Introduction
At Croghan Bank, we understand the importance of your privacy and are committed to protecting your personal information. This Privacy Policy explains how we, along with our service provider Fiserv Inc., collect, use, share, and safeguard your “Personal Information” (data identifiable to you) when you use our online services and website, referred to as the “Site” and “Service.” Fiserv Inc., acting as our service provider, assists us in delivering these services. This policy is designed to be transparent and informative, ensuring you understand our practices regarding your data. We are dedicated to complying with all applicable U.S. federal and state laws concerning your privacy. Please read this policy carefully to understand your rights and our responsibilities.
Eligibility and Age Limitations
To utilize the Croghan Bank Site and Service, you must meet the eligibility requirements outlined in our general Terms and Conditions Agreement. Critically, we do not knowingly collect Personal Information from individuals under the age of 18. If you are under 18, please do not provide us with any personal information. Parents and legal guardians are urged to prevent their children from submitting personal information without their explicit consent. By accessing and using the Croghan Bank Site and/or Service, you confirm your agreement to the terms and conditions of this Privacy Policy.
Cookies and Browser Information
Like most websites, when you visit the Croghan Bank Site, our servers automatically record standard information sent by your web browser. This includes your IP address, browser type and language, access times, and the website you were referred from. This information is used for several purposes, including enhancing the Site’s functionality, improving security, and aiding in user authentication when you access the Site or Service. Analyzing this data helps us ensure secure access and optimize your online experience with Croghan Bank.
We also gather data about your activity on the Site, such as pages viewed, links clicked, and actions taken within the Services. This usage data helps us to further refine the Site’s operation and improve the services we offer to you at Croghan Bank.
To enhance your experience, the Croghan Bank Site employs “cookies,” which are small data files placed on your device by our web server. These are “session” cookies, meaning they are active only during your current visit to the Site, such as during the login process. We do not utilize “persistent” cookies that remain on your computer after you leave the Site. It’s important to note that cookies cannot execute programs on your computer or introduce viruses. While most web browsers automatically accept cookies, you can adjust your browser settings to decline them. However, disabling cookies may limit your ability to sign in and use interactive features of the Croghan Bank Site that rely on them.
Regarding online tracking of individual consumers across different websites, Croghan Bank adheres to the following principles for this Site, except where legally required: (1) we do not permit parties other than Croghan Bank and its authorized service providers to collect such information, and (2) Croghan Bank itself does not collect such information beyond what is necessary for processing and documenting user transactions, like payment history. Therefore, the Croghan Bank Site does not respond to web browser “do not track” signals or similar mechanisms concerning the collection of browsing activity across websites over time.
Types of Personal Information Collected by Croghan Bank
In addition to the browser and cookie information mentioned, Croghan Bank may collect various types of Personal Information to provide and secure our services. This information may include:
- Identifying and Contact Information: Date of birth, name, postal address, email address, telephone number. This allows us to contact you, verify your identity, and manage potential risks. We may also use information from identity verification services and consumer reporting agencies, including credit bureaus, for these purposes.
- Bank Account Information: Details of accounts you designate for payments, including routing numbers, account numbers, balances, and transaction history. This is essential for processing transactions you initiate through Croghan Bank services.
- Billing Account Information: Billing account numbers used to ensure that only authorized users access and manage your Croghan Bank Services.
- Transaction Information: Payment and transaction history related to your use of the Croghan Bank Service. This helps us maintain records and provide customer support.
- User-Provided Information: Any Personal Information you voluntarily enter on the Croghan Bank Site, such as in forms, surveys, or customer service interactions.
How Croghan Bank Collects Your Personal Information
Croghan Bank collects Personal Information through various channels:
- Directly from Your Interactions: When you use the Croghan Bank Site and Service, such as when you make a payment, and during interactions with our customer care services. This includes information you input, speak during calls, and data transmitted by your devices (computers, phones, etc.) used to access our services.
- From Third-Party Sources: We also receive Personal Information from other sources, including your Biller, credit bureaus, affiliates, and other companies. These may include identity verification services, consumer reporting agencies, and entities that provide content to the Site, like electronic bill providers, or utilize the Croghan Bank Service.
Sharing Your Personal Information
Croghan Bank understands the sensitivity of your personal information and shares it only as legally permitted. For nonpublic Personal Information collected in connection with providing a financial service, U.S. federal law restricts sharing to specific purposes outlined below:
Reasons Croghan Bank Shares Personal Information:
| Reason for Sharing | Does Croghan Bank Share? | Can You Limit Sharing? |
|---|---|---|
| 1. For everyday business purposes (transaction processing, account maintenance, legal compliance, credit bureau reporting) | Yes | No |
| 2. For our marketing purposes (offering Croghan Bank products and services) | Yes | No |
| 3. For joint marketing with other financial companies | No | No |
| 4. For our Affiliates’ everyday business purposes (transaction and experience information) | Yes | No |
| 5. For our Affiliates’ everyday business purposes (creditworthiness information) | No | We Do Not Share |
| 6. For our Affiliates to market to you | No | We Do Not Share |
| 7. For Non-affiliates to market to you | No | We Do Not Share |
How Croghan Bank Uses Your Personal Information
Croghan Bank uses your Personal Information in accordance with legal permissions, including but not limited to:
- Essential Service Operations: Maintaining your access to the Service, authenticating you when you access the Site or Service, enabling Croghan Bank to authenticate you when you manage your accounts, sending service-related information, processing, administering, and enforcing transactions.
- Security and Compliance: Performing Anti-Money Laundering and fraud monitoring, preventing and investigating fraud and unauthorized transactions, verifying your identity and account information, determining credit history, performing collections, reporting to credit bureaus (including delinquent account information), complying with legal obligations, court orders, and government agency instructions.
- Protection and Improvement: Protecting the safety of subscribers and the public, preventing and defending legal claims, resolving disputes, troubleshooting technical issues, enforcing our Terms and Conditions, protecting our rights and property, and customizing, measuring, and improving the Services, Site content, and layout through data analysis, pattern recognition, system analysis, and performance monitoring.
Other Important Privacy Information
- Vermont Residents: Vermont law dictates that we will not share information about Vermont residents with non-affiliated companies, except as permitted by law. We will not share creditworthiness information with affiliates without your consent, but may share transaction or experience information with affiliates without consent.
- California Residents: Under California law, we will not share information about California residents with non-affiliated companies, unless legally allowed. Sharing may occur with your consent, to service your accounts, or to provide entitled benefits. We will limit information sharing among our affiliates as required by California law.
Definitions
- Affiliates: Companies under common ownership or control with Croghan Bank.
- Non-Affiliates: Companies not related to Croghan Bank by common ownership. These can be financial or non-financial entities.
- Joint Marketing: Formal agreements between non-affiliated financial companies to jointly market financial products or services. Croghan Bank does not currently engage in joint marketing as described in section 3 of the sharing table.
Protecting Your Personal Information
Croghan Bank implements robust security measures to protect your Personal Information from unauthorized access and use. These include physical, electronic, and procedural safeguards compliant with federal and state laws. We also mandate that our service providers and business partners maintain comparable security standards.
Protection for Former Customers
Even after you cease to be a Croghan Bank customer or stop using our Site or Service, we continue to protect your Personal Information as described in this Privacy Policy and as required by law. This includes data retention and protection for risk management, regulatory compliance, and audit purposes.
Amendments to This Privacy Policy
Croghan Bank reserves the right to modify this Privacy Policy at any time by posting a revised version on the Site. The updated policy will take effect immediately upon posting, unless a later date is specified. We may also, at our discretion, notify you of changes via email. In some cases, we may require you to explicitly acknowledge or accept the updated Privacy Policy to continue using the Site or Service. Your continued use of the Service after any notification of changes constitutes your express agreement to the revised Privacy Policy.
Contacting Croghan Bank
If you have any questions or concerns regarding this Privacy Policy, please contact us using the details below:
In writing:
Croghan Bank
[Insert Bank’s Physical Address for Privacy Inquiries]
By Email:
