Effective Date: April 29, 2005
First National Bank in Port Lavaca recognizes the importance our customers place on the privacy and security of their personal information. Our goal is to protect your personal information in every way that we interact with you, whether it's on the telephone, in our lobby, at one of our ATMs, or on the Internet.
We think it is important for you to be informed of the policies, procedures, and security measures we have in place to safeguard your personal and confidential information. With that in mind, we have developed this policy to help you to understand the steps we take to protect your personal information when you utilize our Internet services.
This institution may utilize the services of third party providers to assist us in providing online services, such as website hosting, Internet banking, bill payment, and aggregation services. These third party providers are referred to within this policy as "service providers".
Information Collected on the Internet
If you are just browsing through our website, we do not request any personally identifiable information, nor do we collect unique identifying information about you unless you voluntarily and knowingly provide us that information, such as when you send us an email or complete an application online. If you provide us this information, it is only used internally and in furtherance of the purpose for which it was provided.
As part of providing online financial products or services, we may obtain information about our customers and website visitors from the following sources:
- Information we receive from you on applications, emails, or other forms;
- Information you provide when you choose to customize our website;
- Information about your transactions with this institution and our affiliates;
- Information we receive from a consumer-reporting agency; and
- Information that is generated electronically when you visit our website; and
- Information that is generated electronically when you use our Internet banking services.
Service providers hosting our website and our Internet banking service may collect general information on our website visitors simply to help us provide banking and other financial services to you online. They collect the following information on our behalf for security and statistical purposes:
- The Internet address (referral site) which brought you to our web site;
- The date and time you access our site;
- The name and version of your web browser;
- The Internet service provider you used when you accessed our site;
- Your Internet Protocol (IP) address; and
- The pages visited in our website.
Additional information about IP addresses and cookies are provided below.
Internet Protocol (IP) Addresses
An IP address is a number that is automatically assigned to your computer whenever you are on the Internet. Web servers, the computers that "serve up" web pages, automatically identify your computer by its IP address. When collecting information for us, our service provider does not link IP addresses to anything personally identifiable; however, this Institution and its service providers may use IP addresses to audit the use of our site. We can and will use IP addresses to identify users when necessary for security purposes.
What is a Cookie?
A cookie is a very small text file sent by a web server and stored on your hard drive, your computer's memory, or in your browser so that it can be read back later. Cookies are a basic way for a server to identify the computer you happen to be using at the time. Cookies are used for many things from personalizing start up pages to facilitating online purchases. Cookies help sites recognize return visitors and they perform a very important function in secure Internet banking.
Internet Banking Cookies
Our Internet banking product uses encrypted cookies that do not pass to your computer's hard drive. Instead, the cookie is stored in your computer's memory, identifying only your computer while you are logged on. Only our service provider can read the information in these cookies. The Internet banking cookie facilitates the processing of multiple transactions during a session without requiring you to reenter your passcode for each individual transaction. The cookies for Internet banking simply provide another level of security for our Internet banking product. When you log off, or close your browser, the cookie is destroyed. A new cookie is used for each session. That way, no one can use the prior cookie to access your account. For additional security, the cookie expires after 10 minutes of inactivity. It must then be renewed by reentering your passcode. We do not (and cannot) use this cookie to collect or obtain new personal information about you. You must allow your browser to accept this cookie so you can use the Internet banking product.
When you register on our website and select the "Remember Me" checkbox, our service provider sends a cookie to your hard drive, which enables you to customize the website and bypass the login process each time you revisit. These cookies are retained on your computer until you either delete them or click on the logout link within the website. These cookies only contain a unique user identification number and do not contain or collect any personally identifiable information.
When registered users login to the website, our service provider may also send cookies called "per-session" cookies or "server-side" cookies. These cookies reside in the browser and are only used to monitor the session by a unique identification number. These cookies are used for security purposes and you must allow your browser to accept these cookies in order to use the website. These cookies are destroyed after eight hours.
When you click on advertisements in our website or advertisements on linked 3rd party web sites, you may receive another cookie. You do not have to accept these cookies to visit the website.
Use of Information Collected
- We do not disclose any non-public personal information about our customers, former customers, website visitors to anyone, except as permitted or required by law.
- In order to provide online services such as: Internet banking and bill payment, we must disclose certain customer account information to our service providers.
- We do not sell any of your personal information.
- We will not disclose any medical information that you provide to us, unless you specifically authorize its disclosure.
If you send us an email, please do not include any non-public personal or sensitive information, as email messages may not be secure and/or confidential. We offer secure messaging through our Internet Banking service. You should use the secure messaging service anytime you send us sensitive personal information.
External 3rd Party Links
Our website may include numerous links to other 3rd party sites. These links to external third parties are offered as a courtesy and a convenience to our customers. When you visit these sites, you will leave our website and will be redirected to another site.
This financial institution does not control linked 3rd party sites. We are not an agent for these third parties nor do we endorse or guarantee their products. We make no representation or warranty regarding the accuracy of the information contained in the linked sites. We suggest that you always verify the information obtained from linked websites before acting upon this information.Also, please be aware that the security and privacy policies on these sites may be different from our policies, so please read third party privacy and security policies closely.
This Institution and its service providers have developed strict policies and procedures to safeguard your personal information. We restrict employee access to your sensitive personal information on a "need to know" basis. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information. We educate our employees about the importance of confidentiality and customer privacy. We take appropriate disciplinary measures to enforce employee privacy responsibilities.
Our Internet banking service provider, has developed a top-of-the line security system to ensure your customer information is protected on the Internet and within the data center environment.
Privacy of Children
This financial institution respects the privacy of children. We do not knowingly collect names, emails addresses, or any other personally identifiable information from children. We do not knowingly market to children, nor do allow children under 18 to open online accounts.
Additional Instructions for Privacy Policies:
Fair Credit Reporting Act
If your financial institution discloses certain customer information collected online with your affiliates (other than your own experience and transactional information), you should detail what type of information your institution shares with its affiliates, such as information from a credit report or information from a consumer's loan application. You should also detail the types of affiliate companies with which you share such information and you must also give your customers an opportunity to "opt-out".
If your financial institution only shares its own transactional information, an opt-out notice may not be required; however, the FCRA was recently amended. Implementing regulations are still pending as of 12/18/03. Please consult your compliance officer for guidance in this area. A sample notice is provided below.
The COPPA and the Federal Trade Commission's (FTC) implementing regulations (16 CFR 312) apply to financial institutions that operate commercial websites or online services that are directed to children and that knowingly collect personal information from children under the age of 13.
If your website site has special promotional accounts and/or services directed at children and you knowingly collect information from children under 13, you should comply with COPPA. Please refer to our support site for additional guidance on the regulation and consult your compliance officers and attorney. The FTC website also has good resources on how to comply, see www.ftc.gov/kidzprivacy.
First Data does not and will not provide legal advice or opinions to financial institutions regarding Privacy matters. This template is designed solely to assist financial institutions in preparation of privacy policies and includes specific information relative to the collection of information by First Data. First Data makes no warranties or representations about the accuracy or completeness of this information, and First Data will not be responsible for any actions or decisions by any financial institution based on this information.