Privacy Policy for the Card Valet Service (Effective as of January 01, 2021)
1. Introduction. This Privacy Policy describes the types of "Personal
  Information" (information that is identifiable to a particular person)
  that is collected (directly or through service providers) in connection
  with the Card Valet downloadable application ("App")
  and related services (collectively, the "Service") offered by your
  financial institution ("we" or "us"). This Privacy Policy is intended to
  supplement the disclosures in any Privacy Policy that you may have
  already been presented by us in connection with online banking or other
  services.
2. Eligibility. The Service is offered only to individual residents of
  the United States, excluding its territories, who can form legally
  binding contracts under applicable law. Without limiting the foregoing,
  the Service is not offered to minors. Other restrictions and eligibility
  requirements for the Service apply as described in the Card Valet Terms
  of Use. We do not knowingly collect any Personal Information from or
  about individuals under 18 years of age. Please do not submit such
  information to us, and as a parent or legal guardian, please do not
  allow your children to submit Personal Information without your
  permission. By using the App or the Service, you represent that you meet
  these requirements and that you agree to the terms of this Privacy
  Policy.
3. What Types of Personal Information We May Collect. We may collect
  Personal Information about you, which may include: name, postal address,
  zip code, e-mail address, telephone number, account numbers, payment
  card expiration date, payment card identification or verification
  numbers, social security number, mobile device location, and other
  information that we can use to contact you, verify your identity,
  provide the functionality available through use of the App and the
  Service, and manage risks, such as information maintained about you by
  identity verification services and consumer reporting agencies,
  including credit bureaus, and payment and other transaction information,
  and history for payments and other transactions in which you
  participate through the Service, and any Personal Information that you
  may enter into information blocks present in the App interface or made
  available through the Service. We
  may collect information regarding your mobile device such as device
  settings, unique device identifiers, information about your location,
  and analytical information that may assist with diagnostics and
  performance. For your convenience, you may be asked to grant permission
  for access to your mobile device's geolocation data. This information
  may be collected when you use certain services that are dependent on
  your mobile device’s location (such as the location of an ATM or in
  store transactions).
4. How We May Collect Personal Information About You. We may collect Personal Information about you from the following sources:
a. Information that you input to the App or that the App collects automatically;
b.
 Your use of the App and the Service, and your interactions with
  customer care, including information you enter or speak, and information
  transmitted by your computer or mobile device or other devices you use
  as part of your receipt of the Service; and
c.
 We may also collect Personal Information about you from others, such as
  Affiliates, or other companies (such as for fraud detection).
5. How We May Share Personal Information About You. We share Personal
  Information about you only as permitted by law. For Personal Information
  that is nonpublic and that we collect in connection with a financial
  service, U. S. federal law permits us to share such information only for
  the purposes shown in the following table:
Reasons we can share Personal Information about you  | Do we share?  | Can you limit this sharing?  | 
For
 our everyday business purposes - such as to process your transactions,
          respond to court orders and legal investigations, and report to credit
          bureaus;  | Yes  | No  | 
For our marketing purposes - to offer our products and services to you;  | Yes  | No  | 
For Joint Marketing with other financial companies;  | No  | We Do Not Share  | 
For our Affiliates' everyday business purposes (information about your transactions and experiences);  | Yes  | No  | 
For our Affiliates' everyday business purposes (information about your creditworthiness);  | No  | We Do Not Share  | 
For our Affiliates to market to you;  | No  | We Do Not Share  | 
For Nonaffiliates to market to you  | No  | We Do Not Share  | 
6. How We May Use Personal Information About You. We use Personal
  Information about you only as permitted by law, including but not
  limited to the following purposes:
a. To complete transactions and render services authorized by you;
b.
 Other everyday business purposes, such as to maintain your ability to
  access the Service, to send you information about the Service, to
  effect, administer and enforce transactions, to perform fraud screening,
  to prevent actual or potential fraud and unauthorized transactions, to
  verify your identity, to determine your credit history, to verify the
  information you provide to the Service, to perform collections, to
  report to credit bureaus (including furnishing delinquent account
  information), to comply with laws, regulations, court orders and lawful
  instructions from government agencies, to protect the personal safety of
  users of the Service or the public, to prevent and defend claims, to
  resolve disputes, to troubleshoot problems, to enforce our Terms of Use,
  to protect our rights and property, and to customize, measure, and
  improve the Service and the App, including pattern recognition,
  modeling, enhancement and improvement, system analysis, and Service
  performance analysis;
c.
 For marketing purposes - to offer products and services to you,
  although you may opt-out of receiving commercial email marketing
  messages from us by following the opt-out processes described in those
  messages; and
d.
 If we are involved in a merger, acquisition, or sale of all or a
  portion of our assets that results in a change of the majority ownership
  of the App or the Service or the entity that owns them, you will be
  notified of this via email and/or a prominent notice on the App, as well
  as any material change in uses of your Personal Information, as well as
  any choices you may have regarding Personal Information about you.
7. Other Important Information.
Vermont: Under Vermont law, we will not share information we collect
  about Vermont residents with companies outside of our Affiliates, unless
  the law allows. We will not share information about your credit
  worthiness with our Affiliates except with your consent, but we may
  share information about our transactions or experiences with you with
  our Affiliates without your consent.
California: Under California law, we will not share information we
  collect about you with Nonaffiliates, unless the law allows. For
  example, we may share information with your consent, to service your
  accounts, or to provide rewards or benefits you are entitled to. We will
  limit sharing among our Affiliates to the extent required by California
  law.
8. Definitions.
a. "Affiliates" means companies related by common ownership or control. They can be financial or nonfinancial companies.
b. "Nonaffiliates" means companies not related by common ownership or control. They can be financial or nonfinancial companies.
c.
 "Joint Marketing" means a formal agreement between nonaffiliated
  financial companies that together market financial products or services
  to you.
9. How We Protect Personal Information About You. To protect Personal
  Information about you from unauthorized access and use, we maintain
  physical, electronic, and procedural safeguards, including but not
  limited to security measures that comply with applicable federal and
  state laws. We also require our service providers and business partners
  to whom we disclose the information to do the same. When you enter
  sensitive information (such as a debit or credit card number) into the
  App, we encrypt the transmission of that information using secure socket
  layer technology (SSL). We may retain and use your information as
  necessary to comply with our legal obligations, resolve disputes, and
  enforce our agreements.
10. Data Retention. We will retain, protect, use and share Personal
  Information about you as long as it is reasonably required for the
  purposes described in this Privacy Policy, and as required by law,
  including but not limited to for risk management, regulatory compliance,
  and audit purposes.
11. Amendments. We may amend this policy at any time by posting a
  revised version in the App. The revised version will be effective
  immediately at the time it is posted unless a delayed effective date is
  expressly stated therein. You may (in our discretion) also be provided
  with an email notification of such amendments. If we make any change in
  how we use your Personal Information, we will notify you by email or by
  means of a notice in the App prior to the change becoming effective. You
  may (in our discretion) be required to affirmatively acknowledge or
  accept the revised Privacy Policy in order to continue using the App and
  the Service. Any use of the App or the Service after a notice of change
  will constitute your express agreement to such changes.