federal Gramm-Leach-Bliley Act or its implementing regulations).

We want you to understand what information we collect and how we use it. In addition, we want you to know about important rights you have under the CCPA in connection with your personal information.

DEFINITIONS

Let us begin by defining some terms that you will see in this notice.

“We,” “our,” and “us” refer to Liberty Bank, N.A.
“You” and “your” refer to a natural person who is a California resident.
“Personal Information” is information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular individual or household.

All other terms defined in the CCPA, or its implementing regulations have the same meanings when used in this notice.

COLLECTION OF PERSONAL INFORMATION

We have collected the following categories of personal information and categories of sensitive personal information about consumers in the preceding twelve (12) months:

“Categories of Personal Information” the categories of personal information we have collected include the following:

Identifying Information is information that identifies an individual, such as an individual’s name, alias, birthdate, account name or other similar unique identifier.
Associated Information is information that relates to, describes, or can reasonably be associated with a particular individual, such as a signature, postal or email address, telephone number, insurance policy number, bank account or card number, or any similar information.
Characteristic Information is information related to characteristics of protected classifications under state or federal law, such gender or marital status.
Commercial Information is information of a commercial nature, such as records of personal property, products or services purchased or considered, or other purchasing histories.
Biometric Information is information related to the measurement or analysis of unique physical or behavioral characteristics, such as a fingerprint or voice pattern.
Internet Activity Information is information related to internet or other electronic network activity, such as a search or browsing history, or interactions with a website.
Geolocation Information is information or data related to a geographical location, such as a device or Internet Protocol (IP) location.
Audio Visual Information is audio, visual, electronic, or similar information.
Employment Information is professional or employment-related information, such as employment history or status.
Education Information is personally identifiable education information that is not publicly available.
Inference Information is inferences drawn from any other category of personal information to create a profile about an individual reflecting potential or probable preferences, behavior, abilities, or other similar predispositions.

“Categories of Sensitive Personal Information” the categories of sensitive personal information we have collected include the following:

Identification Numbers are any information that reveals an individual’s social security number, driver’s license number, state identification card number, or passport number.
Financial Account Information and Credentials are any information that reveals an individual’s account login number, financial account number, such as a loan number or deposit account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials, which would allow someone to gain access to the account.
Precise Geolocation Data is any data that is derived from a device and that is used or intended to be used to locate an individual within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet.
Background Information is any information that reveals an individual’s racial or ethnic origin.
Personal Messages are the contents of an individual’s mail, email, and text messages if the individual is an employee of the Bank, and where the Bank is not the intended recipient of the communication.
Health Information is any personal information collected and analyzed concerning an individual’s health if the individual is an employee of the Bank.

PURPOSES FOR WHICH WE COLLECT PERSONAL INFORMATION

We collect the categories of personal information and categories of sensitive personal information identified above for the following business or commercial purposes:

Providing our products and services: Performing services, including maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, or providing financing.
Marketing/Prospecting: Performing services, including providing advertising or marketing services, providing analytic services, or providing similar services (we do NOT use any of the Categories of Sensitive Personal Information we collect to advertise or market products or services to consumers).
Fraud Prevention: Performing services, including protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Improving our products and services: Undertaking activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance the service controlled by the Bank.
Research: Undertaking internal research for technological development
Legal Compliance/Legal Proceedings: Complying with laws, regulations and with other legal processes and law enforcement requirements, including any internal policies based on or reflecting legal or regulatory guidance, codes, or opinions. Supporting audit and investigations and legal requests and demands from regulatory authorities.
IT Operations: Detecting security incidents, debugging to identify and repair errors that impair existing intended functionality.
Financial Management: Performing accounting, monitoring, and reporting.
Security: Ensuring security and integrity to the extent the use of Personal Information is reasonably necessary and proportionate. To help maintain the safety, security, and integrity of our mobile application or website, products and services, databases, and other technology assets.
Operation of company websites: To provide, support, personalize, and develop our website or mobile application, products, and services.
Investigations: To provide you with support and to respond to your inquiries, including to investigating and addressing your concerns and monitoring and improving our responses.
Human Resource Management: Identifying and processing employment applicants, including conducting background checks and verifying qualifications for employment. Administering employee services, including pay/compensation, and providing benefits to employees and dependents, including healthcare and retirement plans. Managing the health and safety of our employees.

SOURCES FROM WHICH WE COLLECT PERSONAL INFORMATION

We collect the categories of personal information and categories of sensitive personal information from the following sources:

Directly from you
Credit reporting agencies
Our service providers
Persons and entities with whom you perform transactions with
Government entities
Social networks

DISCLOSURE OF PERSONAL INFORMATION

We have disclosed personal information about consumers to third parties for a business or commercial purpose in the preceding 12 months. Below is a list of categories of personal information we have disclosed for business purposes in the preceding 12 months. For each category, we have also listed our business or commercial purpose for disclosing the information, and the categories of third parties to whom the personal information was disclosed:

Categories of Personal Information We Disclose for a Business Purpose

Identifying Information

Legal Compliance/Legal Proceedings, Providing our products and services, Marketing/Prospecting, Fraud Prevention, Improving our products and services, Financial management, Investigations, Human Resource Management, IT Operations, Security, Operation of company websites, Research
Government agencies and related third parties as required to comply with laws and regulations.

Third parties to comply with legal and regulatory requirements or provide professional services to us, including auditors, accountants, and legal services.

Vendors and service providers to conduct day-to-day business, including maintaining or servicing accounts, providing customer service, processing payments and transactions, verifying customer information, and maintaining websites and technology infrastructure.

Vendors and service providers to conduct activities for human resources related to potential, existing, and former employees.

Vendors and service providers to assist us in protecting your accounts and personal information, such as account monitoring services for fraud.

Service provider or vendors of Liberty Bank, N.A. that may use the personal information consistent with this policy, federal, and state privacy laws.

Business partners as part of a sale or transfer of business.

Associated Information

Legal Compliance/Legal Proceedings, Providing our products and services, Marketing/Prospecting, Fraud Prevention, Improving our products and services, Financial management, Investigations, Human Resource Management, IT Operations, Security, Operation of company websites, Research
Government agencies and related third parties as required to comply with laws and regulations.

Third parties to comply with legal and regulatory requirements or provide professional services to us, including auditors, accountants, and legal services.

Vendors and service providers to conduct day-to-day business, including maintaining or servicing accounts, providing customer service, processing payments and transactions, verifying customer information, and maintaining websites and technology infrastructure.

Vendors and service providers to conduct activities for human resources related to potential, existing, and former employees.

Vendors and service providers to assist us in protecting your accounts and personal information, such as account monitoring services for fraud.

Service provider or vendors of Liberty Bank, N.A. that may use the personal information consistent with this policy, federal, and state privacy laws.

Business partners as part of a sale or transfer of business.

Characteristic Information

Legal Compliance/Legal Proceedings, Providing our products and services, Fraud Prevention, Human Resource Management
Government agencies and related third parties as required to comply with laws and regulations.

Third parties to comply with legal and regulatory requirements or provide professional services to us, including auditors, accountants, and legal services.

Vendors and service providers to conduct day-to-day business, including maintaining or servicing accounts, providing customer service, processing payments and transactions, verifying customer information, and maintaining websites and technology infrastructure.

Vendors and service providers to conduct activities for human resources related to potential, existing, and former employees.

Vendors and service providers to assist us in protecting your accounts and personal information, such as account monitoring services for fraud.

Service provider or vendors of Liberty Bank, N.A. that may use the personal information consistent with this policy, federal, and state privacy laws.

Business partners as part of a sale or transfer of business.

Commercial Information

Legal Compliance/Legal Proceedings, Providing our products and services, Improving our products and services, Financial management, Investigations, Fraud Prevention
Government agencies and related third parties as required to comply with laws and regulations.

Third parties to comply with legal and regulatory requirements or provide professional services to us, including auditors, accountants, and legal services.

Vendors and service providers to conduct day-to-day business, including maintaining or servicing accounts, providing customer service, processing payments and transactions, verifying customer information, and maintaining websites and technology infrastructure.

Vendors and service providers to assist us in protecting your accounts and personal information, such as account monitoring services for fraud.

Service provider or vendors of Liberty Bank, N.A. that may use the personal information consistent with this policy, federal, and state privacy laws.

Business partners as part of a sale or transfer of business.

Biometric Information

IT Operations, Security, Operation of company websites
Government agencies and related third parties as required to comply with laws and regulations.

Third parties to comply with legal and regulatory requirements or provide professional services to us, including auditors, accountants, and legal services.

Service provider or vendors of Liberty Bank, N.A. that may use the personal information consistent with this policy, federal, and state privacy laws.

Business partners as part of a sale or transfer of business.

Internet Activity Information

Legal Compliance/Legal Proceedings, Marketing/Prospecting, Fraud Prevention, IT Operations, Security, Operation of company websites, Providing our products and services
Government agencies and related third parties as required to comply with laws and regulations.

Third parties to comply with legal and regulatory requirements or provide professional services to us, including auditors, accountants, and legal services.

Vendors and service providers to conduct day-to-day business, including maintaining or servicing accounts, providing customer service, processing payments and transactions, verifying customer information, and maintaining websites and technology infrastructure.

Vendors and service providers to assist us in protecting your accounts and personal information, such as account monitoring services for fraud.

Vendors and service providers to assist with branch locator applications.

Service provider or vendors of Liberty Bank, N.A. that may use the personal information consistent with this policy, federal, and state privacy laws.

Business partners as part of a sale or transfer of business.

Geolocation Information

Legal Compliance/Legal Proceedings, IT Operations, Security, Operation of company websites
Government agencies and related third parties as required to comply with laws and regulations.

Third parties to comply with legal and regulatory requirements or provide professional services to us, including auditors, accountants, and legal services.

Vendors and service providers to assist with branch locator applications.

Service provider or vendors of Liberty Bank, N.A. that may use the personal information consistent with this policy, federal, and state privacy laws.

Business partners as part of a sale or transfer of business.

Audio Visual Information

Legal Compliance/Legal Proceedings, Marketing/Prospecting, Operation of company websites, Providing our products and services
Government agencies and related third parties as required to comply with laws and regulations.

Third parties to comply with legal and regulatory requirements or provide professional services to us, including auditors, accountants, and legal services.

Vendors and service providers to conduct day-to-day business, including maintaining or servicing accounts, providing customer service, processing payments and transactions, verifying customer information, and maintaining websites and technology infrastructure.

Service provider or vendors of Liberty Bank, N.A. that may use the personal information consistent with this policy, federal, and state privacy laws.

Business partners as part of a sale or transfer of business.

Employment Information

Legal Compliance/Legal Proceedings; Providing our products and services, Marketing/Prospecting, Fraud Prevention, Financial management, Security, Human Resource Management, Marketing/Prospecting
Government agencies and related third parties as required to comply with laws and regulations.

Third parties to comply with legal and regulatory requirements or provide professional services to us, including auditors, accountants, and legal services.

Vendors and service providers to conduct day-to-day business, including maintaining or servicing accounts, providing customer service, processing payments and transactions, verifying customer information, and maintaining websites and technology infrastructure.

Vendors and service providers to conduct activities for human resources related to potential, existing, and former employees.

Vendors and service providers to assist us in protecting your accounts and personal information, such as account monitoring services for fraud.

Service provider or vendors of Liberty Bank, N.A. that may use the personal information consistent with this policy, federal, and state privacy laws.

Business partners as part of a sale or transfer of business.

Education Information

Legal Compliance/Legal Proceedings, Providing our products and services, Financial management, Security, Human Resource Management
Government agencies and related third parties as required to comply with laws and regulations.

Third parties to comply with legal and regulatory requirements or provide professional services to us, including auditors, accountants, and legal services.

Vendors and service providers to conduct day-to-day business, including maintaining or servicing accounts, providing customer service, processing payments and transactions, verifying customer information, and maintaining websites and technology infrastructure.

Vendors and service providers to conduct activities for human resources related to potential, existing, and former employees.

Service provider or vendors of Liberty Bank, N.A. that may use the personal information consistent with this policy, federal, and state privacy laws.

Business partners as part of a sale or transfer of business.

Inference Information

Legal Compliance/Legal Proceedings
Government agencies and related third parties as required to comply with laws and regulations.

Third parties to comply with legal and regulatory requirements or provide professional services to us, including auditors, accountants, and legal services.

Service provider or vendors of Liberty Bank, N.A. that may use the personal information consistent with this policy, federal, and state privacy laws.

Business partners as part of a sale or transfer of business.

SALE OR SHARING OF PERSONAL INFORMATION

We do not and will not sell or share the personal information of consumers to third parties (including personal information of minors under 16 years old).  We have not sold or shared any personal information about consumers in the preceding 12 months for a business or commercial purpose.

USE OF SENSITIVE PERSONAL INFORMATION

We have not used or disclosed any of the Categories of Sensitive Personal Information for purposes other than those specified as permissible uses as set forth in the CCPA and the implementing regulations adopted by the California Privacy Protection Agency (including how the CCPA and its regulations may be amended from time to time) that do not to trigger a consumer’s right to limit use.

RIGHTS UNDER THE CCPA

California residents have the right to:

Request the following information from us regarding our collection of your personal information:
- The categories of personal information that we collect, use, disclose, and sell (as applicable);
- The categories of sources from which personal information is collected;
- Our business or commercial purpose for collecting, selling or sharing (if applicable) personal information;
- The categories of third parties to whom your personal information has been disclosed; and
- The specific pieces of personal information that we have collected about you.
Request the deletion of your personal information collected or maintained by us, subject to exceptions outlined in the CCPA.
Not receive discriminatory treatment from us for the exercise of any privacy rights conferred by the CCPA, including an employee, applicant, or independent contractor’s right not to be retaliated against for the exercise of their rights.
Request corrections to inaccurate personal information we maintain about a California resident.
Opt out of the selling or sharing of their personal information if a business sells or shares their personal information.
Limit the use or disclosure of their sensitive personal information, if a business uses or discloses their sensitive personal information for any reason other than what is specified in the CCPA or its implementing regulations as a permissible use.

HOW TO EXERCISE YOUR RIGHTS

If you wish to exercise your rights and submit a request to know, request to delete, or request to correct you must:

Complete the CCPA Rights Request form available on our website.
Call our toll-free number at (800) 735-2465 and provide us with the information needed to complete our request form, or
Complete the request form with a Bank representative at any of our branch locations.

In order to verify your identity in connection with a request, we will require you to provide us with your name, address, and other information about you, your accounts, or transactions that we can use to match with the information we have on file.  The amount and type of information we request may vary depending on the sensitivity of personal information covered by the request.  We may also require you to give us a signed declaration under penalty of perjury that you are the consumer whose personal information is covered by the request.   

In some instances, we may not be able to comply with your request.  For example, we cannot comply with a request if we cannot verify your identity.  Also, we will not provide a social security number, driver’s license or other government issued identification number, account or card number, password or security question and answer, or any specific piece of information if the disclosure presents the possibility of unauthorized access that could result in identity theft or fraud.   

We do not sell or share personal information so the receipt of an opt-out preference signal will not impact how we collect, use, or disclose your personal information.

AUTHORIZED AGENT

You may designate an authorized agent to make a request to know, request to correct or request to delete on your behalf by sending written authorization with your original signature to our address at: Liberty Bank, N.A., Attn: CCPA Requests, 355 S Grand Ave, Suite 2825, Los Angeles, CA 90071.  Unless the written authorization is a valid power of attorney created pursuant to California law, we will also require you to provide us with your name, address, and other information about you, your accounts, or transactions that we can use to match with the information we have on file.  The amount and type of information we request may vary depending on the sensitivity of personal information covered by the request.

CONTACT FOR MORE INFORMATION

If you have any questions or concerns regarding this notice or our privacy practices, you can contact us by calling our toll-free at (800) 735-2465, writing us at: Liberty Bank, N.A., Attn: CCPA Requests, 355 S Grand Ave, Suite 2825, Los Angeles, CA 90071, or stopping by at any of our California branch locations during normal business hours.