California Privacy

Date last updated: December 27, 2020

This California Consumer Privacy Act Policy (“CCPA Disclosure”) supplements the information contained in any other Privacy Policy or Notice provided by Fremont Bank ("we" or "our”) and applies solely to residents of the State of California. It describes our practices both online and offline to comply with the California Consumer Privacy Act of 2018 (“CCPA”) regarding the collection, use, disclosure, and sale of personal information and the rights of California residents (“consumers” or “you”) regarding their own personal information.

Under the CCPA, “personal information”’ is information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular consumer. The specific personal information that we collect, use, and disclose relating to a consumer will vary depending on our relationship or interaction with that individual.

This CCPA Disclosure does not apply to information collected, processed or disclosed pursuant to the Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act. It also does not apply to information we collect of job applicants, employees, contractors, temporary employees, directors and shareholders, which are subject to our Human Resources CCPA Disclosure.

Your Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to request that we disclose what personal information we have collected, used, disclosed and sold about you during the past 12 months.

Only you or your authorized agent may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

Verifiable Consumer Request

You may only make a verifiable request twice within a 12-month period.To submit a verifiable consumer request to delete, you may submit to us by either:

Completing an online CCPA Request Form
Calling us toll-free at 1- 866-433-1469 Monday – Friday 8:00AM to 7:00PM and Saturday and Sunday 8:30AM to 5:00PM Pacific Time

The verifiable consumer request must:

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information such as name, date of birth, email address, telephone number, postal address, and your business relationship with Fremont Bank.
If you designate an authorized representative to make a request on your behalf, we may require you to verify your identity directly to us and provide a copy of the authorized written permission.

In order to verify your identity we will use the personal information provided in the verifiable consumer request. We cannot respond to your request if we cannot verify your identity or your authorized agent’s authority to make the request and confirm the personal information relates to you. We may require you, or your authorized agent, to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Collection of Personal Information

Below is a list of the categories of personal information we have collected about consumers in the past 12 months. For each category of personal information we have provided the categories of the sources used to collect, our business or commercial purpose for collecting the information, and the categories of third parties with whom we share personal information.

A. Identifiers

Illustrative Examples (Not all items listed in a particular category are collected)
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers

Category of Sources Used to Collect Information

Directly from a California resident or their authorized representatives
Public records (federal, state and local government agencies and departments)
Vendors, service providers, consumer data resellers and other third parties
Websites, Mobile app, and social media

Our Purpose for Collection

Auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this speciﬁcation and other standards.
Complying with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reﬂecting legal or regulatory guidance, codes or opinions).
Debugging to identify and repair errors that impair existing intended functionality.
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulﬁlling orders and transactions, verifying customer information, processing payments, providing ﬁnancing, providing advertising or marketing services, providing analytic services, or providing similar services.
Short-term, transient use where the information is not disclosed to a third party and is not used to build a proﬁle or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
Undertaking activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance the service controlled by the business.
Undertaking internal research for technological development and demonstration.

Category of Third Parties with Whom we Shared

Advertising networks, internet service providers, social networks
Law enforcement, regulatory and government agencies
Other Third Parties who enable customers to conduct transactions online and via mobile devices, support mortgage and fulfillment services, and aggregators (at the direction of the customer)
Partners and Third Parties who provide services such as payment, banking and communication infrastructure, storage, legal expertise, tax expertise, notaries and auditors, who promote the bank and its financial services and products to customers and other prospective buyers, and consumer data resellers
Vendors and Service Providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure, customer service, email delivery, auditing, marketing and marketing research activities including joint marketing partners

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Illustrative Examples (Not all items listed in a particular category are collected)
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Category of Sources Used to Collect Information

Directly from a California resident or their authorized representatives
Other financial institutions
Public records (federal, state and local government agencies and departments)
Transactional counterparties
Vendors, service providers, consumer data resellers and other third parties
Websites, Mobile app, and social media

Our Purpose for Collection

Complying with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reﬂecting legal or regulatory guidance, codes or opinions).
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulﬁlling orders and transactions, verifying customer information, processing payments, providing ﬁnancing, providing advertising or marketing services, providing analytic services, or providing similar services.
Undertaking activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance the service controlled by the business.

Category of Third Parties with Whom we Shared

Advertising networks, internet service providers, social networks
Law enforcement, regulatory and government agencies
Other Third Parties who enable customers to conduct transactions online and via mobile devices, support mortgage and fulfillment services, and aggregators (at the direction of the customer)
Partners and Third Parties who provide services such as payment, banking and communication infrastructure, storage, legal expertise, tax expertise, notaries and auditors, who promote the bank and its financial services and products to customers and other prospective buyers, and consumer data resellers
Vendors and Service Providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure, customer service, email delivery, auditing, marketing and marketing research activities including joint marketing partners

C. Protected classifications under California or federal law

Illustrative Examples (Not all items listed in a particular category are collected)
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)

Category of Sources Used to Collect Information

Directly from a California resident or their authorized representatives
Public records (federal, state and local government agencies and departments)
Vendors, service providers, consumer data resellers and other third parties
Websites, Mobile app, and social media;

Our Purpose for Collection

Complying with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reﬂecting legal or regulatory guidance, codes or opinions).
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulﬁlling orders and transactions, verifying customer information, processing payments, providing ﬁnancing, providing advertising or marketing services, providing analytic services, or providing similar services.
Undertaking activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance the service controlled by the business.

Category of Third Parties with Whom we Shared

Advertising networks, internet service providers, social networks
Law enforcement, regulatory and government agencies
Other Third Parties who enable customers to conduct transactions online and via mobile devices, support mortgage and fulfillment services, and aggregators (at the direction of the customer)
Partners and Third Parties who provide services such as payment, banking and communication infrastructure, storage, legal expertise, tax expertise, notaries and auditors, who promote the bank and its financial services and products to customers and other prospective buyers, and consumer data resellers
Vendors and Service Providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure, customer service, email delivery, auditing, marketing and marketing research activities including joint marketing partners

D. Commercial information

Illustrative Examples (Not all items listed in a particular category are collected)
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

Category of Sources Used to Collect Information

Directly from a California resident or their authorized representatives
Public records (federal, state and local government agencies and departments)
Vendors, service providers, consumer data resellers and other third parties
Websites, Mobile app, and social media

Our Purpose for Collection

Auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this speciﬁcation and other standards.
Complying with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reﬂecting legal or regulatory guidance, codes or opinions).
Debugging to identify and repair errors that impair existing intended functionality.
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulﬁlling orders and transactions, verifying customer information, processing payments, providing ﬁnancing, providing advertising or marketing services, providing analytic services, or providing similar services.
Short-term, transient use where the information is not disclosed to a third party and is not used to build a proﬁle or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
Undertaking activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance the service controlled by the business.
Undertaking internal research for technological development and demonstration.

Category of Third Parties with Whom we Shared

Law enforcement, regulatory and government agencies
Other Third Parties who enable customers to conduct transactions online and via mobile devices, support mortgage and fulfillment services, and aggregators (at the direction of the customer)
Partners and Third Parties who provide services such as payment, banking and communication infrastructure, storage, legal expertise, tax expertise, notaries and auditors, who promote the bank and its financial services and products to customers and other prospective buyers, and consumer data resellers
Vendors and Service Providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure, customer service, email delivery, auditing, marketing and marketing research activities including joint marketing partners

E. Biometric information

Illustrative Examples (Not all items listed in a particular category are collected)
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or Identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, or keystroke, gait, or other physical patterns, and sleep, health, or exercise data

Category of Sources Used to Collect Information

Directly from a California resident or their authorized representatives

Our Purpose for Collection

Performing services, including maintaining or servicing accounts, providing customer service, processing or fulﬁlling orders and transactions, verifying customer information, processing payments, providing ﬁnancing, providing advertising or marketing services, providing analytic services, or providing similar services.

Category of Third Parties with Whom we Shared

Other Third Parties who enable customers to conduct transactions online and via mobile devices, support mortgage and fulfillment services, and aggregators (at the direction of the customer)
Vendors and Service Providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure, customer service, email delivery, auditing, marketing and marketing research activities including joint marketing partners

F. Internet or other similar network activity

Illustrative Examples (Not all items listed in a particular category are collected)
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement

Category of Sources Used to Collect Information

Directly from a California resident or their authorized representatives
Transactional counterparties
Vendors, service providers, consumer data resellers and other third parties
Websites, Mobile app, and social media

Our Purpose for Collection

Auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this speciﬁcation and other standards.
Complying with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reﬂecting legal or regulatory guidance, codes or opinions).
Debugging to identify and repair errors that impair existing intended functionality.
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulﬁlling orders and transactions, verifying customer information, processing payments, providing ﬁnancing, providing advertising or marketing services, providing analytic services, or providing similar services.
Short-term, transient use where the information is not disclosed to a third party and is not used to build a proﬁle or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
Undertaking activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance the service controlled by the business.
Undertaking internal research for technological development and demonstration.

Category of Third Parties with Whom we Shared

Advertising networks, internet service providers, social networks
Law enforcement, regulatory and government agencies
Other Third Parties who enable customers to conduct transactions online and via mobile devices, support mortgage and fulfillment services, and aggregators (at the direction of the customer)
Partners and Third Parties who provide services such as payment, banking and communication infrastructure, storage, legal expertise, tax expertise, notaries and auditors, who promote the bank and its financial services and products to customers and other prospective buyers, and consumer data resellers
Vendors and Service Providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure, customer service, email delivery, auditing, marketing and marketing research activities including joint marketing partners

G. Geolocation data

Illustrative Examples (Not all items listed in a particular category are collected)
Device location and Internet Protocol (IP) location

Category of Sources Used to Collect Information

Directly from a California resident or their authorized representatives
Vendors, service providers, consumer data resellers and other third parties
Websites, Mobile app, and social media

Our Purpose for Collection

Complying with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reﬂecting legal or regulatory guidance, codes or opinions).

Category of Third Parties with Whom we Shared

Law enforcement, regulatory and government agencies
Vendors and Service Providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure, customer service, email delivery, auditing, marketing and marketing research activities including joint marketing partners

H. Sensory data

Illustrative Examples (Not all items listed in a particular category are collected)
Audio, electronic, visual, and similar information, such as call and video recordings, or thermal, and olfactory

Category of Sources Used to Collect Information

Directly from a California resident or their authorized representatives
Websites, Mobile app, and social media

Our Purpose for Collection

Complying with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reﬂecting legal or regulatory guidance, codes or opinions).
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulﬁlling orders and transactions, verifying customer information, processing payments, providing ﬁnancing, providing advertising or marketing services, providing analytic services, or providing similar services
Undertaking activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance the service controlled by the business.

Category of Third Parties with Whom we Shared

Law enforcement, regulatory and government agencies
Partners and Third Parties who provide services such as payment, banking and communication infrastructure, storage, legal expertise, tax expertise, notaries and auditors, who promote the bank and its financial services and products to customers and other prospective buyers, and consumer data resellers
Vendors and Service Providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure, customer service, email delivery, auditing, marketing and marketing research activities including joint marketing partners

I. Professional or employment-related information

Illustrative Examples (Not all items listed in a particular category are collected)
Current or past job history or performance evaluations - such as work history and prior employer

Category of Sources Used to Collect Information

Directly from a California resident or their authorized representatives
Public records (federal, state and local government agencies and departments)
Vendors, service providers, consumer data resellers and other third parties
Websites, Mobile app, and social media

Our Purpose for Collection

Complying with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reﬂecting legal or regulatory guidance, codes or opinions).
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulﬁlling orders and transactions, verifying customer information, processing payments, providing ﬁnancing, providing advertising or marketing services, providing analytic services, or providing similar services.
Undertaking activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance the service controlled by the business.

Category of Third Parties with Whom we Shared

Law enforcement, regulatory and government agencies
Other Third Parties who enable customers to conduct transactions online and via mobile devices, support mortgage and fulfillment services, and aggregators (at the direction of the customer)
Partners and Third Parties who provide services such as payment, banking and communication infrastructure, storage, legal expertise, tax expertise, notaries and auditors, who promote the bank and its financial services and products to customers and other prospective buyers, and consumer data resellers
Vendors and Service Providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure, customer service, email delivery, auditing, marketing and marketing research activities including joint marketing partners

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

Illustrative Examples (Not all items listed in a particular category are collected)
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records

Category of Sources Used to Collect Information

Directly from a California resident or their authorized representatives
Transactional counterparties

Our Purpose for Collection

Performing services, including maintaining or servicing accounts, providing customer service, processing or fulﬁlling orders and transactions, verifying customer information, processing payments, providing ﬁnancing, providing advertising or marketing services, providing analytic services, or providing similar services.

Category of Third Parties with Whom we Shared

Law enforcement, regulatory and government agencies
Vendors and Service Providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure, customer service, email delivery, auditing, marketing and marketing research activities including joint marketing partners

K. Inferences drawn from any information list above

Illustrative Examples (Not all items listed in a particular category are collected)
Profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Category of Sources Used to Collect Information

Vendors, service providers, consumer data resellers and other third parties
Websites, Mobile app, and social media

Our Purpose for Collection

Auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this speciﬁcation and other standards.
Complying with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reﬂecting legal or regulatory guidance, codes or opinions).
Debugging to identify and repair errors that impair existing intended functionality.
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulﬁlling orders and transactions, verifying customer information, processing payments, providing ﬁnancing, providing advertising or marketing services, providing analytic services, or providing similar services.
Short-term, transient use where the information is not disclosed to a third party and is not used to build a proﬁle or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
Undertaking activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance the service controlled by the business.
Undertaking internal research for technological development and demonstration.

Category of Third Parties with Whom we Shared

Advertising networks, internet service providers, social networks
Law enforcement, regulatory and government agencies
Other Third Parties who enable customers to conduct transactions online and via mobile devices, support mortgage and fulfillment services, and aggregators (at the direction of the customer)
Partners and Third Parties who provide services such as payment, banking and communication infrastructure, storage, legal expertise, tax expertise, notaries and auditors, who promote the bank and its financial services and products to customers and other prospective buyers, and consumer data resellers
Vendors and Service Providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure, customer service, email delivery, auditing, marketing and marketing research activities including joint marketing partners

Disclosure or Sale of Personal Information

In the past 12 months, we have not sold any personal information about consumers for a business or commercial purpose, nor do we intend to do so in the future.

We have disclosed personal information about consumers to third parties for a business or commercial purpose in the past 12 months. Below is a list of categories of information (from table above) we have disclosed for a business or commercial purpose:

A. Identifiers
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
C. Protected classifications under California or federal law
D. Commercial information
E. Biometric information
F. Internet or other similar network activity
G. Geolocation data
H. Sensory data
I. Professional or employment-related information
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))
K. Inferences drawn from any information list above

We do not sell the personal information of minors under 16 years of age without affirmative authorization.

Right to Request Deletion of Personal Information

You have the right to request we delete any personal information about you which we have collected or maintained.

Once we receive and confirm your verifiable consumer request we will delete your personal information from our records, unless an exception applies.

Only you or your authorized agent may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

Verifiable Consumer Request

You may only make a verifiable request twice within a 12-month period. To submit a verifiable consumer request to delete, you may submit to us by either:

Completing an online CCPA Request Form
Calling us toll-free at 1- 866-433-1469 Monday – Friday 8:00AM to 7:00PM and Saturday and Sunday 8:30AM to 5:00PM Pacific Time

The verifiable consumer request must:

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information such as name, date of birth, email address, telephone number, postal address, and your business relationship with Fremont Bank.
If you designate an authorized representative to make a request on your behalf, we may require you to verify your identity directly to us and provide a copy of the authorized written permission.

Right to Opt-Out of the Sale of Personal Information

You have the right to opt-out of the sale of their personal information. As stated above, we do not and will not, sell the personal information of consumers to third parties.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

Discrimination may exist where a business takes or suggests that it will take the following actions in response to a consumer exercising their rights under the CCPA:

Deny access to or use of goods or services.
Charge different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide a different level or quality of goods or services.

You have a right not to receive discriminatory treatment by us for exercising any of your privacy rights under the CCPA.

Authorized Agent

A consumer may designate an authorized agent to make a request under the CCPA on their behalf.

If you wish to have an authorized agent make a verifiable consumer requests on your behalf, they will need to provide us with sufficient written proof that you have designated them as your authorized agent.

An authorized agent is someone who has registered with the California Secretary of State to act on your behalf, or whom you have provided power of attorney pursuant to California Probate Code sections 4000 to 4465.

If your authorized agent makes a request on your behalf, we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information. However, 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 that the personal information relates to you.

Contact for More Information

If you have any questions or concerns about our privacy policies and practices, please call 1- 866-433-1469 Monday – Friday 8:00AM to 7:00PM and Saturday and Sunday 8:30AM to 5:00PM Pacific Time or email us at compliance@fremontbank.com.