Privacy Policy

Citizens Trust Bank (“Citizens Trust Bank,” “we,” “us,” or “our”) cares about the privacy of the information we collect about you. This Privacy Statement outlines how we collect, use, share, and protect your personal information and the rights and choices you can exercise in relation to your personal information. By using our Services, you agree to the terms outlined in this Privacy Statement. Please contact us via Contactus@ctbatl.com if you have any questions or would like additional information regarding this Privacy Statement. We may update this Privacy Statement from time to time, so please check this Privacy Statement periodically for changes.

SCOPE OF THIS PRIVACY STATEMENT

This Privacy Statement applies to our collection of personal information via interactions with you across various platforms, including the below (collectively the “Services”):

  • Websites and Mobile Applications: This includes any interaction you have with our websites and any associated mobile applications (“the Website”).
  • Facilitating our Banking Services: This includes information collected for applications (but does not include GLBA data, as described below) and other marketing programs.
  • Events: When you attend events such as trade shows, webinars, and others where we participate or present, we may collect personal information from and about you.
  • Phone, Text, Chat and Email Communications: Personal information may be collected when you communicate with us via phone, text, chat, or email, such as call logs, email addresses, and the content of the communications.
  • Social Media: We collect likes, comments, and direct messages through interactions on our social media pages and other third-party social media sites such as Facebook, YouTube, LinkedIn, Instagram, and X/Twitter.
  • Online Advertisements and Emails: If you view our online ads or emails, we may collect information about your interaction with these communications, such as click-through rates and preferences.
  • Authorized Service Providers: We may also collect information through third-party service providers who are authorized to act on our behalf, including marketing firms and payment processors.

Personal information does not include: (i) publicly available information; (ii) deidentified or aggregated consumer information; or (iii) personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FRCA”) and the Gramm-Leach-Bliley Act (“GLBA”). For more information on information collected, processed, or disclosed pursuant to the GLBA and its implementing regulations, please refer to our GLBA Privacy Notice.

COLLECTION OF PERSONAL INFORMATION

As further described below, we collect personal information directly from you, automatically through your use of the Website, and from other, third-party sources. To the extent permitted by applicable law, we may combine the information we collect from publicly available or third-party sources.

Personal information We Collect Directly From You. While the personal information we collect varies depending upon your use of the Services and our interactions with you, in general, we may collect the following personal information directly from you:

  • Contact Information. When you contact us, we collect your name, email address, phone number, postal address.
  • Application Information. When you fill out an application for our services, we collect personal information about you and those for which you provide it on behalf of, which includes:
    • Identifiers, including name, alias, telephone number, postal address, unique personal identifier, online identifier, email address, account name, financial and account information, social security number, driver’s license number, passport number;
    • Customer Records, including name, signature, physical characteristics or description, postal address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, account number, credit and/or debit card number, other financial information, medical information, health insurance information;
    • Demographic and Protected Classifications, including age, citizenship, marital status, race/ethnic origin, medical condition, disability status, or veteran status (as permitted by law);
    • Professional or Employment Information, including current or past job history; and
    • Sensitive Personal Information, including government-issued identifiers and certain demographic details. We only collect this information as necessary to provide our services or as authorized by you.
  • Communications and Interactions. When you send email, text message, call, or otherwise communicate with us and with members of our team, we collect and maintain a record of your contact details, communications, and our responses.
  • Responses and Feedback. If you participate in our surveys or questionnaires, we collect your responses and feedback, such as user satisfaction or other information related to your use of the Website, and any other information you so choose to provide.
  • Marketing and Promotions. If you agree to receive marketing communications from us, we collect your email, name, phone number, preferences. If you participate in promotions we offer, we collect your name and other information related to the activities available through the Website.
  • Inferences. We may generate inferences about you based on other personal information we collect such as your preferences, behaviors, contact information, and demographics information.
  • Preferences. We also may collect information about your preferences, including communications preferences.

Special Category Information

Some of the information that we may collect as a result of providing credit solutions and banking services is particularly sensitive (e.g., social security number, driver’s license number, passport number, and racial or ethnic origin). We only collect this information as provided by or consented by you.

Such sensitive information is only shared for the purpose of providing the Services you request or as consented for and will not be shared or used by us for any other purposes.

Personal information We Collect Automatically. We and our third-party providers automatically collect personal information related to your use of the Website, including using cookies and other similar technologies. The personal information we may automatically collect includes the below categories of information (collectively, “Usage Data”):

  • Device and Browsing Information. When you visit the Website, we may collect IP address, browser type, domain names, access times, date/time stamps, operating system, language, device type, unique ID, Internet service provider, referring and exiting URLs, clickstream data, and similar device and browsing information.
  • Activities and Usage. We also collect activity information related to your use of the Website, such as information about the links clicked, searches, features used, items viewed, time spent within the Website, your interactions with us within the Website, and other activity and usage information.
  • Location Information. We may also collect or derive location information about you, such as through your IP address. If you choose to enable location-based sharing with us through your device settings, we may collect precise location information to provide content that is more relevant to your location and to otherwise improve your interactions with the Website. You may turn off location data sharing through your device settings.
  • Video viewing data. We may collect internet protocol (IP) address and your activity and history regarding your interactions with videos contained on the Website.

For more information about our use of cookies and other similar technologies, please review our Cookie Policy, incorporated herein by reference.

Personal information We Collect from Other Sources.

In addition, we may collect and receive personal information from third parties, such as business partners, public databases, and credit bureaus where permitted by law and in the course of providing the services you request. We may combine this information with personal information we collect directly from you, and use it to generate inferences about your preferences, behavior, or other characteristics, as permitted by applicable law.

Some parts of the Services allow you to provide us with personal information relating to other parties (collectively, “Third-Party Data”). If you use any feature of the Services that allows you to communicate with other parties or to provide information regarding other parties (such as to refer another other party to the Website or to provide us information on a spouse, guarantor, dependent, or authorized user), either by submitting Third-Party Data to the Website or otherwise permitting the Website to automatically access Third-Party Data in your possession, you acknowledge, represent, and agree (a) that you have the authority of the relevant other party for us to access and use the relevant Third-Party Data, and (b) that you have notified these other parties and informed them how their information is collected and used by us to provide the Services. We reserve the right to identify you as the person who has made the referral in any messages that are sent to other parties. We use Third-Party Data to (a) contact such party using the Third-Party Data provided, and/or (b) provide you with an editable template message designed to facilitate communication between you and such party through the Services. We may also send reminders or related messages to you and to other parties on your behalf from time to time, as and where permitted by applicable law.

USE OF PERSONAL INFORMATION

We use your personal information for various purposes, including:

  • Providing Information, Products, or Services. To fulfill or evaluate your requests for information, products, or services.
  • Website and Support. To provide and operate the Website, communicate with you about your use of the Website, respond to your inquiries, and to otherwise run our day-to-day operations.
  • Analytics and Improvement. To better understand how users access and use the Website and Services, and for other research and analytical purposes, to develop the Website and its features, and for internal quality control and training purposes.
  • Communicate With You. To respond to your inquiries, send you requested materials and newsletters, as well as information and materials regarding the Services and offers. We also use this information to send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies.
  • Marketing and Promotions. For marketing and promotional purposes. For example, to send you information about the Services, such as newsletters and other marketing content that you sign up to receive. If you do not wish to receive promotional e-mails from us, you may opt out at any time by following the unsubscribe directions in the email or contact us. If you opt out of a promotional e-mail, we may still send you transactional and administrative emails about this privacy notice or about the products or services you have purchased.
  • Targeted Advertising. To deliver personalized content and advertisements, including through the use of cookies and similar technologies, and to measure the effectiveness of our advertising campaigns. Please see below for further information regarding how to exercise your right to opt-out of the sharing of your personal information and targeted advertising.
  • To Create and Use Identifiers. We may generate hashed identifiers (e.g., from your email address) or first-party identifiers to recognize users across devices, measure ad effectiveness, and enable personalized advertising. These identifiers may be shared with Business Partners and Service Providers in connection with our advertising efforts, subject to applicable laws.
  • Research, Development, and Surveys. To administer surveys and questionnaires, such as for market research or user satisfaction purposes and to develop new products and services, including market analysis and product testing.
  • User-Generated Content. To enable you to post and share content, such as reviews, comments, forum posts, and other submissions, and to publish this content within the Citizens Trust Bank community.
  • Security and Protection of Rights. To protect the Services and our business operations, and to protect our rights or those of our stakeholders; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or act regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms and Conditions.
  • Compliance and Legal Process. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
  • Auditing, Reporting, and Other Internal Operations. To conduct financial, tax, and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions, and to maintain appropriate business records and enforce company policies and procedures.
  • General Business and Operational Support. To assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financing, and to administer our business, accounting, auditing, compliance, recordkeeping, and legal functions.

 

SHARING OF PERSONAL INFORMATION

We may share your personal information for the purposes described above and as follows:

  • Affiliates and Subsidiaries. We may disclose the personal information we collect to our corporate affiliates and subsidiaries. We may also partner with other businesses to offer our products, and we may disclose personal information to those business partners as necessary to facilitate your orders or requests.
  • Vendors and Service Providers (“Service Providers”). We may disclose the personal information we collect to service providers who perform functions on our behalf, such as IT and website hosting, marketing, and marketing research providers, customer support, data storage, analysis and processing providers, auditors, consultants, and legal counsel.
  • Business Partners, Including Advertising Partners and Analytics & Marketing Partners. We may also disclose your Usage Data to marketing and advertising networks, data analytics providers, and other companies who provide marketing or analytics services on our behalf as further described in our Cookie Policy.
  • In Support of Business Transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may disclose or transfer the personal information we have collected from you with or to the other company. We may also disclose certain personal information as necessary prior to the completion of such a transaction or other corporate transactions such as a financing or restructuring, to lenders, auditors, and third-party advisors, including attorneys and consultants.
  • Compliance and Legal Obligations. To comply with our legal and compliance obligations and to respond to the legal process. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.
  • Security and Protection of Rights. Where we believe doing so is necessary to protect us, our rights and property, or the rights, property, and safety of others. We may also disclose personal information related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
  • Aggregate and Deidentified Information. Notwithstanding anything else in this Privacy Statement, we may use, disclose, and otherwise process aggregate and deidentified information related to our business and the Website with third parties for quality control, analytics, research, development, and other purposes.
  • Other Disclosures. We may disclose personal information in other ways not described above, but will notify you and, if necessary, obtain your consent.
  • Authorized Representatives. If another individual is managing your account or access to the Services on your behalf (for example, a wife managing the account of her husband), as authorized by you or as a personal representative under applicable law, that person can view all personal information about you in the Services

 

ADVERTISEMENTS

If streaming videos displayed on our sites include Third-party Tags, the third parties that have provided the Third-party Tags also may receive information about videos you watch on the Website.

While we may use a variety of service providers to perform advertising services, some of these companies are members of NAI or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. You may want to visit http://www.networkadvertising.org/managing/opt_out.asp, which provides information regarding targeted advertising and the “opt-out” procedures of NAI members. You may also want to visit or http://www.aboutads.info/choices/, which provides information regarding targeted advertising and offers an “opt-out” by participating companies in the DAA Self-Regulatory Program. Please note that opting out through these mechanisms does not opt you out of being served advertising, and you will continue to receive generic ads while online.

Do Not Track. Currently, the Website does not recognize all “Do-Not-Track” requests. You may, however, disable certain tracking by disabling cookies. If our site detects that your browser or device is transmitting an opt-out preference signal, such as the “global privacy control”—or GPC — signal, we will opt that browser or device out of the use of cookies or other tools on our site that result in a “sale” or “sharing” or use for targeted advertising of your personal information. If you come to our site from a different device or from a different browser on the same device, or if you clear your cookies, you will need to opt-out again, or use an opt-out preference signal, for that browser and/or device as well.

SECURITY

We take information security very seriously and use reasonable administrative, technical, and physical measures to protect your personal information from unauthorized access. Unfortunately, no security system can be guaranteed to be 100% secure. Accordingly, we cannot guarantee the security of your information and cannot assume liability for improper access to it.

CHILDREN’S PRIVACY

Citizens Trust Bank does not sell products for purchase by children. If you believe we have collected information from a minor, please contact us so we can take appropriate action. If you are under 18, you are not permitted to transact with Citizens Trust Bank.

MODIFICATION

We may update this Privacy Statement from time to time to reflect changes to our privacy practices, and when we do, we will update the “Last Updated” date at the top of the Privacy Statement. If we make material changes, we will provide prominent notice (such as through a notice or banner or, where feasible, via email). Your continued use of our Services after the “Last Updated” date constitutes your acceptance of the changes. If you do not agree to the changes, you should immediately stop using our Services.

VISITING OUR WEBSITE FROM OUTSIDE OF THE UNITED STATES

If you are visiting our Website from the European Union or other region outside of the United States or otherwise contacting us from outside of the United States, please be aware that your personal information will be transferred to, stored or processed in the United States, where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries may differ and may not be as comprehensive as those in your country. We will protect your privacy in accordance with this Privacy Statement. By using our services or purchasing our products, you consent to the transfer of your personal information to our facilities in the United States and to those third parties with whom we share our facilities as described in this Privacy Statement.

CONTEST AND SWEEPSTAKES ENTRIES

We occasionally offer sweepstakes and contests. To participate in these online sweepstakes, we may require you to register and provide us with personal information, such as your name and email address. This Privacy Statement applies to sweepstakes we may administer online through the Website or other social media or digital platforms. Some sweepstakes we advertise may be administered by third parties who would collect your information, and you should review the privacy policies of the administering party to understand how your data is used and protected by them. In sweepstakes we offer, we will use the information you provide us for purposes including administering the sweepstakes, subscription to our newsletter, and other purposes disclosed at the time of registration. You should carefully review the Official Rules of any sweepstakes or contest in which you participate, including any option to opt-out of receiving special offers and marketing material by unchecking the appropriate box when registering for sweepstakes.

LINKS TO OTHER WEBSITES

For your convenience, we may provide links to other websites and web pages that we do not control. We cannot be responsible for the privacy practices of any websites or pages not under our control and we do not endorse any of these websites or pages, the services or products described or offered on such sites or pages, or any of the content contained on those sites or pages.

RETENTION

Personal information is retained no longer than necessary to fulfill the purposes set out in this Privacy Statement, unless a longer retention period is required (such as under applicable contracts with clients or business partners) or permitted by law (such as tax, accounting, or other legal requirements).

STATE-SPECIFIC PRIVACY RIGHTS

Citizens Trust Bank does not currently meet the thresholds for applicability under any enacted comprehensive privacy laws (“State Privacy Laws”). However, we are committed to transparency in how we handle personal information and will make reasonable efforts, as described in this Privacy Policy, to provide clear information and to honor certain requests regarding personal information where feasible. Please note that these efforts are provided as a courtesy and do not create any obligations or liabilities under State Privacy Laws to which Citizens Trust Bank is not otherwise subject. In all cases, our responses to such requests will remain consistent with Citizen Trust Bank’s regulatory and legal obligations.

DATA REQUESTS & CONTACT US.

To contact us regarding our data practices, you can contact us via : Contactus@ctbatl.com