Citizens State Bank of New Castle Digital Privacy Policy
This Digital Privacy Policy (“Policy”) describes how Citizens State Bank of New Castle and its subsidiaries (collectively, “Citizens,” “Citizens State Bank”, the “Bank,” “we,” “us,” “our”) collects and uses personal information when you visit, use, or interact with us through one of our “Sites.” When we use the word “Site” or “Sites” in this Policy, we intend for it to be interpreted broadly to include, without limitation: (i) any of our online or mobile banking applications (e.g., CSBI Mobile Banking); (ii) any Citizens State Bank website (e.g., https://www.mycsbin.com/); (iii) any Citizens State Bank branded social media site or page; and (iv) any current or future digital advertising campaign in which the Bank may engage.
This Policy also explains how we may use or share personal information collected through any of our Sites to deliver products and services to you, as well as for advertising purposes. 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 in accordance with our consumer Privacy Policy.
Agreement to the Terms and Conditions of this Policy
By using any of our Sites, you agree to the terms and conditions of this Policy as well as any disclosures, terms of service, end-user license agreements, or other agreements included on, or applicable to, each Site you visit or use. Where we have a presence on a site owned by a third party, such as a social media site, that third party’s privacy policy and terms of use will apply to the third party’s collection, use, and disclosure of data, unless we have specifically stated otherwise.
Types of Information We May Collect
Information that we may collect about you through our sites includes personal information that you input, such as your name, postal address, email address, and other information necessary to contact you; data resulting from transactions you enter into with us; the pages you visit on any of our Sites; location information; and biometric information, and behavioral characteristics, such as keystroke and mouse movement patterns. We may also collect additional information, such as the type of device and browser you are using; the IP address of your device; information about your device’s operating system; and additional information associated with your device. We may also collect information through cookies, tags, and other technologies.
Subject to receipt of any necessary permissions from you, we may access your camera and any photos, media or other files stored on your device for various purposes such as attaching a document to chat, adding a photo to your profile, adding an image to a transaction, and capturing images of a check being deposited.
What are cookies and how do we use them?
Cookies are pieces of information stored directly on your device. Cookies provide information that is used for security purposes, to facilitate navigation, to display information more effectively and to personalize/customize your online experience. When you visit one of our Sites, we, or our service providers, may use cookies or other similar technologies to collect information on our Site. Cookies may also be used to make offers to you via online ads, email, U.S. mail, or telephone, subject to the privacy preferences you have on file with us. We also use cookies for purposes such as maintaining continuity during an online session, collecting data about the use of our Sites, monitoring online promotions, and anti-fraud and information security purposes.
Other parties that may collect information about your web browsing behavior when you use one of our Sites are limited to service providers who may only use any information collected to provide services and marketing for us and not to provide services or advertising for any other party. We may also provide certain links on our Sites that allow you to interact with third parties who offer additional features, such as allowing you to share information on another platform. At other times, information from a third party may be embedded on our Site. These features may function through the use of third-party cookies and may enable such third party to access information about your interaction with our Sites.
Industry standards are currently evolving and we may not separately respond to or take any action with respect to a “do not track” configuration set in your internet browser.
Options to Manage Cookies
You may opt-out from our use of cookies and similar technologies that track your use of other sites for third party advertising. Websites such as https://optout.aboutads.info/ allow you to control the ads you see. In addition, you may also be able to set your browser to reject browser cookies. Setting your browser to reject or disallow cookies, may limit the functionality we can provide when you visit one of our Sites.
Additional Technologies
We, or our third-party service providers, may also use pixel tags, web beacons, SDKs, clear GIFs, and other current or future technologies for purposes such as measuring the effectiveness of our advertisements or other communications, determining viewing and response rates, and determining which offers to present to you on our own Sites or on third party sites. These interactions are collected using cookies and technical log files. We use the data for purposes that include interaction monitoring and visual replay for fraud, customer service, product improvement, and other purposes allowed by law.
Our Sites do not currently use “local shared objects” known as “Flash cookies”. Flash cookies, unlike browser cookies, are not stored in the browser and will not be deleted when you clear cookies from your browser. Flash cookies are generally used for the purposes of information security and fraud prevention. We reserve the right to implement Flash cookies at any time. In which case, you may be able to manage these Flash cookies by visiting the Adobe Website. If you choose to limit or disable Flash cookies, it may limit the functionality we can provide when you visit one of our Sites.
Using Information
In addition to the uses described above, we may use information for purposes as allowed by law such as: servicing; communicating with you; improving our Sites, products, or services; legal compliance; risk control; information security; anti-fraud purposes; marketing or personalizing the presentation of our products and services to you; tracking email access or website usage, such as number of hits, pages visited, and the length of user sessions in order to evaluate the usefulness of our Sites; to allow you to participate in surveys, contests, and similar promotions and to administer such promotions; to process applications for products or services; to review and process applications for employment with us and for recruiting purposes; or to verify your identity and/or location to allow access to your accounts, conduct online transactions and to maintain measures aimed at preventing fraud and protecting the security of account and personal information.
Disclosing Information
We may disclose information to service providers with whom we work, such as data processors and companies that help us market products and services to you. When permitted or required by law, we may disclose information to additional third parties for purposes including response to legal process. Please see our Privacy Policy for more information on how we may share information with affiliates and third parties.
Online Advertising
We advertise online and offline. In order to understand how advertising performs, we may collect certain information on our Sites and other sites and mobile apps through our advertising service providers. We use cookies from third-party partners for marketing purposes that allow us to display promotional material to you on other sites you visit across the internet. We may also share IP addresses and other technologies. The collected information may include the number of page visits, pages viewed on our Sites, search engine referrals, browsing activities over time and across other sites following your visit to one of our Sites, and responses to advertisements and promotions on the Sites and on sites where we advertise. We use such information to present tailored ads to you.
Relationship-Based Advertising
To help make our advertising informative and useful, we may use information about your relationship with us (such as types of accounts, transactional information or the city in which you bank) to help determine which advertisements or offers to present to you.
Online Behavioral Advertising
We or our advertising service providers may use certain information about your activities on our Sites and other websites, such as pages visited and search key words entered to help determine which of our advertisements or offers may be of interest to you. We limit access and collection of information for specific purposes by advertising service providers. We may use this online information for online and offline advertising.
Advertising on Third-Party Sites and Mobile Apps
We contract with advertising companies to advertise our products and services on sites and mobile apps not affiliated with us. These companies use non-personally-identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over, hardware/software information, cookies and session ID) and personally-identifiable information (e.g., static IP address) during your visits to this and other websites in order to provide advertisements about goods and services likely to be of greater interest to you or advertising-related services, such as ad delivery, reporting, attribution, analytics, and market research. These parties typically use a cookie, web beacon or other similar tracking technologies to collect this information. Third party sites and mobile apps are not subject to Citizens State Bank privacy notices. Please visit the individual sites and mobile apps for additional information on their data and privacy practices and opt out policies.
Social Media
We may participate in programs offered by various social media platforms, which enable us to display personalized ads to persons on our email list when they visit such platforms, respectively. We may provide personal information, such as your email address and phone number, to the social media provider to enable it to determine if you are a registered account holder. You may opt out of participation in this program by contacting us as at 888-529-5450. You may also opt out of receiving these ads from the social media network(s) directly.
You may set your advertising choices in the following ways:
Online Behavioral Advertising: If you prefer that we do not use information based on online site behavior to provide online and offline tailored content and advertising, you may opt out of online behavioral advertising. Opting out also means that the online content and advertising you receive on our non-servicing sites (i.e., before sign-in) will be untailored and may not be based on your online behavior or your relationship. Please note that if you opt out of this advertising, you may still receive untailored advertising from us. When accessing online account servicing areas (i.e., after sign-in), such as online banking, you may receive tailored content and advertising based on your account relationships.
Bank-managed Direct Marketing: If you prefer we not deliver you marketing offers in email, postal mail or through telemarketing, you may manage your direct marketing choices by telephone at 888-529-5450.
Important Reminder: For online behavior advertising opt outs from our Sites and on other sites to work on your device, your browser must be set to accept cookies. If you delete cookies, buy a new device, access our Site or other sites from a different device, login under a different screen name, or change web browsers, you will need to opt out again. If your browser has scripting disabled, you do not need to opt out, as online behavioral advertising technology does not work when scripting is disabled. Please check your browser’s security settings to validate whether scripting is active or disabled.
Linking to Other Sites
We may provide links to third party sites. This Policy does not apply to third party sites. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions, as they may differ from those of our Sites. For more information regarding links to other sites, see our Terms of Use.
Social Media Sites
We may provide experiences on social media platforms that enable online sharing and collaboration among users who have registered to use them. Any content you post on official Citizens State Bank managed social media pages, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms, is subject to the Terms of Use and Privacy Policies of those respective platforms. Please refer to them to better understand your rights and obligations regarding such content. In addition, please note that when visiting any official Citizens State Bank social media pages, you are also subject to any of Citizens State Bank’s terms and policies regarding social media. Whenever you visit a third-party website, you should review its privacy notice.
Aggregated Information and Digital Analytics
We collect information about your digital browsing experience through third-party analytics services for threat-monitoring and digital performance measurement. This information is not personally identifiable and is used in-aggregate to provide enhanced digital experiences. This information may include, but is not limited to the type of device being used, type of browser being used and type of operating system. We may use this aggregate and anonymous data for various business purposes, where permissible by law and regulations.
Security
To protect personal information from unauthorized access and use, we use security measures that comply with applicable federal and state laws. We will use reasonable organizational, physical, technical and administrative measures to protect personal information within our organization. These measures may include device safeguards and secured files and facilities security to ensure information remains confidential and secure. We maintain customer authentication procedures to protect your personal information and accounts from identity theft.
Using Other Aggregation Websites
Other companies offer aggregation websites and services that allow you to consolidate your financial account information from different sources (such as your accounts with us or with other financial institutions) so that you can view all of your account information at one online location. To do this, an aggregation provider may request access to personal information, such as financial information, usernames and passwords. You should use caution and ensure that the aggregation provider has appropriate policies and practices to protect the privacy and security of any information you provide or to which they are gaining access. We are not responsible for the use or disclosure of any personal information accessed by any company or person to whom you provide any Site username and password. If you provide any Site username, password, or other information about your accounts with us to an aggregation website, we will consider that you have authorized all transactions or actions initiated by an aggregation website using access information you provide whether or not you were aware of a specific transaction or action. If you decide to revoke the authority you have given to an aggregation website, we strongly recommend that you change your password for our Sites to ensure that the aggregation website cannot continue to access your account.
Making Sure Information is Accurate
Keeping your account information accurate and up to date is very important. If your account information is incomplete, inaccurate or not current, please use the “Contact Us” option on our Site or call or write to us at the telephone numbers or appropriate address for changes listed on your account statements, records, online or other account materials. You can also speak to a customer representative at one of our banking centers.
Protecting Children’s Privacy Online
Our Sites are not intended for use by or directed to individuals under the age of thirteen (13), and we do not knowingly collect personal information from such children without parental consent. We request that these individuals do not provide personal information through any of our Sites. Visit the Federal Trade Commission website for more information about the Children’s Online Privacy Protection Act (COPPA).
Accessing, Modifying or Deleting Your Information
In certain jurisdictions, you may have a right to access your personal data, correct inaccurate data, or delete your personal data. You may contact us directly to request access to, or modify or delete your information. You should be aware, however, that we may not be able to provide access to, modify, or delete your information in all circumstances.
Because certain of our Sites constitute banking applications under federal law and regulations, it would be a violation of law for us to delete your information. Under federal law, banks are required to implement customer identification programs and other measures in order to limit money laundering. These programs and other measures require banks to obtain and retain checking and savings account customer data, including contact, identification and tax information. FDIC and bank Secrecy Act regulations stipulate that banks must keep this information for at least five years after the account is closed.
Policy Updates and Effective Date
This Policy is subject to change. Please review it periodically. If we make updates or changes to this Policy, we will update the Policy with the changes and revise the “date of most recent update” posted at the top of this Policy. Any updates to the Policy become effective when we post the updates on the Site. To the extent permitted by applicable law, your use of the Site following the update to the Policy means that you accept the updated Policy.