At Commencement Bank, we respect the privacy of our customers. Protecting your privacy and maintaining the confidentiality of your personal information is a high priority for us. This document describes the privacy principles and practices followed by Commencement Bank to fulfill our commitment to protect your nonpublic personal and financial information. This document also explains what types of customer information Commencement Bank collects and under what circumstances Commencement Bank may share it.
ACCURACY OF INFORMATION
Commencement Bank will take reasonable precautions to protect the accuracy and reliability of your account information. However, you are responsible for notifying us to update your account records from time to time to assure their accuracy; Commencement Bank will respond to your requests to update information on your account as quickly as possible.
CONFIDENTIALITY AND CUSTOMER INFORMATION SECURITY SAFEGUARDS
Commencement Bank maintains strict policies and security controls to assure that customer information in its computer systems and files is protected. Commencement Bank employees are permitted access to customer information that they may need to perform their jobs and to provide service to you, such as conducting a transaction or responding to your inquires. Employees may access customer information only for legitimate business reasons and are trained to respect customer privacy. Commencement Bank has also established internal security controls, including physical, electronic, and procedural safeguards to protect the information you provide to Commencement Bank and the information Commencement Bank collects about you.
CUSTOMER INFORMATION WE COLLECT
Commencement Bank collects only relevant information that is needed to establish and maintain customer relationships, accounts, and services as the law allows or requires us to collect. Commencement Bank may collect personal and financial information (i.e., customer information) about you which is “nonpublic.” The customer information Commencement Bank collects varies depending on the accounts and services you request and use.
Commencement Bank collects information about you from the following sources:
• Information we receive from you on applications or other forms and by telephone (such as your address, phone number, personal financial information, and employment)
• Information about your transactions with us (such as your account number, account balance, and account history)
• Information we receive from a consumer reporting agency (such as your credit score or credit usage)
• Information about you from third parties in order to verify information you have provided to us (such as new account verification)
• Information about you when you visit Commencement Bank’s website, www.commencementbank.com. (such as information you send by e-mail and internet banking transactions)
WHEN WE WILL SHARE INFORMATION
The information Commencement Bank shares falls into the following categories:
Sharing Information as Legally Required or Permitted
Commencement Bank may share customer information:
• In response to a lawful request issued by a court, government agency, or regulatory authority
• As permitted by law in order to administer or enforce your account
• Commencement may also share its experience information about you with credit bureaus and related reporting agencies.
Sharing Information with Nonaffiliated Third Party Service Providers
In order for Commencement Bank to conduct its operations, including servicing your account or processing your transactions, Commencement Bank relies upon certain nonaffiliated third party service providers and shares personal, account and transactional information with them. Nonaffiliated third party service providers include data processing companies; check, ATM, and other payment processing companies; payment networks; loan service providers; collection agencies and credit reporting agencies. These service providers act on Commencement Bank’s behalf and have agreed in writing to keep the customer information provided to them confidential. Commencement Bank shares the following categories of information to nonaffiliated third party service providers depending on the specific services provided:
• Personal information (name and address)
• Account information (account number, type of accounts, account balances, and transaction history)
• Transaction information (dates, amounts, locations, and type of transaction)
Sharing Information with Other Nonaffiliated Third Parties
Commencement Bank does not share any non-public personal information with nonaffiliated third parties except as permitted by law and described above. This means Commencement Bank will not sell customer information, share nonpublic personal information obtained from outside sources (such as a credit bureau), or share account information (such as account number, type of accounts, account balances, and transaction history) or other non-public personal information with any nonaffiliated third parties.
Sharing Information about former Customers
Information Commencement Bank may have about former customers is only shared or disclosed if necessary to enforce or administer an account or as required by law.
SUPPLEMENTAL PRACTICES RELATIVE TO ONLINE SERVICES
The following information pertains to the use of online services.
How Commencement Bank Handles E-Mail
Commencement Bank preserves the content of your e-mail, your e-mail address, and Commencement Bank’s response for a reasonable period of time, so that any follow-up questions you may have can be effectively handled. In addition, Commencement Bank may occasionally contact you at your e-mail address to inform you of potential benefits and the availability of particular products or services that might apply to your situation.
Inquires sent through Commencement Bank’s “Contact Us” link are not secure. Commencement Bank’s response back to you will not include confidential account information. You may also contact Commencement Bank by phone, U.S. postal mail, or by visiting Commencement Bank’s branch.
Protecting Your Online Banking
When you bank online, Commencement Bank and contracted third party service providers have access to your personal information. The information is retained on Commencement Bank’s system or the system of the appropriate service provider, depending on what is required in order to serve you. Commencement Bank uses state-of-the-art Internet technology, supported by service providers, to make online banking secure and to protect your personal information. Commencement Bank also requires your account number and a password as I.D. to access your accounts. If you do not provide this information, Commencement Bank cannot establish an online banking service for you. You can help maintain the security of your personal information by not sharing your I.D. or password with anyone, by changing your password regularly, and by remembering to sign off.
Use of “Cookies”
To measure web site activity and address security, Commencement Bank’s web site makes use of “cookie” technology. A “cookie” is a small text file placed on your hard drive by Commencement Bank’s web page server. “Cookies” are commonly used on web sites and do not harm your system. These “cookies” do not contain any customer information about you, and they cannot be used to capture your e-mail address, obtain data from your hard drive, or gain personal information about you. “Cookies” sent by Commencement Bank cannot be read by anyone other than Commencement Bank.
Commencement Bank collects standard non-identifying information about your visits to its web site such as date and time visited and IP address. Use of this information is restricted to compiling standard statistics that measure the use of the site. Commencement Bank’s information systems record certain information when you access your account information through the Internet Banking web pages, including transactions you conduct. This data enables Commencement Bank to process and confirm those transactions and minimize the potential for fraud. “Cookies” contain information that verifies the authenticity of Internet Banking requests and maintains continuity.
Commencement Bank’s Internet Banking also has a time-out feature. This feature automatically logs you out of your session after 20 minutes of inactivity (by use of a “cookie”). It is recommended, however, that you actually log off the system when you finish conducting your Commencement Bank business, instead of relying on this back-up security feature.
Protecting Your Children’s Information
The online services offered through Commencement Bank’s web site are not designed for or directed toward children under age 13. Commencement Bank does not knowingly solicit or collect data from children or knowingly market to children online without express parental consent or notification. If Commencement Bank receives online information from any child, it will only use the information to respond directly to a child’s request. Commencement Bank recognizes that protecting children’s identities and online privacy is important.
If you believe your child has provided personally identifiable information to Commencement Bank, please contact Commencement Bank so such information can be reviewed and deleted. Please call Commencement Bank at (253) 284-1800 or toll-free at (877) 284-1880 or sending an e-mail using the “Contact Us” link at www.commencementbank.com.
“Links” to Other Sites
Commencement Bank’s web site may contain “links” to other sites. If you use a “link” to visit the site of another company, Commencement Bank cannot be responsible for the privacy practices or the content of that company’s site. Accordingly, Commencement Bank recommends that you review the privacy policies/practices of each of the companies before you provide them with any personal and financial information about you.
COMPLAINTS
Because of Commencement Bank’s commitment to the confidentiality of your information, complaints relating to this policy or Commencement Bank’s perceived noncompliance with the policy should be forwarded directly to Commencement Bank’s Privacy Officer for prompt consideration. Commencement Bank’s Privacy Officer can be reached by calling (253) 284-1800, or sending an e-mail using the “Contact Us” link at www.commencementbank.com. Correspondence directed to Commencement Bank’s Privacy Officer should be addressed to:
Commencement Bank
1135 Broadway Plaza Suite 103
Tacoma, WA 98402
PRIVACY POLICY INQUIRIES
At Commencement Bank, trust has always been the foundation of our relationship with our customers. Since you trust us with your personal and financial information, we are committed to respecting your privacy. In order to preserve that confidence, Commencement Bank commits to protect your privacy by adhering to the practices described in this statement.
If you have any questions about Commencement Bank’s privacy practices, contact Commencement Bank by calling (253) 284-1800 or toll-free at (877) 284-1880, or sending an e-mail using the “Contact Us” link at www.commencementbank.com, or writing Commencement Bank, 1135 Broadway Plaza, Suite 103, Tacoma, WA 98402.
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