What does CBB Bank do with your personal information?
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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.
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.
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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 (CCPA)
Your Right to Know About Personal Information Collected, Disclosed, or SoldOverview
The California Consumer Privacy Act ("CCPA") of 2018 which was amended by the California Privacy Rights Act (CPRA) of 2020, which grants to California residents ("consumers") or another person authorized to act on behalf of the California consumer, the following:
- Know what personal information Commonwealth Business Bank ("CBB-Bank" "we" or "Bank") has collected about you
- Know whether CBB sells your personal information, and if so, to whom
- Give or withhold consent to the selling of your personal information
Request the disclosure of:
- The categories of personal information collected, disclosed, or sold about you and the purpose(s)
- 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 your personal information is shared
- The specific personal information that the Bank has collected about you
- Right to limit use of sensitive personal information, including limits on how long your personal information can be retained
- Right to correct personal information by requesting changes to any of their personal information held in a company's data records Right to opt-out of automated decision-making technology
- Request the deletion of your personal information permanently from the Bank's records, to the extent possible
- Right to opt-out of the sale or sharing of personal information to any other company
- To not be discriminated against and/or retaliated for exercising your privacy rights
Sharing or Sale of Personal InformationBelow 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, the reason for collecting the information as well as whom the information was disclosed to:
|Category||Source(s) Information is Collected:||Reason Information is Collected:||Information is Disclosed to:|
|A. Identifiers||Bank product/service applications, financial records (e.g. pay stubs, tax returns, bank statements), credit reports, employment applications, driver's license||To evaluate requests for deposit/loan products, to service your existing account(s), and employment purposes including the offering of employee benefits||Third party vendors as contracted by the Bank, credit reporting agencies, benefits providers, and others as required or allowed by the law|
|B. Biometric Information||Biometric information is currently not obtained or collected or used by the Bank||Biometric information is currently not obtained or collected or used by the Bank||Biometric information is currently not obtained or collected or used by the Bank|
|C. Geolocation data||Primarily used with the mobile application and via use of the Internet||To assist the person in locating the nearest retail branch or ATM in relation to their current location||Service providers and other parties as allowed by the law|
|D. Internet or other electronic network activity information||Bank product applications, online activity through IP address||Primarily for the Bank's marketing efforts, employment purposes such as payroll, benefits, etc. and other required uses such as business resumption||Service providers and other parties as allowed by the law|
|E. Personal Information - includes signature, telephone number, passport number, account number, credit card number, medical and health insurance information||Bank product/service applications, financial records (e.g.; pay stubs, tax returns, bank statements), credit reports, employment applications, driver's license||For account servicing, responding to your service inquiry/requests or in accordance with government reporting requirements||Service providers and other parties as allowed by the law|
|F. Characteristics of Protected Classifications under California and/or federal law||Bank product/service applications, financial records (e.g. pay stubs, tax returns, bank statements), credit reports, employment applications, driver's license||For account servicing, responding to your service inquiry/requests or in accordance with government reporting requirements||Service providers and other parties as allowed by the law|
|G. Commercial information||Bank product/service applications, financial records (e.g. pay stubs, tax returns, bank statements), credit reports, and driver's license||To evaluate requests for deposit/loan products, to service your existing account(s), and employment purposes including the offering of employee benefits||Third party vendors as contracted by the Bank, credit reporting agencies, benefits providers, and others as required or allowed by the law|
|H. Audio, electronic, visual, thermal, olfactory, or similar information||Directly from consumers and/or our service providers||Audio, electronic, visual, or similar information, such as call and video recordings;||Service providers and other parties as allowed by the law|
|I. Professional or employment-related information||Employment applications, banking information for payroll, background checks/credit report, tax returns, deposit / loan application, and other information obtained by the employee||To evaluate requests for deposit/loan products, to service your existing account(s), and employment purposes including the offering of employee benefits||Service providers and other parties as allowed by the law|
|J. Education Information||Employment applications, banking information for payroll, background checks/credit report, tax returns, deposit / loan application, and other information obtained by the employee||Service providers and other parties as allowed by the law|
|K. Inferences||Inferences based on information about an individual||Identifying potential products and services that may be of interest||Service providers and other parties as allowed by the law|
Selling of Client InformationThe Bank does NOT sell customer information to third parties.
Request to Know Personal Information CollectedYou may submit a request for the personal information we collect, use, disclose or sell by submitting a "Request to Know" ("RTK") using one of the following methods:
- 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
The identity of any individual requesting deletion or disclosure of your personal information will first be verified to protect you and CBB Bank from fraud and/or 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.
We will respond within 45 calendar days of receipt of your request and provide the data free of charge.
*** Please note that CBB Bank 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. ***
Sensitive Personal Information (SPI)SPI is defined to include the following:
- Racial origin and ethnicity
- Religious beliefs and political and philosophical convictions
- Sexual orientation and sex life activity
- Contents of a consumer's mail, email and/or text messages
- Health and medical status and history
- Financial status and history
- Precise geolocation
- Genetics and biometrics
- Social security number and driver's license
You have the right to limit the use of your sensitive personal information to only the information "which is necessary to perform the service reasonably expected by an average consumer who requests such a product/service."
You may also request disclosure of what information is collected, how it is used, and for how long the information is retained.
Correcting SPI or Limiting its Use: You have the right to correct or revise inaccurate or incomplete SPI that is maintained by the CBB-Bank. You also have the right to limit the use of the information. To exercise these rights:
- Submit an email to: Compliance@cbb-bank.com
- Tell us exactly what information needs to be corrected or limited and provide your phone number and email address so that we can contact you back
You will receive a phone call within two business days after submission of your request.
- We will ask for your name, address, account information, date of birth, email address, phone number(s), date(s) of interaction with our website. The information is needed to verify your identity but to also locate any information that could have been collected
- Your information will be promptly corrected after your identification has been verified
Please note: the Bank uses the information to provide you with products / services that you have requested and/or to limit losses/fraud or as needed for required governmental reporting.
Collecting of Personal InformationWe collect your personal information for our own business and commercial purposes. The business and/or commercial purpose for which we collect your personal information may 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 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
Opting out of Automated Decision-Making TechnologyIn general, automated decision-making technology has the ability to collect information about you and to make decisions about whether or not you will be approved for a banking product or service.
- The Bank does not currently utilize automated decisioning technology
Data Collection & Minors - Under the age of 16We do not market our product or services to minors.
Right to Request Deletion of Personal InformationYou 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 Bank 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
In order to verify your identity CBB Bank will contact you and use non-public information to validate your identity via telephone, in person or by electronic means. It should be noted that under the law, all data maintained by the Bank cannot be deleted. Only certain types of data are eligible for deletion.
Authorized Agent for Request to Know or DeleteYour designated authorized agent can make a request under the California Consumer Privacy Act on your behalf by visiting us at one of our convenient locations. Both the designated agent and the person whose information is being requested need to be present.
Right to Non-Discrimination for the Exercise of Your Privacy RightsYou have a right to not be discriminated and/or retaliated against for exercising your privacy rights.
Changes to this DisclosureWe may change the information contained in this disclosure from time to time and if we do so, we will update the "Last Updated" date of this document.
Last Updated: July 31, 2023