Effective Date: April 18th, 2024
Your Privacy
Your privacy is important to us. FirstBank is committed to maintaining the privacy of our customers. We have policies and procedures in place to restrict access to your information to employees who need to know that information in order to provide products or services to you. We train our employees to protect the confidentiality of your records. In addition, consistent with our obligations under applicable laws and regulations, we maintain physical, technical, electronic, procedural, and organizational safeguards and security measures that are designed to protect information against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, or access, whether it is processed by us or elsewhere.
If you are a California resident, you have rights under the California Consumer Privacy Act ("CCPA"). Visit the California Consumer Privacy Act page for more information.
Your Information and FirstBank
This Online Privacy Policy ("Online Policy") applies to consumers, ("consumer(s)", "you", "your", "their", or "them"). It explains how FirstBank, our Holding Company, and our Affiliate(s) ("we," "our," or "us") collect, disclose, share, use, and protect information when you visit or use our efirstbank.com, es.efirstbank.com, efirstbankblog.com, similar websites offered by FirstBank that link to or reference this Online Policy (collectively, our "Sites"), or use our FirstBank Mobile Banking Application ("Mobile App" or "App"). This Online Policy specifically applies to our collection, use, and disclosure of information collected from visitors during use of the Sites, such as for employment purposes, transactional purposes, or through tracking technology, including cookies or other tracking technologies. This Online Policy should be read together with the FirstBank Privacy Notice ("Privacy Notice") required by the Gramm-Leach-Bliley Act (GLBA), which, among other things, describes how FirstBank may disclose information gathered from you and how you can opt out or limit certain types of information sharing.
Information We Collect ("Information")
Your Information
When you visit or use our Sites, we may collect information provided by you through the Sites, including, but not limited to, your name, email address, mailing address, telephone number(s), username and password, and account numbers. We may also collect tax identification numbers, driver's license numbers (or comparable), and credit qualification information where we believe it is reasonably required for ordinary business purposes. We may also collect information for employment purposes, such as work history and prior employer, information from background checks, resumés, personnel files, and education, as applicable.
Site Visit and Usage Information
We or our third-party partners may use cookies, web beacons, or other technologies to collect and store information about your visit to or use of our Sites. In addition, we may later associate the usage and other information we collect online with personal information about you. We collect the following information we call "Site Visit Information" when you visit our Sites or use our Apps:
- network or device-related information like your operating system, browser, or IP address
- your physical location, but only with your permission (i.e. for branch location finder services)
- limited location information for other purposes
- information about which sections or pages you visit and certain interactions you make on our Sites
- information about the webpage you visited just before our Sites
- information about the webpage you visit through a link from our Sites
If you submit any information to us relating to other people or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Online Policy.
Mobile Applications ("Mobile Apps" or "Apps")
If you download and use our Mobile App, in addition to the information discussed above, we will also automatically collect and keep certain information about your mobile device, such as your device's unique identification number, its operating system, certain device settings and preferences, and information about how you are interacting with our Apps. If you use our mobile deposit services and take photographs of checks using our App, we will collect an image of your check solely to process your deposit. Additionally, if you choose to use the Zelle® Ready Contact feature, this will allow us to collect the information from your "Contacts" list on your mobile device to determine if any of your contacts are enrolled with Zelle®. This information is only shared with Zelle®.
Additional Sources of Information
We may also collect information about you from additional online and offline sources, including commercially available third-party sources, such as credit reporting agencies. We may combine this information with the personal and other information we have collected about you under this Online Policy.
Use of Information
We use the information discussed above in the following ways:
- Processing loan or credit applications
- Processing transactions
- Processing employment applications
- Supporting employment, human resource management, and related reasons to provide benefits, manage compensation activities, process employment applications, and to fulfill similar purposes, internally or in partnership with professional services providers and business partners
- Authenticating users (such as when you access your account information)
- Preventing fraud and enhancing the security of your account or our Sites
- Responding to your requests and communicating with you
- Managing your preferences
- Performing analytics concerning your use of our Sites, including your responses to our emails and the pages and advertisements you view
- Providing tailored content and marketing messages
- Operating, evaluating, and improving our business (including developing new products and services
- Improving existing products and services
- Performing data analytics
- Performing accounting, auditing, and other internal functions
- Complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations, and our policies
- For any other purposes that we may specifically disclose at the time you provide, or we collect, your information
We may also use information that we collect on an aggregate or anonymous basis (such that it does not identify any individual customers) for various business purposes, where permissible under applicable laws and regulations.
Disclosure of Information
We may disclose the information we collect from and about you with our affiliates and other third parties as described below. In particular, we may disclose your information to:
- Our affiliates
- Third-party service providers
- Third-party "Analytic Providers" for analytics and advertising purposes to provide more relevant advertisements to customers or potential customers. For more information about this, please read the section of this Online Policy on "Online Behavioral Advertising."
- Other third parties to comply with legal requirements such as the demands of applicable subpoenas and court orders; to verify or enforce our terms of use, our other rights, or other applicable policies; to address fraud, security, or technical issues; to respond to an emergency; or otherwise, to protect the rights, property, or security of our customers or third parties.
As described in the Privacy Notice and the "Opting Out of Online Behavioral Advertising" section, we will limit the sharing of your information in accordance with the choices you have provided us.
We may disclose anonymous or aggregated information with third parties to help deliver products, services, and content better tailored to our Sites' users and for other purposes.
Cross-Context or Online Behavioral Advertising (OBA)
To deliver relevant digital advertising to you, we utilize cookies and pixels (also called beacons) or similar technologies to evaluate our Sites and track digital advertising performance.
Cross-Context or Online Behavioral Advertising "OBA"
OBA allows advertisers to display relevant ads and personalized marketing messages to users based on their web browsing behavior. We use Site Visit Information to deliver advertising content that is more likely to be of interest to you. For more information regarding OBA, please visit youradchoices.com.
Analytics Providers
We engage third-party service providers to conduct OBA activities on our behalf. We call these third parties "Analytics Providers" and we use them to determine which of our ads are more likely to appeal to you and deliver them. We share Site Visit Information with our Analytics Providers through cookies, beacons, or similar technologies to get better insights into the use of our Sites and to engage in Online Behavioral Advertising.
Cookies
A "cookie" is an electronic file our Sites place on your computer or device(s) to store information that makes your visit to our Sites more efficient. Cookies let our Sites recognize if your computer or mobile device has visited our Sites before and what security requirements and browser preferences your computer or mobile device requires. We use cookies for fraud prevention, security, to improve the functionality and performance of our Sites, and to monitor advertising and marketing campaign performance. Additional information about cookies and how they work is available at www.allaboutcookies.org.
You can block cookies by either changing the settings on your internet browser or through the use of software programs specifically designed to block cookies. Please note, however, that if you choose to block cookies, you will not be able to log into our secure Online Banking service, and you may limit other functionality we can provide when you visit our Sites. To block targeting cookies used in Online Behavioral (OBA) without losing other functionality, you can opt out of targeting cookies as described in the Opting Out of Online Behavioral Advertising (OBA) section.
Beacons/Pixels
A "beacon" or "pixel tag" is a type of tracking technology associated with cookies. Unlike cookies, beacons or pixel tags are typically one-pixel, transparent images embedded on websites, not downloaded on your computer or device. We may also use technologies, such as cookies or pixel tags to provide you with personalized online display advertising tailored to your interests. Please refer to the Cross-context or Online Behavioral Advertising (OBA) section for more information, including how to opt out of personalized advertising.
Opting Out of Online Behavioral Advertising (OBA)
You can opt out of OBA by clicking "Cookie Settings" at efirstbank.com/privacy. You can also opt out by clicking on the "Cookie Settings" link in the cookie banner presented when you first visit our Sites, or anytime by clicking on the "Cookie Settings" link in our Site footer. Keep in mind that this opt-out works using cookies, so if you delete cookies, you will need to opt out again. Also, if you use different browsers or devices, you will need to opt out for each one individually.
Please note: Even if you opt out, you may still see advertisements from FirstBank while browsing online. These advertisements may be less relevant to you and your interests because they won't be based on information collected about you.
Global Privacy Control (GPC)
Our Sites process global browser opt-out preferences for consumers in California only. If we detect a global opt-out preference signal from a California IP Address, you will receive a notification, and your opt-out preference signal will be honored.
Site and App Security
Protecting your information is a priority for FirstBank. To protect your information from unauthorized access and use, we use reasonable administrative, technical, and physical controls to protect your information. While we take these important steps to protect you and your information, there are also important steps you can take to protect yourself. For more information, please visit our Security Center and our Digital Access Options on efirstbank.com.
Other Websites
For your convenience, our Sites may contain links to other websites or may refer you to other websites. Those other sites may be operated by other companies affiliated with us or by third-party companies not affiliated with us. Once you leave our Sites and access another website, you should be aware that you are subject to the privacy and security policies of that website.
Children's Online Privacy
Our Sites and our Apps are not intended for children under the age of 13. Please do not access or use our Sites or our Apps if you are under 13 years of age. By using our Sites or using our Apps, you affirm that you are 13 years of age, or older. For more information about the Children's Online Privacy Protection Act (COPPA), visit the FTC website: www.ftc.gov.
Accuracy
This Online Policy is accurate to the best of our knowledge. FirstBank performs monitoring of our Sites to ensure this Online Policy accurately reflects our practices.
Changes to this Online Privacy Policy
We may add to, delete from, or otherwise amend and update this Online Policy from time to time without prior notice. The date of the last update to this document is provided at the beginning of this Online Policy. Use of our Sites after an update indicates acceptance of the most current version.
Questions
You may contact us with questions or concerns about this Online Policy and our practices by:
- Calling us toll-free at 800-964-3444, or
- Emailing us at dataprivacy@efirstbank.com