Privacy Policy

The collection, storage, and sharing of customer information is an important part of delivering useful banking products and services to consumers. To serve you, as a consumer, efficiently and conveniently, we have to make use of modern technology and customer information. But we know that you are concerned about privacy and our use of the information you give us. We are committed to an ongoing review of our procedures and policies in the interest of protecting your privacy. As a result, we have established the following privacy policy to provide guidance in our dealings with consumers.

We Recognize Your Expectation Of Privacy

We understand that you expect us to maintain proper safeguards to protect confidential information you provide to us. The privacy of your information is protected not only by state and federal laws but by our commitment to the protection of your financial information. We have established policies and procedures to help prevent misuse of that information. This Policy has been prepared to explain to you what types of information we collect, how we use that information, and the circumstances under which we may share all or part of the information. Under no circumstances do we provide deposit or loan account personal information to third parties for the purpose of independent telemarketing or direct mail marketing of any non-financial products or services of those companies. We disclose information permitted or required by a variety of federal and state laws, as required to consummate your transaction, and as directed by you. Our strict policies to protect your information applies equally to current (active) accounts as well as inactive (closed) accounts, both loans and deposits.

Our Policy

WE COLLECT, RETAIN, AND USE INFORMATION ABOUT YOU ONLY FOR LEGITIMATE BUSINESS PURPOSE AS REQUIRED BY LAW OR AS DIRECTED BY YOU.

We collect information about customers and consumers from many sources. Some information is provided to us by you, such as your social security number, income, employment, monthly expenses, and assets. Other information is created by us in the course of providing you with products and services. Some information comes from our experience of doing business with you, such as account usage or payment history. Additional information comes from outside third party sources, such as consumer credit reporting agencies and other lenders you have done business with. Some information is obtained at your request. We gather, use, and keep information about you only if we believe:

• • It is necessary or useful as part of our relationship with you.
• • It will serve your interests.
• • It will help us provide you with products and services meeting your needs.
• • It is required by law or regulation and federal or state regulatory agencies.

Sometimes, we gather or store or analyze data as the agent or service provider for another person, in which case that person decides what data is collected and how it will be used.
 
We retain customer information as required by federal and state regulations. This includes retaining some information after a loan or deposit account no longer exists. We exercise extreme care in protecting the sharing of this information.
 
We use this information we collect about our customers to :

• • Identify new products or services that may help us meet a customer’s needs or that may result in additional savings or convenience to consumers.
• • Positively identify our customers to protect their accounts and guard against unauthorized access to deposits or loan and deposit account                  information.
• • Help us identify and minimize potential risks for loss to Firstbank.

We Control The Disclosure And Use Of Account Information

Firstbank places internal restrictions on the disclosure of your account information. We limit the type of information shared and whom we share it with. We may share information concerning your account history, experiences with us, and other data to outside parties, such as another bank or clearinghouse, to process transactions on your account or loan, verify information that you provide to us, to obtain information concerning a particular transaction involving your account, loan, or deposit, or to perform any of our obligations to you. We may disclose information as permitted by any of our agreements with you, or as provided in any permission given by you to share information about you or your account. We may also share with third party providers of service or companies, in which our bank is acting as a broker or agent, certain information you have given us in connection with an application for one of our products or services, or information we have received from a consumer reporting agency or other third party. We do not reveal specific information about your accounts, or other personally identifiable data, to third parties we are not affiliated with for their independent use, unless:

• • The information is provided to help complete a customer transaction.
• • You request or authorize it.
• • The disclosure is made to a financial institution, reputable information reporting agency, merchant, or other person in accordance with standard             banking industry practice.
• • The disclosure is required or allowed by law.
  
  

In addition, sometimes it is necessary for us to disclose confidential customer information to third parties assisting us in the operation of our business, such as vendors and service companies we hire to provide services for us or to provide support for one of our products or services to you. Occasionally, we may decide to sell a particular part of our business, including the customer loan or deposit data, to someone else; we reserve the right to transfer the customer data in those instances.

We Disclose Information When Required By Law Or Regulation

There are many state and federal laws that require us to disclose information to various government entities. Some examples of these laws are the Bank Secrecy Act, the Internal Revenue Code, Equal Credit Opportunity Act, Flood Disaster Protection Act, and the Right to Financial Privacy Act. There are many other laws and regulations that require us, and our contractors and service providers, to disclose information. In addition, if you are involved in a legal proceeding, state and federal law provides that parties to the litigation have the right to subpoena and obtain records and information from us. In all these instances, we will disclose the information whenever required to do so by law, regulation, lawful judicial or administrative process, or court order.
 
As permitted by law, we routinely share customer information with reputable consumer reporting agencies (commonly known as credit bureaus) in accordance with standard banking industry practice and the Fair Credit Reporting Act. We disclose information that is otherwise permitted or required by a variety of federal and state laws, such as a court order or a subpoena for records. We do not disclose or share information about our customers or former customers to anyone except as permitted or required by law or as directed by you.

We Strive To Ensure That Our Records Are Up-To-Date And Accurate In Accordance With Commercial Standards

We are proud of our quality service to you, and if you find a mistake, let us know. This includes an error on your statement, checks ordered from us, your ATM or debit card, or other bank loan payoffs and teller errors. If you find an error in our information about you, please call us or write to us at the address or telephone number we have provided on your deposit or loan statement. We have procedures in place for maintaining and updating information about our customers. We also have procedures for timely correction of inaccurate information provided to us by you or third parties after we become aware of the inaccuracy. We will correct the error and credit your account for any changes imposed if the error is ours, and they will not be reported to a credit reporting agency or reflected negatively in your records.
 
In addition, various state and federal laws and federal and state regulatory agencies impose specific obligations and standards on us with respect to the collection of information, the accuracy of information we maintain and the correction of erroneous information.

If we do not approve an application for a product or service and have used a consumer credit report during the application process, we will give you the name and address of each credit reporting agency that gave us the consumer credit report, even if the report was not used in making our decision. You are entitled to free copies of reports from reporting agencies and to have the reports corrected by those agencies if they contain inaccurate information. If we deny a credit application for other reasons, we will tell you why or give you an opportunity to request the reasons.
 
If you are declined for an insurance policy such as credit life insurance and Firstbank is merely an agent for the carrier that actually provides the insurance, we will provide the information you need to contact the carrier that made that decision. You have a right to find out from the carrier whether a consumer report was used and/or why the application might have been declined.

We Have Policies And Procedures Addressing Employee Access To Information About You

We have procedures in place intended to limit employee access to personally identifiable information about you. Employee access to this information is limited to our employees who, because of their position or responsibilities, have a business reason to know or have access to such information. We educate our employees about the importance of confidentiality and customer privacy through training.

We Maintain Standards And Procedures Intended To Help Prevent Unauthorized Access To Information About You.

We have established internal security procedures and safeguards intended to prevent access to your confidential information by unauthorized persons. We periodically upgrade and test our technology and these security procedures and safeguards to enhance protection of your information and to ensure their integrity.

Privacy On Our Website

We are equally committed to protecting the privacy of customer information on the Internet. For information on our Internet security measures, please review the Online Banking Security section below.

Your Security And Protection While Online

It is of utmost importance for us to protect your personal information when you are on our website. We go to great lengths to make sure that your transactions are confidential and secure.

Your User ID And Password

The most important way of protecting your Online Banking transactions is with your self-selected User ID and Password. Be sure to keep them a secret. Memorize them, and if you need to maintain a written record of the codes, it is recommended that you store them away from your computer in a secure place and not in your wallet or purse. Always make sure that no one is watching you enter the information, and always log off the Firstbank website whenever you are away from your computer. If your computer is left unattended and the browser is running with your User ID and Passwords entered, anyone can gain access to your accounts. It is recommended that you change your Password often and do not use simple words or numbers in sequence. It is recommended that you use upper case and lower case numbers and letters and use symbols that are unique to you. Stay away from obvious words and numbers, like a family member’s birthday or name.

Encryption, Firewalls, And Other Protection

All personal and account information that passes between you and Firstbank is encrypted. This means that while your information is in transit, it is scrambled so that only the Firstbank’s computer equipment can reassemble it to its original text format. When Firstbank sends personal account information to you, it is also encrypted so that only your computer can decipher it and reconstruct the data transmitted.

There are also internal procedures in place within the Firstbank’s online banking system that include a system of filtering routers and firewalls. Filtering routers verify the source and destination of each transaction, while firewalls shield Firstbank’s customer service network from outside sources. These two systems protect Firstbank’s internal accounts from illegal outside access while keeping the structure of our internal networks invisible to outside observers.

Firstbank is continuously evaluating its security systems to ensure that we provide the highest levels of privacy and security that are appropriate for our customers.
 
To simplify your online experience with us, we may place a “cookie” on your personal computer while you are visiting our website. You have our assurance that we do not use cookies to record information that will enable anyone to contact you via telephone, e-mail, or regular mail.

Internet Privacy Frequently Asked Questions

What are cookies?

A cookie is a file sent from a website to your computer’s hard drive that is logged on to the site. This file allows the site to recognize whether the computer has been there before and what security requirements and browser preferences the computer requires. Only the site that sent the cookie can read the cookie, and only information that has been given directly by the logged on user to the site is accessible. Computer viruses cannot be transmitted through cookies.

Do I have to accept cookies?

You as a customer can choose not to accept cookies. You may do this by making the appropriate selection from your browser options. Please understand, however, that certain services require cookies for effective delivery. Whenever this is the case, you will be informed that you will need to allow cookies if you wish to receive the service. Cookies also make your visit to a site simpler by keeping you from having to re-enter your password every time you change pages within a secure session.

How secure is Internet banking?

Firstbank is committed to the security of all customer information. Internet banking users are required to select their own password, and all sessions are automatically logged off after 15 minutes of inactivity.

What is encryption and how is it used to protect my personal information?

Encryption is the scrambling of data into an unreadable form. Decryption is the reversal of that process. The data transmitted via Internet banking is encrypted using a code, or key, that is known only by the sender and the recipient. This ensures that no matter what path information takes on the Internet, it remains secure because only the intended recipient has the key to decrypt, or unlock the data.

What is a 128-bit encryption?

Since encryption works by scrambling data into an unreadable format using a code, or key, the longer the key, the harder it is to break. The number of possible combinations of a 128-byte key is 2 raised to the 128th power, or an astronomical number.

How do you know when my information is encrypted?

Your browser will display a closed lock icon or a completed picture of a key on the bottom of your screen whenever your information is encrypted.