Online Privacy Policy

Effective Date December 15, 2023

Liberty Bank, N.A. ("we", “our”, “us”) respects your desire for privacy and is committed to maintaining the confidentiality of your information consistent with applicable legal requirements. This Online Privacy Policy(“Privacy Policy”) describes how we treat information provided by you or collected through our web site, www.libertybk.com (“Site”) as well as services we make available or provide access to through our Site, including the online banking applications or services provided or made available through the Site (the “Website Services”). Note, this Privacy Policy does not govern our privacy practices offline or with respect to information that is not provided or collected through the Site or the Website Services. If you are a consumer who has a continuing relationship with us or have applied for a product or service with us, please see our Privacy Notice for additional details about our treatment of your consumer financial data. Additionally, please see the Mobile Banking Application Privacy Notice for additional details about how we collect, use and retain information from the Bank’s mobile application.

By using our Site or the Website Services, you consent to this Privacy Policy, including your consent to our use and disclosure of the information in the manner described in this Privacy Policy. However, while this Privacy Policy describes how we treat information received through the Site or Website Services, please be aware that additional terms and conditions may apply for certain parts of the Site and Website Services.

Visitors to Our Web Site.

Visitors to our Site remain anonymous unless they register for a Website Service or otherwise elect to disclose their identity to us voluntarily or as part of their interaction with a Website Service. If you register for a Website Service or otherwise elect to disclose information to us through the Site we may collect the categories of personal information discussed below in the section entitled “Our Collection of Information About You”.

However, while we do not collect personal information about visitors that merely visit our Site, we do collect a certain limited amount of information about visitors, such as their IP address (a numeric address assigned automatically to computers when they access the Internet). We may also place “cookies” on a computer to track a visitor’s use of our Site or the Website Services.

Our Collection of Information About You.

We may collect personal information about you in order to understand your needs, administer our business, process transactions, and provide you with products and services through the Site. The personal information that we receive and collect is provided by you when you send us a message, fill out a form from our Site, or otherwise interact with our Website Services. The categories of personal information that we may collect from you include the following:

Identity Information, such as your first and last name, social security number, passport numbers, birth date, gender, marital status and title.
Contact Information, such as your physical home or work address, email address, and telephone number.
Identification Documentation, such as copies of a government issued identification card, including but not limited to a driver’s license or passport.
Financial Account Information, which includes information about your online transactions with us, information regarding accounts you hold with Liberty Bank or which you may otherwise link to the Website Services, and details about payments or other transactions to and from your bank accounts used in connection with the Website Services.
Employment Information, which includes information about your employment history, such as years of employment, employment status and salary or income levels.
Device Information, which includes information about the device you use to interact with our Site or the Website Services, such as your IP address, login data, the domain and host from which you access the Site or Website Services, browser and operating system data, the date and time in which you accessed the Site or the Website Services.
Online Activity Information, which includes information and data about how you use and interact with the Site or Website Services, such as pages or screens viewed or how long you spent on a particular screen or page on the Site.
Credential Information, which includes the information you provide to use to create a profile and access the Site or the Website Services, such as a username, password and security questions and answers used to recover your account.
Geolocation Information, which includes your approximate geographic location which we can infer from the Device Information we collect from you.
Cookies, which are text files that we may place on a visitor of our Site’s device to uniquely identify the visitor’s browser or to store information or settings in the browser.

Liberty Bank, N.A. and third-party vendors of ours do not collect personal information relating to your online activities over time and across different websites not owned by the Bank. At this time the Bank only tracks your activities while on our Site or while using the Website Services.

How We Use Personal Information.

The Bank may use the personal information described above for the following purposes:

Provide, maintain or service products and services that the Bank provides through the Site or a Website Service
Identify and prevent fraud
Verification of your identity
Product analysis and research
Maintenance of internal systems and infrastructure
Ensuring compliance with applicable laws and regulations
Responding to civil, criminal or other applicable regulatory legal processes
Auditing related to a current interaction with a user of the Site or Website Services
Detecting security incidents, protecting against malicious, deceptive fraudulent or illegal activity
Recognize when you return to the Site or Website Services in order to enhance the experience
Process transactions
Respond to your requests

Our Disclosure of Your Personal Information.

The personal information we collect from you described in the section above entitled “Our Collection of Information About You” allows us to offer you online services through the Site or the Website Services that can help you with your financial needs. Your personal information may also be shared with the following types of third parties.

Consumer reporting agencies and credit bureaus
Businesses and service providers that we rely on, or whom rely on us to provide you the products or services you request
Other third parties with whom you authorize or direct us to share your information with
Federal and state government entities and regulatory agencies as required by law or if we reasonably suspect in good faith that there is criminal activity involving you or a product or service you have obtained from the Bank
We may need to disclose your personal information to third parties in order to comply with subpoenas or other legal processes

"Do Not Track" Settings.

Your Internet browser may contain tools to request that that the Site or Website Services not track your online activities. The Bank does not track your browser activity, and as such does not respond to or take any action with respect to the "do not track" settings in your Internet browser.

Maintaining Accurate Information.

We have procedures in place that help us to maintain the accuracy of the personal information that we collect through the Site and Website Services. Please contact our customer service center at (800) 735-2465, if you believe that our information about you is incomplete, out-of-date, or incorrect.

Information Security.

We restrict access to personal information about you we collect to those employees who have a need to know such information (e.g., to process your transactions or provide services to you). We also maintain physical, electronic, and procedural safeguards that are designed to protect and safeguard against the loss and misuse of the personal information in our possession. . However, no information security safeguards or practices can be guaranteed to be 100% secure. If you have reason to believe that your interaction with the Site or the Website Services is no longer secure please immediately contact the Bank’s customer service center at (800) 735-2465.

Links to Other Web Sites.

The Site and Website Services may feature links to third party web sites that offer goods, services or information. Some of these sites may appear as windows-within-windows at this Site. When you click on one of these links, you will be leaving our Site and will no longer be subject to this Privacy Policy. We are not responsible for the information collection practices of the other web sites that you visit and urge you to review their privacy policies before you provide them with any personal information. Third party sites may collect and use information about you in a way that is different from this Privacy Policy.

Minors.

We feel strongly about protecting the privacy of children and teenagers. As such, we do not knowingly collect the personal information from individuals that are under the age of thirteen (13) through our Site or the Website Services and we request that these individuals do not provide any personal information to us through this Site.

Changes to this Policy.

This Privacy Policy may be modified from time to time. The effective date of this Privacy Policy is set forth at the top of the Privacy Policy. If the effective date listed at the top of the Privacy Policy has changed since the last time you reviewed the Privacy Policy, that will mean there have been changes to the Privacy Policy.

We may notify you, in our sole discretion, of any material changes of our collection, use, or disclosure of your personal information by posting an updated Privacy Policy on the Site or sending you a copy of the updated Privacy Policy by written or electronic communication.

However, your use of the Site or Website Services following changes to this Privacy Policy means that you have acknowledged and accepted any changes to the Privacy Policy.

If you have any questions regarding this Consumer Online Privacy Policy, you can call us at
(800) 735-2465.