Privacy Policy
What does CBB Bank do with your personal information?
To help you understand how CBB Bank protects your nonpublic personal information, this notice describes our current privacy policy and practices. This document outlines our privacy policy for visitors to our web site, as well as for consumers who have a continuing relationship with us, such as a deposit account, loan account, credit card, or safe deposit box.
You receive a Privacy Notice when you open an account or become a new customer of CBB Bank. Additionally, we provide you with updates whenever our Privacy Policy is changed as long as you remain an active customer. This notice explains how we handle and share your personal information, and tells you how you can act to limit the sharing of certain information within our corporate family of affiliated companies.
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Confidentiality
We believe the confidentiality and protection of customer information is one of our fundamental responsibilities. While the collection and use of information is critical to quality service, we recognize that one of our most important assets is our customers' trust. We will maintain standards to protect the privacy and security of your information, we will provide a summary of our policies and practices to you on a regular basis.
Security
We have policies in place that restrict access to nonpublic personal information about you to those employees who have a need to know that information (for example, to provide products or services to you). We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.
Visitors to Our Web Site
Visitors to our web site remain anonymous; unless they register for a service or otherwise elect to disclose their identity to us. Although we do not collect personally identifying information about persons who simply visit our site, we do collect certain limited information about visitors, such as their IP address (a numeric address assigned automatically to computers when they access the Internet). We also may place "cookies" on a computer to track a visitor's use of our web site. A cookie is a piece of data that is stored on your hard drive. It takes up very little room on your system and helps us to customize our site and make its navigation easier for you. We sometimes use cookies to help estimate the number of visitors to our site and to determine which areas are the most popular. Unless you register with us for a service (such as our On-Line Banking service), the cookie does not provide us with any personally identifying information about you, such as your name or address.
Information We Collect and Use
We collect nonpublic personal information about you in order to administer our business and provide you with products and services. We use the information to protect and administer your records, accounts, and funds; to communicate with you; to comply with applicable laws and regulations; and to help us design and improve our products and services. Nonpublic personal information is any information about you that is not generally available to the public. (Examples of public information include items such as information readily available in a telephone book or a publicly recorded document such as a mortgage or a securities filing.) We collect nonpublic personal information about you from the following sources:
- Information we receive from you on applications or other forms (such as your name, address, social security number, assets and income),
- Information about your transactions with us, our affiliates, or others (such as your account balance, payment history, parties to transactions, and credit usage), and
- Information we receive from a consumer-reporting agency (such as your creditworthiness and credit history).
We may disclose all of the information we collect, as described above, to companies that perform marketing services on our behalf.
If you decide to close your account(s) or you are no longer an active customer, we will retain your records for as long as required by law. We will continue to treat your personally identifying information as described in this notice, as amended from time to time.
CALIFORNIA CONSUMER PRIVACY ACT
Your Right to Know About Personal Information Collected, Disclosed, or Sold
The California Consumer Privacy Act ("CCPA") grants California residents ("consumers") or another person authorized to act on behalf of the consumer, the right to:- Know what personal information Commonwealth Business Bank ("CBB" or "Bank") has collected about you during the prior twelve months
- Know whether CBB sells your personal information, and if so, to whom
- Give or withhold consent for CBB to sell your personal information
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Request that CBB disclose to you:
- The categories of personal information CBB has collected about you
- The categories of sources from which the personal information is collected
- The purpose for collecting the personal information
- The categories of third parties with whom CBB shares personal information
- The specific pieces of personal information that CBB has collected about you
- Request that CBB delete your personal information, to the extent possible and
- To not receive discriminatory treatment by the Bank for the exercise of any privacy rights conferred by the California Consumer Privacy Act (California Civil Code § 1798.100 et seq.)
- The Bank has a toll-free number of which consumers may call to submit a RTK: (866) 857-2272 (CCPA)
- email us at: Compliance@cbb-bank.com
- In Person - RTK forms are available at all banking locations and may be submitted in person
Please note that the identity of individuals requesting deletion or disclosure of their personal information must first be verified to protect you and CBB from fraud and identity theft. In order to verify your identity, we will contact you and use non-public information to validate your identity via telephone, in person or by electronic means. Please note that CBB may not disclose or delete all personal information requested by consumers due to various state and federal regulations governing financial institutions and available statutory exemptions.
Collection of Personal Information
Personal Information collected in the last 12 monthsCategories of Personal Information We Collect
Below is a list of categories of personal information CBB has collected about consumers in the preceding 12 months. CBB has collected:
- Identifiers
- Characteristics of Protected classifications under California and/or federal law
- Commercial information
- Biometric information
- Internet or other electronic network activity information
- Geolocation data
- Audio, Electronic, and Visual information
- Professional or employment-related information
- Education Information
- Consumer profile information
Categories of Sources from Which We Collect Personal Information
We collect the categories of personal information from the following categories of sources:
- Directly from you during the account application and opening process or other times when we are in direct communication with you
- We may also collect personal information from you when you use our products and services, including in-branches, at ATMs, Bill Pay and ACH services
- We may also collect personal information directly from you on employment applications and during human resource reviews if you are employed by us
- We also collect personal information through our online systems
- Government Entities
- Credit Bureaus
Our Business or Commercial Purpose for Collecting Personal Information
Our Business or Commercial Purpose for Collecting Personal Information
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We collect your personal information for our own business and commercial purposes.
The business and/or commercial purpose for which we collect your personal information include:
- To conduct employee training and education, cooperative projects, and to seek legal and/or consulting advice
- For physical security purposes, business continuity, hiring, employment, vetting, payroll, to administer employment benefits, and other employment-related purposes. We collect fingerprint information for physical security purposes. For most employees, we collect a photo for identification and security purposes. We may collect additional personal information for employees.
- To deliver services, remember users and their preferences, perform statistical analysis, authenticate users, to detect and respond to security incidents, and to deliver information to prospective and current online account holders, as described in our privacy policy
- To assist with background checks, candidate search, onboarding, to prevent fraud, seek legal advice, and to respond to court orders, regulatory inquiries, internal audits and legal investigations, and otherwise where reasonably necessary for the Bank's operations
Disclosure or Sale of Personal Information
Below is a list of the categories of personal information that we have disclosed for a business purpose or disclosed to third parties in the preceding 12 months. For each category so identified we also describe the categories of third parties to whom the information was sold or disclosed to:
Categories of Personal Information Disclosed for a Business Purpose or Sold to Third Parties | Categories of Third Parties to Whom the Personal Information was Disclosed or Sold |
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Identifiers |
Account Management software vendors, credit reporting agencies, vendors, Bank software vendors, Bank Vendors for specified purposes. Vendors who contract with the Bank to provide services and benefits to employees and the Bank. Legal and regulatory agencies and Bank auditors. Third party vendors and affiliates who contract with the Bank to assist with background checks, candidate search, onboarding, to prevent fraud, seek legal advice, and to respond to court orders, regulatory inquiries, and legal investigations, and otherwise where reasonably necessary for the Bank's operations. Third party vendors, credit bureaus, state and federal bureaus, agencies, and departments, transactional counterparties, to service accounts, conduct background and credit checks, facilitate transactions, for marketing purposes, to prevent fraud, money laundering or terrorist financing, seek legal advice, and to respond to court orders, regulatory inquiries, and legal investigations, and otherwise where reasonably necessary for the Bank's operations. Authorized issuers, processors, or facilitators of subpoenas, summons, search warrants, levies, garnishments and similar legal process. |
Biometric Information |
Account Management software vendors, credit reporting agencies, and other vendors Third party vendors, credit bureaus, state and federal bureaus, agencies, and departments, transactional counterparties, to service accounts, conduct background and credit checks, facilitate transactions, for marketing purposes, to prevent fraud, money laundering or terrorist financing, seek legal advice, and to respond to court orders, regulatory inquiries, and legal investigations, and otherwise where reasonably necessary for the Bank's operations. Authorized issuers, processors, or facilitators of subpoenas, summons, search warrants, levies, garnishments and similar legal process. |
Geolocation data |
Account Management software vendors, credit reporting agencies, and appraisers. Authorized issuers, processors, or facilitators of subpoenas, summons, search warrants, levies, garnishments and similar legal process. |
Internet or other electronic network activity information |
Account Management software vendors, credit reporting agencies, and appraisers. Third party vendors and affiliates who contract with the Bank to assist with background checks, candidate search, onboarding, to prevent fraud, seek legal advice, and to respond to court orders, regulatory inquiries, and legal investigations, and otherwise where reasonably necessary for the Bank's operations. Third party vendors, credit bureaus, state and federal bureaus, agencies, and departments, transactional counterparties, to service accounts, conduct background and credit checks, facilitate transactions, for marketing purposes, to prevent fraud, money laundering or terrorist financing, seek legal advice, and to respond to court orders, regulatory inquiries, and legal investigations, and otherwise where reasonably necessary for the Bank's operations. Authorized issuers, processors, or facilitators of subpoenas, summons, search warrants, levies, garnishments and similar legal process. |
Characteristics of Protected Classifications under California and/or federal law |
Vendors who contract with the Bank to provide services and benefits to employees and the Bank. To legal and regulatory agencies. Third party vendors and affiliates who contract with the Bank to assist with background checks, candidate search, onboarding, to prevent fraud, seek legal advice, and to respond to court orders, regulatory inquiries, and legal investigations, and otherwise where reasonably necessary for the Bank's operations. Third party vendors, credit bureaus, state and federal bureaus, agencies, and departments, transactional counterparties, to service accounts, conduct background and credit checks, facilitate transactions, for marketing purposes, to prevent fraud, money laundering or terrorist financing, seek legal advice, and to respond to court orders, regulatory inquiries, and legal investigations, and otherwise where reasonably necessary for the Bank's operations. Authorized issuers, processors, or facilitators of subpoenas, summons, search warrants, levies, garnishments and similar legal process. |
Commercial information |
Third party vendors and affiliates who contract with the Bank to assist with background checks, candidate search, onboarding, to prevent fraud, seek legal advice, and to respond to court orders, regulatory inquiries, and legal investigations, and otherwise where reasonably necessary for the Bank's operations. Third party vendors, credit bureaus, state and federal bureaus, agencies, and departments, transactional counterparties, to service accounts, conduct background and credit checks, facilitate transactions, for marketing purposes, to prevent fraud, money laundering or terrorist financing, seek legal advice, and to respond to court orders, regulatory inquiries, and legal investigations, and otherwise where reasonably necessary for the Bank's operations. Authorized issuers, processors, or facilitators of subpoenas, summons, search warrants, levies, garnishments and similar legal process. |
Audio, electronic, visual, thermal, olfactory, or similar information, |
Bank Vendors for specified purposes. Authorized issuers, processors, or facilitators of subpoenas, summons, search warrants, levies, garnishments and similar legal process. |
Professional or employment-related information |
Vendors who contract with the Bank to provide services and benefits to employees and the Bank, to legal and regulatory agencies Third party vendors and affiliates who contract with the Bank to assist with background checks, candidate search, onboarding, to prevent fraud, seek legal advice, and to respond to court orders, regulatory inquiries, and legal investigations, and otherwise where reasonably necessary for the Bank's operations. Third party vendors, credit bureaus, state and federal bureaus, agencies, and departments, transactional counterparties, to service accounts, conduct background and credit checks, facilitate transactions, for marketing purposes, to prevent fraud, money laundering or terrorist financing, seek legal advice, and to respond to court orders, regulatory inquiries, and legal investigations, and otherwise where reasonably necessary for the Bank's operations. Authorized issuers, processors, or facilitators of subpoenas, summons, search warrants, levies, garnishments and similar legal process. |
Education Information | Third party vendors and affiliates who contract with the Bank to assist with background checks, candidate search, onboarding, to prevent fraud, seek legal advice, and to respond to court orders, regulatory inquiries, and legal investigations, and otherwise where reasonably necessary for the Bank's operations. |
We comply with lawful requests for information from law enforcement, regulators, judicial authorities and court-appointed trustees, supervisors, and other third parties pursuant to subpoenas or document requests. We disclose employee contact information where reasonably necessary for the Bank's operations, to secure the Bank's employees and assets, for employee career development, to prevent fraud, seek legal advice, respond to court orders, investigations and regulatory inquiries, and comply with legal and regulatory obligations.
We do not have actual knowledge that we sell the personal information of minors under 16 years of age. By default, California residents the Bank knows to be under the age of 16 would be opted out of the sale of their personal information.
Right to Request Deletion of Personal Information
You have the right to request the deletion of any personal information about you which we have collected or maintained. If you would like to request that CBB delete your personal information, you may do so by:
- The Bank has a toll-free number which consumers may call to submit a RTK: (866) 857-2272 (CCPA)
- email us at: Compliance@cbb-bank.com
- In Person - RTD forms are available at all banking locations and may be submitted in person
Right to Non-Discrimination for the Exercise of Your Privacy Rights
You have a right not to receive discriminatory treatment by us for the exercise of any privacy rights conferred by the California Consumer Privacy Act (California Civil Code § 1798.100 et seq.)
Authorized Agent
Your designated authorized agent can make a request under the California Consumer Privacy Act on your behalf by:
- The Bank has a toll-free number of which consumers may call to submit a RTK: (866) 857-2272 (CCPA)
- email us at: Compliance@cbb-bank.com
Changes to Disclosure
We may change this disclosure from time to time. When we do, we will update the "Last Updated" date.
Contact for More Information
If you would have any questions, then please email us at Compliance@cbb-bank.com
Date Last Updated: July 31, 2020