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First PREMIER Privacy Statement

 

 

Effective as of January 1, 2020
Last updated December 29, 2022

 

Introduction

First PREMIER Bank (“PREMIER,” “we,” “our,” or “us”) respects the privacy of your information. This Privacy Statement is designed to assist you in understanding how we collect, use, share, and safeguard your information. This Privacy Statement applies to individuals who access our websites (the “Sites”), the services provided through our Sites and the mobile application we offer (collectively, “Services”).

If you have a financial product or service with us, we will use and share any information that we collect from or about you in accordance with our Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information.

From time to time, we may change this Privacy Statement. If we do, we will post an amended version on this webpage. Please review this Privacy Statement periodically. 

This Privacy Statement covers the following topics:

 

Information We Collect Online

We collect Personally Identifiable Information from you through your use of the Sites and Services. “Personally Identifiable Information” is individually identifiable information about an individual consumer that we collect online and that we maintain in an accessible form. We collect the following types of Personally Identifiable Information:

Information You Provide

We may collect the following Personally Identifiable Information that you voluntarily provide to us in using our Sites and Services:

  • Applications. If you apply for one of our financial products or services, such as applying for a credit card, bank account or mortgage, we may collect, among other information, your first and last name, address, telephone number, Social Security number, and email address. In addition, we may collect other information such as your zip code, birth date, gender, salary range, education, marital status, occupation, industry of employment, personal and online interests.
  • Enrollment. If you enroll for one of our online banking services, we may collect, among other types of information, your first and last name, address, telephone numbers, email address social, security number, account number, and requested login ID.
  • Account. If you create an account for any of our Services, we will require you to establish a username and password.
  • Credit Card Information and Bank Account Information. We may, in certain instances, collect credit card and bank account numbers and related information when you request a product or service on our Sites. We will use the credit card or bank account information for the purpose of processing and completing the transaction you requested. Such information will be disclosed to third parties as necessary to complete the requested transaction. 
  • Mobile App. If you use our mobile banking application, we will collect your login and password information. We also will collect a device identifier.  
  • Careers. If you apply for a job, you will create an account and provide us with your name, email address, telephone number, country, and zip code. You will create a username and password for future logins. Additionally, you will be asked to provide other information such as a resume/CV. We use Symphony Talent, LLC (“Symphony”) to provide us with talent search services. Symphony will collect and process this information. Please review Symphony’s Privacy Policy here. 
  • Contact Us. When you send us any feedback, questions, comments, suggestions, ideas, or interact with us in any way through email or social media channels, we will receive your email address and any other Personally Identifiable Information that you may voluntarily provide.

Information as You Navigate Our Sites

We automatically collect certain Personally Identifiable Information through your use of our Sites and Services, such as the following:

  • Usage Information. For example, the pages on the Sites you access, the frequency of access, and what you click on while on the Sites.
  • Device Information. For example, hardware model, operating system, application version number, and browser.
  • Mobile Device Information. Aggregated information about whether the Sites are accessed via a mobile device or tablet, the device type, and the carrier.
  • Location Information. Location information from Site visitors on a city-regional basis.

Third Party Information

We may receive certain Personally Identifiable Information from you about a third party. For example, as part of applying for an account, you may provide the name, date of birth, and address of a third party. If you submit any Personally Identifiable Information about another individual to us, you are responsible for making sure you have the authority to do so and to allow us to use their Personally Identifiable Information in accordance with this Privacy Statement.

How We Use Your Information

We use the Personally Identifiable Information we collect to provide the Services to you, to improve our Sites and Services, and to protect our legal rights. In addition, we may use the Personally Identifiable Information we collect to:

  • Contacting you Via Mobile Device. You expressly consent to receiving communication from us, our affiliates and agents at any telephone number associated with a mobile telephone or device. Such communications include but are not limited to pre-recorded or artificial voice messages, calls, text messages, email messages, and calls made or using automatic telephone dialing systems. Calls or messages may incur fees from your mobile service provider. You further agree to receive commercial email messages at such email address from us, our vendors or advertisers (unless and until you have elected not to receive such commercial messages by following the instructions provided under "CHOICES ABOUT YOUR INFORMATION" below). You understand that your wireless carrier’s standard rates apply to communications you receive via your mobile device. You represent that you are the owner, or authorized user of the mobile device on which communications will be received, and you are authorized to approve the applicable charges.
  • Providing Services and Products. We use the information we gather on our Sites to provide you with the Services and or products you have requested. This may include passing your information on to a service provider to provide such services or products. Although our contractual arrangement limits how this party can use your information, we do not control the privacy practices of service providers. 
  • Customer Support Services. We will use the information to confirm your registration and complete transactions requested by you or verify information you have provided to us to assist you with any support services you request.
  • Identity Verification. We may use the information we gather on the website for identity verification purposes, for example, to text users a code that they must enter on the Site or Services to verify their identity when they sign on to their account. 
  • Careers. We use the information we gather on our Sites and with Symphony to process your job application.
  • Improving Our Internet Content and Services. We use the information we gather to respond to any inquiries you make, operate and improve the functionality of our Sites and Services, and deliver the products and services advertised on our Sites.  Our Services include the display of personalized products, content, and advertising, relating to your experience and interests.
  • Promotional Material. We will use the information to contact you when we have special offers or promotions.
  • Legitimate Business Purpose. We may use the information we gather on the website for any other legitimate business purpose, as permitted by law. We may also use the information for any other purpose for which we receive your specific consent. 
  • Other Purposes. We may use your information to (i) protect the security and integrity of our Sites and Services; (ii) investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our agreements, and to otherwise fulfill our legal obligations; (iii) monitor compliance with and enforce this Privacy Statement; and (iv) fulfill any other purposes for which you provide it, or any other purpose we deem necessary or appropriate.

How We Share Your Information

We do not disclose your Social Security number, credit card or banking information to third parties not assisting us with supplying your request for products or Services without your authorization. However, we may share the Personally Identifiable Information that we collect about you in the following ways:

  • Product and Service Delivery.  We share your information with vendors who help us in the delivery of the products and services you have requested.
  • Careers. We share your information with Symphony who helps us process your job application.
  • Platform Functionality. We share your information with companies and individuals we employ to perform technical functions on our behalf. Examples include service providers who host our website, build and support our mobile application, analyze our data, provide marketing assistance, process credit card payments, and provide customer service.
  • Anonymous Information. We share aggregated anonymous information about you, combined with other persons using our Sites with service providers, so that they can understand the kinds of visitors that come to our Sites, and how those visitors use those platforms. For more information, see the "COOKIES AND OTHER TRACKING TECHNOLOGIES" section below.
  • Legal Process. We disclose your information if legally required to do so, or at our discretion, pursuant to a request from a governmental entity, or if we believe in good faith that such action is necessary to (a) conform to legal requirements or comply with legal process; (b) protect our rights or property, or our affiliated companies; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public.
  • Acquisition or Merger. We may disclose and transfer your information to another entity who acquires any or all of our business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets or in preparation for these events. In the event we become the subject of an insolvency proceeding, whether voluntary or involuntary, we or our liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of, such information in a transaction approved by the court.
  • Corporate Family. We may share information within our corporate family, such as with subsidiaries, joint ventures, or affiliates, to the extent permitted by law.
  • With Consent. We may disclose your information to any other third-party with your consent. 
  • Other Purposes. We may disclose your information for any other purpose disclosed by us when you provide the Personally Identifiable Information or for any other purpose we deem necessary.

Where appropriate, we will limit sharing of your information in accordance with the choices you have provided us in response to our Privacy Notice.

Cookies and Other Tracking Technologies

Cookies

Like many other companies, we use cookies and other tracking technologies (such as pixels and web beacons). To learn more about how we use cookies and your choices regarding our use of cookies, please see our Cookie Policy.

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the Site and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website.  The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google, click here.

Google RECAPTCHA

We use Google reCAPTCHA, a free service provided by Google, Inc., to protect our Sites from spam and abuse. Google reCAPTCHA uses advanced risk analysis techniques to decipher humans and bots. Google reCAPTCHA works differently depending on what version is deployed. For example, you may be asked to check a box indicating that you are not a robot or Google reCAPTCHA may detect abusive traffic without user interaction. Google reCAPTCHA works by transmitting certain types of information to Google, such as the referrer URL, IP address, visitor behavior, operating system information, browser and length of the visit, cookies, and mouse movements. Your use of Google reCAPTCHA is subject to Google’s Privacy Policy and Terms of Use. More information as to Google reCAPTCHA and how it works is available here.

“Do Not Track Signals”

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, our Sites do not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.

Choices About Your Information

Wireless Addresses

If the email address you provide to us is a wireless email address, you agree to receive commercial messages at such address from us, our vendors or advertisers (unless and until you have elected not to receive such commercial messages by following the instructions in the unsubscribe portion of this Statement). You understand that your wireless carrier’s standard rates apply to these messages. You represent that you are the owner, or authorized user of the wireless device on which messages will be received, and you are authorized to approve the applicable charges.

Security

We endeavor to safeguard and protect your information. When you submit information on our Sites, such information is protected both online and offline. We have security measures in place to protect against the loss, misuse, and alteration of Personally Identifiable Information under our control.  Please be advised that, although we take commercially reasonable technological precautions to protect your data, no data transmission over the Internet can be guaranteed to be 100% secure; therefore, we cannot and do not warrant that your information will be absolutely secure. Any transmission of data at or through our Sites or Services is at your own risk. However, access to your information is strictly limited and not accessible to the public.

Third Party Links

The Sites may contain links that will let you leave the Sites and access another website. Linked websites are not under our control. Except as stated below, this Privacy Statement applies solely to Personally Identifiable Information that is acquired on the Sites. We accept no responsibility or liability for these other websites.

Children's Privacy

The Site and Services are not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal information from children under 13.

Notice to California Residents

The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (CCPA) requires that we provide California residents with a privacy statement that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Statement is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this section does not apply to you and you should not rely on it.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.  Personal information does not include information that is publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this "Notice to California Residents" section we will refer to this information as “Personal Information.”

The CCPA’s privacy rights described below do not apply to Personal Information that we collect, process, sell, or disclose subject to the federal Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act. Because we are subject to those laws and regulations, much of the Personal Information that we collect is exempt from the CCPA. Your choices and rights with respect to our use and sharing of that information are subject to our Privacy Notice.

The CCPA’s privacy-related rights also do not apply to certain types of Personal Information that is subject to the federal Fair Credit Reporting Act (FCRA). Some of our services are subject to the FCRA and, therefore, exempt from the CCPA on that basis.

Notice at Collection of Personal Information

We currently collect and, in the 12 months prior to the Last updated date of this Privacy Statement, have collected the following categories of Personal Information:

  • Identifiers (name, postal address, online identifiers, internet protocol address, social security number, driver’s license number, account name, and email address)
  • Unique personal identifiers (cookies, beacons, pixel tags, or other similar technology; customer number)
  • Telephone number
  • Signature
  • Bank account number
  • Commercial information (records of personal property, products or services purchased, obtained or considered)
  • Other financial information
  • Biometric/Fingerprint (collected by your phone when using our app, but not by us)
  • Employment information
  • Characteristics of protected classifications under California or federal law (gender, sex, age (40 and older), and military/veteran status)

We collect Personal Information directly from California residents and service providers. We do not collect all categories of Personal Information from each source.

In addition to the purposes stated above in the section “COLLECTING AND USING INFORMATION” we collected the above Personal Information for the following business or commercial purposes:

  • Auditing related to counting ad impressions to unique visitors
  • Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
  • Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling order and transactions, providing financing, providing analytics services
  • Enabling or effecting, directly or indirectly, a commercial transaction

Disclosure of Personal Information

The following is a list of categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Last updated date of this Privacy Statement and, for each category, the categories of recipients to whom we disclosed Personal Information.

  • Name (business partners, recruitment and talent acquisition service providers)
  • Postal Address (business partners, recruitment and talent acquisition service providers)
  • Email address (recruitment and talent acquisition service providers)
  • Telephone number (business partners, recruitment and talent acquisition service providers)
  • Gender (business partners)
  • Employment information (recruitment and talent acquisition service providers)
  • IP address (business partners and data analytics providers)
  • Cookies, beacons, pixel tags, or other similar technology (data analytics providers (Please see “Cookies and Other Tracking Technologies” section above for further information as to our use of cookies))

We disclosed Personal Information for the following business or commercial purposes:

  • Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
  • Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling order and transactions, providing financing, providing analytics services
  • Enabling or effecting, directly or indirectly, a commercial transaction

We have not sold or shared Personal Information in the 12 months preceding the Last updated date of this Privacy Statement. We do not knowingly collect, sell, or share the Personal Information of minors under 16 years of age. We do not use Sensitive Personal information for purposes other than those the CCPA and its regulations allow for.

Retention of Personal Information

We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.

Your Rights

If you are a California resident, you have the following rights with respect to your Personal Information:

  • The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling, or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
  • The right to delete Personal Information that we collected from you, subject to certain exceptions;
  • The right to correct inaccurate Personal Information that we maintain about you;
  • If we sell or share Personal Information, the right to opt out of the sale or sharing;
  • If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
  • The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.

How to Submit a Request to Know, Delete, and/or Correct

CREDIT CARD: If you have a First PREMIER Bank credit card or provided personal information in relation to a First PREMIER Bank credit card, please submit your request through our interactive webform available at https://connect.mypremiercreditcard.com/Home/CCPA or by calling us at 1-877-635-2568.

OTHER BANKING RELATIONSHIPS: If you have provided personal information in relation to any First PREMIER Bank account other than a credit card account, such as a checking, savings, loan, mortgage or trust account, please submit your request through our interactive webform available at https://www.firstpremier.com/ccpa or by calling us at 1-800-501-7547.

If you submit a request to delete online, you may be asked to confirm separately that you want your Personal Information deleted.

If you have both a credit card and a non-credit card relationship with First PREMIER Bank, please submit your request to know for each relationship separately as described above.

As mentioned above, if you are a California resident who has a financial product or service with us, much of the Personal Information that we collect is exempt from the CCPA and, therefore, is not subject to the rights discussed in this “Notice to California Residents” section. Your choices and rights with respect to our use and sharing of that information are subject to our Privacy Notice.

If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, and if the request is not subject to an exemption or exception, we will require additional information to verify your authority to act on behalf of the California resident.

Our Process for Verifying a Request to Know, Delete, and/or Correct

If we determine that your request is subject to an exemption, we will notify you of our determination. If we determine that your request is not subject to an exemption, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a password-protected account with us.

If you maintain a password-protected account, we may verify your identity through existing authentication practices available through your account. Prior to disclosing the requested information, we will ask you to re-authenticate yourself with respect to that account.

If you do not maintain a password-protected account, or if you are an account holder but we suspect fraudulent or malicious activity with your account, we will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable.

For requests to access categories of Personal Information and for requests to delete or correct Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities. 

For requests to access specific pieces of Personal Information or for requests to delete or correct Personal Information that is sensitive and poses a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information you previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you must submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

Right to Opt-Out of Sale or Sharing of Personal Information

If you are a California resident, you have the right to direct businesses to stop selling or sharing your Personal Information. We do not sell or share Personal Information as it is defined in the CCPA.

Accessibility

We are committed to ensuring this Privacy Statement is accessible to individuals with disabilities. If you wish to access this Privacy Statement in an alternative format, please contact us as described below.

How to Contact Us

To contact us for questions or concerns about our privacy policies or practices please contact us via any of the following methods:

In writing:
First PREMIER Bank
500 S. Minnesota Avenue
Sioux Falls, SD 57104

By phone: 1-800-501-7547

By email: deposit.services@firstpremier.com

 

 

 

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