Online Privacy Notice

Last Updated: August 31, 2022

 

This Notice describes the digital privacy practices of Battle Bank and applies to anyone who interacts with us through Battle Bank websites, emails, and social media (“Digital Channels”). It explains how we may collect information from you through our Digital Channels and how we protect and use that information. 

 

The information that you provide to Battle Bank (or that we otherwise receive) when you apply for or receive a product or service is governed by the Battle Bank Consumer Privacy Notice. 

 

Digital Information Collection

 

When you use our Digital Channels, Battle Bank collects information in several ways, including directly from you, automatically through cookies and similar technologies when you access and use our Digital Channels, and from third parties. We may collect information from some or all of these sources when you use our Digital Channels. 

 

The types of personal information we collect depend on how you interact with us. Below are examples of the types of information we collect from you when you interact with us in various ways and why we collect that information:

 

  • If you access or use our Digital Channels, Battle Bank collects and uses your IP address to help diagnose problems with its servers and to administer the website. Battle Bank uses your IP address and information transmitted from your computer to help identify your computer and browser as you move through our Digital Channels and to gather general information such as where your Internet Service Provider is located or the type of service that you have. In many cases, this allows Battle Bank to present a convenient, more customized experience to you.
  • When you access or use our Digital Channels, Battle Bank and our service providers automatically collect information from you through cookies and similar technologies. The information we collect includes information about which computers and browsers access our Digital Channels. Battle Bank and our service providers use the information we automatically collect through cookies for a number of reasons, including to provide you with access to our Digital Channels, deliver content specific to your interests, provide access to our secure banking functions, authenticate users, prevent, detect, and investigate fraud, assist with website traffic reporting (such as reporting unique visitor counts), provide client support, respond to your inquiries (including through the use of live chat or video session technologies), measure and report the level of engagement with Battle Bank advertisements across our Digital Channels and on other websites, and provide you with advertisements tailored to your interests (also known as “Targeted Advertising”). In some cases, the information collected from cookies will be combined with other personal information in order to provide you with Targeted Advertising. Some portions of the Battle Bank website use cookies to provide you with a secure environment for certain financial transactions. For more information about cookies used on our Digital Channels and any options you may have regarding our use of cookies, please see the “Cookies” section below.   
  • Battle Bank also collects information that you provide to us through your use of our Digital Channels and their features (including live chat or video sessions) to provide client support and to respond to your inquiries.
  • We also collect commercial and profile data through Battle Bank’s Digital Channels. Battle Bank uses this data to tailor its visitor digital experience, providing you with content that Battle Bank believes may be of interest to you and displaying content based on your preferences.
  • Battle Bank also collects the information you provide to us directly when you access and use our Digital Channels, such as information you provide when you fill out a form on our website, when you communicate with us, or when you otherwise voluntarily submit your information to us. 
  • Battle Bank may collect any other information you choose to provide, or that Battle Bank notifies you we will collect at the point of collection. 
  • We may also aggregate or de-identify information that we collect about you. Once information is aggregated or de-identified so that it no longer identifies or relates to an individual consumer or household, it is no longer considered personal information. 

 

Information Disclosure

 

We may disclose information that we collect from you when you use our Digital Channels with third parties according to the terms described in our Consumer Privacy Notice.  We share information as follows and as otherwise described in our Consumer Privacy Notice:

 

  • With service providers, vendors, and consultants who carry out work on our behalf and who need access to your information in order to carry out their work for us. These third parties are contractually obligated to keep the information confidential and to only use it to provide the services we have asked them to perform;
  • In response to a request for information if we believe disclosure is advisable or required, including to comply with any law, legal process, or a request by public authorities or third parties such as a subpoena, search warrant, court order, or other requests; 
  • To investigate actions we believe are inconsistent with our agreements or policies, or to protect the rights, property, and safety of Battle Bank or others;
  • In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company;
  • With your consent or at your direction.

 

We may also share aggregated or de-identified information which cannot reasonably be used to identify you. 

For a description of how Battle Bank may share information collected from consumers who have applied for or obtained a consumer product or service from us, please refer to our Consumer Privacy Notice.

 

Cookies

 

As mentioned above, Battle Bank and our service providers use cookies and similar technologies to automatically collect information from you when you use our Digital Channels. Cookies are small text files or text identifiers that are placed on your computer, smartphone, or other devices you use to access the internet when you visit a website.  When we use the term “cookies” in this policy, we also mean similar technologies such as pixel tags, clear GIFs, web beacons, and other similar technologies that automatically collect information from you when you visit a website. For more information about cookies generally, visit allaboutcookies.org. 

 

Battle Bank uses the following categories of cookies on our Digital Channels:

 

  • Preference. These cookies allow us to remember any settings you enable or choices you make on our website so that you do not have to make these choices each time you use our Digital Channels.
  • Advertising. These cookies allow us to provide you with advertising about our products, including targeted advertising based on your preferences or personal information. 
  • Analytics. These cookies assist us with learning more about how users and visitors use our websites, including pages visited, how much time is spent on each page, and similar information.
  • Authentication. These cookies assist us with authenticating Digital Channel user and visitor requests, and with maintaining session information related to users. 
  • Functionality. These cookies help us ensure that the Digital Channels function properly.
  • Security. These cookies allow our servers to mitigate the risk of information leakage attacks by ensuring that requests are submitted to our websites from proper domains.
  • Third-Party. These cookies are placed by our service providers. 

 

The information we collect through cookies allows us to keep track of you as you move through our Digital Channels. The service providers we utilize may also use these technologies to keep track of you as you move through our website and third-party websites that have a business relationship with our service providers.  Many of our service providers who use cookies and similar technologies to collect information about your online activities for the purposes of Targeted Advertising, ad measurement, and reporting, on both our website and third-party websites with which they have a business relationship, offer you the ability to opt-out of that collection of your information. For more information about how to opt-out of such collection, please visit aboutads.info/choices. We do not currently respond to web browser “do not track” signals; if we do so in the future, we will describe how we do so in the applicable Privacy Notice. For more information on do not track, visit allaboutdnt.org.

 

Most browsers are set to accept cookies by default. If you prefer, you can usually disable some or all cookies by adjusting the appropriate setting within your browser. This setting is often found in the “Help” section. Please note that certain features of our website may not function properly, or certain content on our website may not display to you meaning the functionality and availability of our website may differ if you restrict the use of cookies across our Digital Channels. We do not currently recognize “Do Not Track” signals. 

 

Public forums

 

Battle Bank’s Digital Channels may make chat rooms, forums, message boards, comment boxes, and/or news groups available to its users. Please remember before you post any personal information or other information in these forums that any information you choose to disclose in these areas becomes public information that may be read, collected, and obtained by anyone. Battle Bank is not responsible for content posted in public forums by third parties or users of Battle Bank’s Digital Channels. Battle Bank reserves the right to discontinue offering public forums at any time for any reason.

 

Links to Other Websites

 

When using our Digital Channels, you may encounter embedded content or links to other websites that are not affiliated with Battle Bank. We do not maintain the privacy programs or practices of these other sites. Accordingly, we encourage you to review the privacy notice, statement, or policy of each website you visit before you submit your personal information to them or visit the website.

 

Information security

 

Protecting your information is important to Battle Bank. Some examples of how Battle Bank protects your information include the following safeguards that Battle Bank applies to nonpublic personal information (NPI), as that term is defined and regulated under the Gramm-Leach-Bliley Act (15 U.S.C. § 6809(4)) include:

 

  • Restricting access to NPI to only those persons with a business need to know the information in order to process or service client account(s).
  • Contractually requiring third parties doing business with Battle Bank to comply with all applicable privacy and security laws.
  • Maintaining physical, electronic, and procedural safeguards that comply with applicable federal and state standards to safeguard NPI.

 

By using our online services, you acknowledge and agree that you will not, under any circumstances, disclose your Battle Bank Online Banking password by telephone or any other means to any person, including any person claiming to represent us. Of course, you may supply a security code to a Battle Bank representative if you have initiated the call to a number supplied by Battle Bank. No person from Battle Bank will ever ask you for your Battle Bank Online Banking password. You are responsible for all transactions made or authorized using your username or password. You agree that if you give your username or password to anyone or fail to safeguard their secrecy, you do so at your own risk.

 

Encrypted email

 

Encrypted email not only provides authentication but also protects your privacy. Encryption software “scrambles” the message so that only the intended recipient can read the message. Encrypted email often supports a digital signature with the same process. When combined, encryption and a digital signature allow you to obtain both authentication and privacy. Battle Bank encourages and supports the use of encrypted messages for communication with Battle Bank. Battle Bank banking account holders have access from within the Battle Bank Online Banking platform to an encrypted, secure web-based email system. That system will allow you to communicate via a secured channel with Battle Bank Client Specialists.

 

Fraud and other internet risks

 

Battle Bank maintains user authentication procedures to protect your personal information and account from identity theft. These procedures are for your protection. If you suspect a website is “spoofing” or pretending to be a Battle Bank website, do not enter personal information instead please contact us using any mechanism described in the “Contact Us” section below.

 

Information Retention

 

Battle Bank retains information only for as long as is reasonably necessary to fulfill the purpose for which it was collected. We also retain information in accordance with the laws regulating banking and financial services information retention and deletion practices. 

 

How to refuse communications

 

Battle Bank provides you with the opportunity to opt-out of receiving marketing communications from Battle Bank. If you do not wish to receive future marketing communications. If you do not wish to receive future marketing communications, you may contact us at privacy@battlebank.com, or by using the “unsubscribe” mechanism noted in the email.

 

You can refer to the Battle Bank Consumer Privacy Notice for more information on your right to request that we not share certain aspects of your information. Please contact privacy@BattleBank.com with any questions, or concerns, or to learn more about any rights you may have regarding our collection, sharing, or disclosure of your personal information.

 

Transfer of Information to the U.S. 

 

Battle Bank is operated out of the United States and offers our services to individuals in the United States and Canada. As such, we and our service providers will collect and maintain your information in the United States. If you choose to visit our website from outside of the United States, the jurisdiction from which you access our website may have different or more stringent, protections regarding personal information than the laws of the United States. By accessing our website, you consent to our processing of your information in the United States. 

 

Protecting children’s online privacy

 

Battle Bank encourages the protection of children’s information on the internet. Our services are not directed toward children under the age of 13. We will not collect personal information from children under 13 on our website without first obtaining consent from their parent or legal guardian. If you learn or suspect that we have collected information from a child under the age of 13 without obtaining the appropriate consent, please contact us so that we may take appropriate action. For more information about children’s privacy, including the Children’s Online Privacy Protection Act (COPPA), please refer to the Federal Trade Commission’s website.

 

Changes to this Notice

 

This Notice describes our current digital privacy practices. Battle Bank may change its digital privacy practices in the future, and we will update this notice when we make changes.  You may see the date this notice was last updated at any time by reviewing the “Last Updated” date at the top of this Notice. If we make material changes to this Notice, we will endeavor to provide you with more direct notice, such as through a notification on our website or by contacting you through your account or the last known email address we have on file, if we have this information about you. Unless otherwise stated, changes to this Notice are effective upon posting. Your continued use of Battle Bank’s Digital Channels following the posting of changes to these terms will mean that you accept those changes.