West Town Bank & Trust Privacy Notice for California Residents
Last Reviewed on: 02/01/2022
Information We Collect
As a financial institution, it is necessary for us to collect certain personal information from and/or about our clients in order to provide our products and services, fulfill consumer requests, to comply with the federal and state laws and other legal obligations. Below is a list of categories of data we may collect about our clients:
- Personal information (“information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household,” as defined in the CCPA)
- Demographic/Protected class information
- Biometric information (ex: voice recordings when you leave a voicemail for a WTBT agent)
- Commercial information
- Professional or employment-related information
- Education information
- Geolocation (ex: your IP address when visiting a WTBT website)
- Internet or other electronic network activity information
- Audio, electronic, visual, thermal or olfactory information
- Personally identifiable health information
- Background/criminal record
- Marketing opt-out/preference information
- Inferences drawn from any of the above information
Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA's scope, like:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
WTBT obtains the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase;
- From publicly accessible sources (e.g. property records);
- Directly from a third party (e.g. sanctions screening providers, credit reporting agencies, or customer due diligence providers);
- From a third party with your consent (e.g. your bank).
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
WTBT will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes.
Sharing Personal Information
WTBT may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, it is explicitly known to keep all personal information confidential and not use it for any purpose except performing the related business.
The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.
We share your personal information with the following categories of third parties:
- Service providers.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months WTBT has disclosed the following categories of personal information for a business purpose:
- California Customer Records personal information categories
- Protected classification characteristics under California or federal law
- Professional or employment-related information
We disclosed your personal information for a business purpose to the following categories of third parties:
- Service providers.
Sale of Personal Information
In the preceding twelve (12) months, WTBT has not sold personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request, free of charge, that WTBT disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that WTBT delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request we will delete (and direct our service providers to delete) your personal information from our records unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Emailing firstname.lastname@example.org
- Filling out an online form at wtbt.com.
- Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com or complete the online contact us form at wtbt.com
Changes to Our Privacy Notice
WTBT reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this notice, the ways in which WTBT collects and uses your information described below, and in the Privacy Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Website: www. wtbt.com
West Town Bank & Trust
Attn: Compliance Dept.
7820 West 26th Street
North Riverside, IL 60546
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