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CCPA Notice at Collection
NOTICE AT COLLECTION
We are required to provide California residents with timely notice, at or before the point of collection, about the categories of personal information to be collected from you and the purposes for which the personal information is collected or used. For example, upon receiving the Notice at Collection, you can use the information in the notice as a tool to choose whether to engage with us, or to direct us not to sell or share your personal information and to limit the use and disclosure of your sensitive personal information, if applicable. We will not collect additional categories of personal information or use personal information collected for additional purposes that are incompatible with the disclosed purpose for which the personal information was collected without providing you prior notice. Our privacy policy can be found at www.keystone.bank/privacy.
Categories of Personal Information. The following categories of personal information are to be collected:
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers
Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her 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.
Characteristics of protected classifications under California or federal law, Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an internet website application, or advertisement
Geolocation Data
Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information Professional or Employment-Related Information
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act
Inferences drawn from any of the information to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We will retain each category of personal information for the length of time that we intend to retain each category of Personal Information will depend on a number of criteria, including (i) the length of time we are required to retain Personal Information in order to comply with applicable legal and regulatory requirements, (ii) the length of time we may need to retain Personal Information in order to accomplish the business or commercial purpose(s) for which such Personal Information is collected, used or disclosed (as indicated in this Notice), and (iii) whether you choose to exercise your right, subject to certain exceptions, to request deletion of your Personal Information.
Purpose for collection: We only use or disclose Sensitive Personal Information for the following purposes consistent with CCPA Regulations:
To perform the services or provide the goods reasonably expected by an average California resident who requests those goods or services. For example, a California resident's precise geolocation may be used by a mobile application that is providing them with directions on how to get to a specific location.
To detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted Personal Information, provided that the use of a California resident's Personal Information is reasonably necessary and proportionate for this purpose. For example, we may disclose a California resident's account information to a data security company that is hired to investigate and remediate a data incident that involved that individual's account.
To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions, provided that the use of a California resident's Personal Information is reasonably necessary and proportionate for this purpose. For example, we may use information about a California resident's ethnicity and/or the contents of email messages to investigate claims of racial discrimination.
To ensure the physical safety of natural persons, provided that the use of a California resident's Personal Information is reasonably necessary and proportionate for this purpose. For example, we may disclose a California resident's account information to law enforcement, when required by law, to investigate financial elder abuse.
For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a California resident's current interaction with us. To perform services such as maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying a California resident's information, processing payments, providing financing, analytic services, or storage.
To verify or maintain the quality or safety of a service or device that is owned, manufactured by, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by us.
CCPA Policy
Collected Personal Information
Categories of Personal Information. We collected the following categories of personal information in the preceding 12 months:
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers
Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her 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.
Characteristics of protected classifications under California or federal law
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an internet website application, or advertisement
Geolocation Data
Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information
Professional or Employment-Related Information
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act
Inferences drawn from any of the information to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
Categories of Sources. We collected your personal information from the following type of people or entities:
Direct from the consumer
Internet service providers
Data analytics providers
Government entities
Operating systems and platforms
Social networks
Business or Commercial Purposes. We collected your personal information for these business or commercial purposes: Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes
Debugging to identify and repair errors that impair existing intended functionality
Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer's current interaction with the institution, provided that the consumer's personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer's experience outside the current interaction with the institution
Performing services on behalf of the institution, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the institution
Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer provided that, for the purpose of advertising and marketing, a service provider or contractor shall not combine the personal information of opted-out consumers that the service provider or contractor receives from, or on behalf of, the business with personal information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with consumers
Undertaking internal research for technological development and demonstration
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business
How to Submit A Request Regarding Your Personal Information
You can submit to us a verifiable request to know, request to delete, or request to correct your personal information. We will verify that you are the person who we have collected information about by Keystone Bank will follow CCPA regulations when verifying the identities of individuals submitting data access and deletion requests.. No later than 10 business days after receiving your request(s), we will confirm that we received your request(s) and provide you with information on how we will process your request(s). We will respond to your request to know, request to delete, or request to correct no later than 45 calendar days after receiving your request(s). Ifwe cannot verify your identity within this time period, we may deny your request(s) in whole or in part and will inform you that your identity cannot be verified. Ifwe need more time, we will inform you of the reason for the delay during this time period and may extend the time to respond up to an additional 45 calendar days. Our response will cover the 12-month period preceding our receipt of your request.
You can submit your request to know, request to delete, and request to correct by calling us toll-free at (888) 266-9709. You can also submit your request(s) by using any of the following methods:
Visiting our online form at: www.keystone.bank/ccpa
Authorized Agents. We may allow an authorized agent to make a request to know, request to delete, or request to correct on your behalf. We may require written proof that you have given the agent permission to submit a request on your behalf, require the agent to verify their identity with us, or require you to confirm with us that you have provided the agent permission to submit the request. If you are an authorized agent, you may make these requests by following these instructions: For individuals submitting a request on behalf of another person, we may require proof of authorization and verification of identity directly from the person for whom the request is made.
For a company or organization submitting a request on behalf of another person, we may require proof of authorization from the individual such as a Power of Attorney and verification of identity directly from the person for whom the request is made.
Contact Information
For information about our privacy policy and Information Practices, you can contact us by Phone: (888) 266-9709.
Should you have any questions about the information collected and stored about you at Keystone Bank, please complete the online form below, and we will help you.
IMPORTANT: Proper authentication is critical to ensuring the protection of personal information. Depending on the response to your request, you may be required to provide proof of identity before it can be fulfilled. We will respond to your request consistent with applicable laws.
