First Bank Online Privacy Statement
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First Bank Online Privacy Statement

Effective Date: 1/1/20

At First Bank your privacy is important to us.

We are committed to the responsible use and protection of your consumer information. This Online Privacy Statement (Privacy Statement) applies to First Bank online services (i.e. website, mobile, and social media applications). 

This Privacy Statement explains how we collect, share and use your information when you visit or use the First Bank website or an online service.  You may also refer to our Consumer Privacy Notice, which explains our practices surrounding the collection, use, and sharing of your personal information when you obtain a financial product or service for a personal, family, or household purpose.

If you are a California resident, you may have additional rights; please see “California Privacy Rights”, below.

If you are a California resident with a financial product or service obtained for personal, family, or household purposes, please refer to our Consumer Privacy Notice.

Your Personal Information 
As a client or prospect you may visit our website or use one of our online services.  First Bank may collect personal information from or about you such as, but not limited to: contact information including your name, mailing address, email address, one or more telephone numbers, and your bank account numbers. We may collect location information such as a zip code to help you find a nearby First Bank branch. We may also collect additional information which may include credit or debit card information, social security number(s), driver's license numbers and a user name or password. This is common information you use while accessing our online services and which First Bank requires for identification and security purposes.

Sharing
We may share your information with our service providers, such as data processors and companies that help us market products and services to you. When permitted or required by law, we may share information with third parties for purposes such as responding to a specific legal process.

Use of Your Personal Information 
We will use any  information we gather  in a variety of ways, including  processing  transactions such as a home loan request, verifying your identity, improving the security of your account through fraud detection and other means,  responding to your requests and communicating with you, managing your specific preferences such as passwords and login credentials, complying with applicable legal requirements,  and for  other purposes that we may disclose at the time you provide us with or we collect your personal information. 

First Bank may also gather and collect other information about your online usage. For example, when you access our website, www.firstbanks.com, we will display specific graphics and product offers by aligning those graphics and offers with your computer’s specific IP address.  

Either First Bank or our third-party partners, including Ad Roll, may track and analyze your online behavior to send you targeted First Bank digital advertisements.   This process occurs by identifying specific technologies which collect and store information about your visit behavior, or use of our online services.

California Privacy Rights
If you are a California resident, with one of the following relationships, please read this section carefully as it provides information relating to your rights under the California Consumer Privacy Act: 

  • Individual with a business relationship, such as a sole proprietorship or d/b/a account
  • Individual who is an authorized signer on a business account
  • Individual who is a guarantor on a business or commercial loan
  • Non-client of First Bank who has interacted with the Bank’s webpage or social media sites
  • Trustee for a trust
  • Beneficiary for a trust for which First Bank is trustee
  • Participant in a 401(k) or pension plan that First Bank sponsors or is a trustee or fiduciary.

You have the right to request that First Bank disclose the following:

A.    Information Collection and Sharing Practices

  1.  The categories and specific pieces of personal information we have collected about you; and
  2.  The categories and specific pieces of personal information we have collected about you; the categories of sources from which we collected your information; the business or commercial purpose for collecting your personal information, and; the categories of third parties with whom we shared your personal information. We do not sell your personal information for business or commercial purposes. 

B.    Sale and Disclosure of Your Information for our Business Purposes 

  1.  The categories of personal information we have collected about you and the categories of personal information that we have disclosed about you for a business purpose.
  2. We do not sell your personal information; however, we will provide you with the categories of personal information we have collected about you, along with a statement that we do not sell your personal information.

In order to view the information noted above, use our web form or call (800) 760-2265.  

First Bank will never discriminate against you for exercising any of your rights under the California Consumer Privacy Act, by taking actions including, but not limited to, the following: 

  1. Denying you products and services;
  2. Charging you different prices or rates for products or services, including through the use of discounts or other benefits or by imposing penalties;
  3. Providing you a different level or quality of products or services; or
  4. Suggesting that you will receive a different price or rate for products or services or a different level or quality of products or services.

However, we may charge you a different price or rate or provide you a different level or quality of product or service, if that difference is reasonably related to the value provided to us by your data.  We may also offer you financial incentives, including payments to you as compensation, for the collection or deletion of your personal information.  We may also offer you a different price, rate, level, or quality of goods or services if the price or difference is directly related to the value provided to us by your data.   

At this time, First Bank does not offer financial incentive programs.  Should we decide to offer financial incentive programs in the future, you will receive disclosures that clearly describe the material terms and conditions of the program.  You will be required to opt-in to the program, after reviewing the terms and conditions.  You will also have the right to revoke your opt-in consent at any time.  We will not use financial incentive practices that are unjust, unreasonable, coercive, or usurious in nature.

First Bank’s Recent Information Collection and Sharing Practices

We believe it is important you know and understand the types of personal information we collect and share and our reasons for doing so.  We have outlined below First Bank’s practices regarding the collection and sharing of your personal information in the past twelve months:


I.    First Bank has collected the following categories and specific pieces of personal information about you from the following sources:  

  • Identification Information
    • ​​We collected the following specific pieces of information:  Name; Alias or Nickname; Address; Account Name; Account Number; Border Crossing Card Number; Consular Card Number; Credit Card Number; Customer Number; Debit Card Number; Driver’s License or State ID Number; Email address; Identification Protection Personal ID number; Insurance Policy number; Military ID Number; Passport number; Permanent Resident number; Signature; Social Security Number; Student ID number; Telephone number (home, business, cellular); and Tribal ID number. 
       
    • This information was collected from you and our service providers.  
       
  • Commercial Information
    • We collected the following specific pieces of information:  Universal loan identifier, application date, loan type, loan purpose, construction method, occupancy type, loan amount, action taken and action taken date, property address, property location, year built, legal description, title information, county and census tract, income, type of entity that purchased the loan, rate spread, lien status, credit score, total loan costs, lender credits, interest rate, source of down payment, prepayment penalty term, debt to income ratio, combined loan-to-value ratio, loan term, introductory rate period, non-amortizing features, property value, manufactured home secured property type, manufactured home land property interest, total units, multifamily affordable units, application channel, purchase agreement and addendum, co-borrower and guarantor.  
       
    • We collected asset values, such as current balances of cash, bank account, securities, and retirement accounts; real estate owned; accounts and notes receivable; automobiles and other personal property; and the cash surrender value of life insurance.
       
    • We collected values for your liabilities, including outstanding loans; accounts and bills due; unpaid taxes; contingent liabilities; and information related to legal proceedings such as judgments, bankruptcy, foreclosure, and divorce. 
       
    • This information was generally collected from you or our service providers.  In some cases, the information was collected from or verified with a third party, with your authorization.
       
  • Demographic Information Collected to Document our Compliance with Applicable Anti-Discrimination Laws and Regulations.
    • We collected the following information, when required: age, ancestry, citizenship, disability, ethnicity, familial status, gender, gender identity and expression, health insurance information, marital status, medical condition, medical information, national origin, physical characteristics or description, pregnancy status, race, religion, sexual orientation, source of income, veteran status. 
       
    • This information was collected from you or from our employees.
       
  • Internet/Other Electronic Network Activity Information
    • We collected your IP address, browsing history and search history while on First Bank’s site, information relating to your interactions with First Bank’s online banking, and your comments on any social media page maintained by First Bank including First Bank’s Facebook, LinkedIn and YouTube pages.  We also collected and stored your user ID, member ID or subscriber ID for various First Bank online services, payee information including address and account number information for our bill pay service, and payee information including name, address, telephone and email address information for our People Pay service.  If you signed documents electronically, we retained your electronic signature information, and related systems documentation.
       
    • Your IP address, browsing history, search history, and interaction information were collected by our online systems, if you visited any of our online sites.  Our system assigned and stored user, member, and subscriber IDs for various online services.  We collected information from you in our online payment services, such as Bill Pay and People Pay, if you enrolled in those services.  We also collected information you entered as comments on any website or social media page maintained by First Bank including firstbanks.com and our Facebook, LinkedIn, and YouTube pages. 
       
  • Geolocation Data
    • We collected your IP address while you were on any First Bank site.
       
    • This information was collected from our processing systems and service providers.
       
  • Audio, Electronic, Visual, or Similar Information
    • We collected photographs of events, which may contain visual images of attendees (e.g. Bank events and Bank related seminars); videos and images from security cameras showing images of individuals on the Bank’s premises; and videos posted to firstbanks.com and First Bank’s social media site may contain individual images or audio. First Bank also imaged certain documents, such as identification documents (e.g. driver license or other identification card)
       
    • We collected visual and audio information from our systems which recorded such information.  Photographs may have been taken by camera and later captured digitally.  You may have input photographs or images into our social media sites in connection with sweepstakes entries or other contests.  Similarly, you may have submitted documents, which we later imaged for record retention purposes (e.g., driver license or other identification).
       
  • Professional/Employment-Related Information
    • We collected information about your employment, such as your occupation, job title, length of employment, and employment history. 
    • This information was collected from you and your employer.
       
  • Education Information
    • We collected information about your educational history.
    • This information was collected from you and your educational institution.
       
  • Profile Inferences
    • We collected the following information to build client profiles:
      • Account usage information was analyzed to determine future account performance.
      • Deposit transaction and history were analyzed for risk assessment and fraud detection purposes. 
      • Account transaction information was analyzed to determine your behavior and product preferences.
      • Loan repayment patterns were analyzed to determine the likelihood that delinquent borrowers will repay their loans.
    • This information was collected from our internal systems and our marketing service providers.  
       
  • First Bank collected personal information for the following business purposes
    • To verify your identity, authenticate transactions you initiated, protect you and your accounts from fraud; and to perform quality control monitoring
    • To perform services on your behalf, such as processing your transactions
    • To contact you whenever necessary
    • To evaluate your creditworthiness and report to consumer reporting agencies, such as credit bureaus
    • To file required reports with federal and state agencies
    • In our online channels, to assist you in locating our nearest branch
    • For promotional and security purposes
    • For risk management purposes
    • To offer products and services to you
       
  • First Bank collected personal information for the following commercial purposes:
    • To perform reviews of your existing products and services.
    • To inform you of other products and services that we believed will be beneficial to you.
    • To analyze your usage of our online services by reviewing activity such as page visits and click-throughs and to offer products to you based on the results of that analysis.
       
  • First Bank did not sell any categories of personal information for business or commercial purposes.  
     
  • First Bank shared personal information with the following categories of third parties:
    • We shared personal information with government agencies for required reporting purposes and law enforcement when we reported fraud or other banking-related crimes.

II.    First Bank collected but did not sell the following categories of personal information:  

  • Identification Information
  • Commercial Information
  • Demographic Information
  • Internet/Other Electronic Network Activity Information
  • Geolocation Data
  • Audio, Electronic, Visual, or Similar Information
  • Professional/Employment-Related Information
  • Education Information
  • Profile Inferences

III.    First Bank collected and disclosed the following categories of personal information so that we could service your account(s) and meet regulatory reporting requirements:

  • Identification Information
    • We disclosed your identification information to verify your identity, authenticate transactions you initiated, protect you and your accounts from fraud, report to consumer reporting agencies and meet government reporting requirements, and to facilitate processing of your accounts and services.
       
  • Commercial Information
    • We disclosed your transaction information so that we could determine products and services that we believed would be beneficial to you, based on your past activity. 
       
  • Demographic Information
    • We disclosed certain demographic information, such as race, gender, and ethnicity, to document our compliance with applicable antidiscrimination laws and regulations.
       
  • Internet/Other Electronic Network Activity Information
    • We disclosed information relating to your interactions with firstbanks.com, First Bank’s eBanking and Business eBanking service, and your comments on First Bank social media sites to authenticate you, identify fraudulent transactions, and analyze site usage and market products to you. 
       
  • Geolocation Data
    • We disclose this data to identify fraudulent transactions and investigate fraud claims.
       
  • Audio, Electronic, Visual, or Similar Information
    • We disclosed this data for transaction verification, and to assist us in identifying fraudulent transactions and investigating fraud claims. We disclosed this data for promotional purposes with your consent.
       
  • Professional/Employment-Related Information
    • We disclosed this information for verification of employment, credit underwriting, and transaction authentication purposes.
       
  • Education Information
    • We disclosed this information for verification of employment, credit underwriting, and transaction authentication purposes.
       
  • Profile Inferences
    • We used information contained in your client file to create a profile, which is disclosed for credit underwriting and risk management purposes, as well as to market products and services to you.  

Technologies We and Our Third Party Advertising Partners Use
First Bank uses technologies such as cookies and pixels to anonymously keep track of your activities on our website and our advertiser's websites, so that we may serve you more relevant advertisements. A cookie is a small text file that is stored on your device for record-keeping purposes. Session cookies expire when you close your browser. Persistent cookies remain on your device for an extended period of time. We and our third party partners use session cookies and persistent cookies.

We use persistent cookies to keep track of your activities when you visit our website or our advertisers' websites, and to serve you relevant advertisements. Our advertising partners (including Recrue Media and Frequence) also place persistent cookies on your device when you visit our website in order to help serve relevant advertisements to you when you visit websites in their networks.

This is how the process works: when you visit our website, a pixel on our site causes a persistent cookie to be set in your browser. When you leave our website and visit another website, our advertising partners are able to recognize that cookie if the other website is also an advertising partner with that website provider.

You may use the following links to view and set your choices regarding the advertisement mechanisms of our advertising partners:
Recrue Media:  http://www.youradchoices.com/privacy.aspx
Frequence:  https://www.frequence.com/privacy-policy

Removal of Cookies
You can remove cookies from your browser by following the directions provided in your Internet browser's "help" file. You may also decline cookies if your browser permits, but please be aware that doing so may interfere with your use of our website.

Accessing First Bank with a Mobile Device 
First Bank offers you the ability to access our website with a mobile-enabled device such as a smartphone or tablet. When you connect with First Bank’s Online Banking, we utilize personal protection solutions including unique identifiers and True Stamp images to protect your information.  If you use a location feature, such as locating a First Bank branch or ATM, we will use information about your location to present you the current information.  The Privacy Policy specific to our Mobile Banking service can be found by selecting Mobile Money Privacy Policy.

Linking To Third Party Websites
Our website has links to third party sites. These links are offered as a courtesy and a convenience to our clients. We will notify you via a browser pop-up message when you are being re-directed to a third party site. You will be given the option to proceed to the third party site or to remain on firstbanks.com. First Bank is not responsible for the information practices of sites linked to or from our website. Please review the privacy and information security policies of these sites prior to providing any personal information, as their practices may differ from First Bank’s. 

Children’s Privacy
We do not knowingly solicit or collect personal information from individuals under the age of 13. 

California Residents: Neither firstbanks.com nor Firstbank’s social media sites are directed to minors, nor does First Bank knowingly allow California residents under the age of eighteen to become registered users of its online services.  

Your Security 
Visit our Security Center for additional information about how we protect your personal information. Please note that information you send to us electronically may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information (such as your Social Security number or Bank Account Number) to us.

Updating Your Personal Information 
It is very important to keep your account information accurate and up to date. You can access your account information through various means, such as account statements, telephone banking, online banking, and in response to specific requests. To update your account information, please request changes at your local branch, through our Client Contact Center, with your financial advisor, or your First Bank Account Representative.
 
Social Media Policy
First Bank’s purpose in having a presence in various social media sites is to engage with our current and potential clients. By sharing 100 years of experience and knowledge with our communities, our goal is to build a stronger relationship with our clients in the communities that we serve. 

Our Social Media sites are NOT intended to serve as a client service channel, although your comments are always welcome. However, if you need assistance with your account, please contact our Client Contact Center at 800-760-2265 or visit us at www.firstbanks.com to find a location near you.  If you post a comment on any of our social media sites, our Client Contact Center may reach out to assist with any questions or concerns regarding your experience with us.  For your own protection, you should never post an account or telephone number, or any other personal identifying information. 

The social media sites that First Bank participates in are owned by third parties and are not affiliated with First Bank.  Each site has its own policies and procedures that you have agreed upon by using their product.  We encourage you to familiarize yourself with the privacy and security policy posted on each social media site, for your own protection.

First Bank does not tolerate inappropriate comments from users.  We reserve the right to remove any posts or comments that First Bank in its own discretion deems inappropriate. 

Updates to this Statement.  We reserve the right to make changes to both our practices and our Statement, at any time.  Please return to this site frequently to determine if changes have been made.