Online Privacy Policy

Introduction

Greenfield Banking Company (“GBC Bank”, “we”, “us” or “our”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit or use our websites (including www.gbcbank.com, www.refergbcbank.com, gbcbankchecking.com and www.gbcbankwm.com), the GBC Bank Mobile Banking application, or other online services (collectively, our “Site”). This policy also describes our practices for collecting, using, maintaining, protecting, and disclosing that information. If you seek, apply for, or obtain a financial product or service with us, we will use and share that information we collect from or about you in accordance with our consumer Privacy Notice.

This policy does not apply to information collected by:

• Us offline; or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Site.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Site. By accessing or using this Site, you agree to this Online Privacy Policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Information we collect

We collect several types of information from and about users of our Site. For example, we may collect:

• Personal Identifiers – Like your name, mailing address, email address, phone number, date of birth, government-issued identifier (e.g., Social Security number, tax ID number, driver’s license, or other government ID), username and password, and other information that directly identifies you.
• Account Information – Like account number, credit/debit card number, account history, account balances, loan details, vehicle or property information, information about beneficiaries and joint account holders, and other information related to your accounts and applications.
• Business Information – Like business-related information (e.g., business name, address, revenue, and industry type), business contact, and professional information.
• Transaction Information – Like transaction details when you transfer money to or from your accounts, third-party billing information or statements, credit/debit card purchases, payment or transaction history, and payment card details.
• Credit Report Information – Like your credit score, credit history, and other information that we receive from credit reporting agencies.
• Demographic Information – Like gender, marital status, age, citizenship, household size/composition, education information, income, occupation, veteran or military status, and employment status.
• Biometric Information – Like fingerprints, voiceprints, scans of your facial geometry, keystroke and mouse movement patterns.
• Geolocation Information – Like internet protocol address, device location, and any information used to identify your physical location.
• Device Information – Like your device type, web browser type and version, operating system type and version, display/screen settings, language preferences, device contacts (e.g., to facilitate payments), photos (e.g., to deposit checks), mobile network information, general location (e.g., city, state, or country), precise location (e.g., latitude/longitude to find a nearby branch or ATM), cookie IDs, device IDs, mobile advertising IDs, and likely connections among different browsers and devices that you use.
• Online/Mobile Activity Information – Like login data, communication preferences, search history, information about how you use and interact with our Site (including content viewed, links clicked, and features used), when and how often you use our Site, and the webpage from where you were directed to our Site.
• Marketing Information – Like your marketing preferences, information about products or services we think you might like, and inferences based on your interactions with us or our partners (e.g., Online/Mobile Activity Data used for targeted advertising).
• Survey and Research Information – Like your responses to questionnaires, surveys, requests for feedback, and research activities.

If you inquire about or apply for a job at GBC Bank through our Site, we may also collect:

• Employment Application Information – Like professional, employment-related, and education history collected through the Site about job applicants, employees, associates, contractors, or other members of our workforce.

Automatic data collection and tracking technologies

As you interact with our Site, we may use automatic data collection technologies to collect certain information about your device, browsing actions, and patterns, including:

• Details of your visits to our Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site.
• Information about your device and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we already have. It helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Site according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Site.

The technologies we use for this automatic data collection and tracking may include:

• Server Logs – Server logs automatically capture details of your online interactions with us, such as the time and date of your website visit.
• Cookies – A cookie is a small file placed on your computer's hard drive. You can refuse to accept cookies by changing your browser settings, but this may limit access to parts of our Site. If you don't adjust your browser settings to refuse cookies, our Site will place and use cookies. For details on managing cookie privacy and security, see Choices About How We Use and Disclose Your Information.
• Pixels/Web Beacons/Web tags – Pixels, web beacons and web tags are an image or small code in a website or online ad. They enable companies (us or our service providers) to set or read cookies or transfer data to their servers when you load a webpage or interact with online content. For instance, we or our service providers might use pixels to see if you have interacted with part of our website or viewed an online ad.
• SDKs – Software Development Kits (“SDKs”) are code integrated in mobile apps to connect them to third-party technologies and services, such as in-app ad displays and tools for analytics. SDKs may be used to track users with an advertising ID (such as Apple’s IDFA and Google’s Advertising ID) to identify your mobile device over time for advertising purposes. They can also be used to collect information such as geolocation or IP address.
• Third-Party Plugins – Plugins from other companies, including social media companies (for example, through a “Share” or Like” button). Plugins might collect data about your page visits and share it with the plugin creator, even if you do not click on a button. Their use is governed by the creators' privacy policies and terms.
• Session Replay/Heatmaps – Session replay technology uses trackers added to a user’s browser to record how they navigate a website (mouse clicks, movements and scrolling) and interact with content. A heatmap is a visual representation of user interaction on a website, highlighting sections with more clicks and attention.

THIRD-PARTY USE OF AUTOMATIC DATA COLLECTION AND TRACKING TECHNOLOGIES

Some content or applications, including advertisements, on the Site are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use automatic data and tracking technologies to collect information about you when you use the Site. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content on third party websites and mobile apps, including online advertisements for our products and services, including online advertisements for our products and services.

We do not control these third parties’ data collection and tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from certain providers, see Choices About How We Use and Disclose Your Information.

How we use your information

We use information that we collect about you or that you provide to us for various purposes depending on how you interact with us, including, but not limited to:

• Providing Products and Services – Like evaluating your applications for our products and services, managing your accounts, offering customer support, communicating with you, and providing online tools.
• Processing Transactions – Like transferring funds, processing payments and other transactions, fulfilling orders, conducting settlements and billing, clearing or reconciliation activities.
• Identity Verification and Fraud Prevention – Like verifying your identity when you apply for products or services, authenticating your login credentials, confirming your location to grant access to your accounts, storing security questions for future verification, assessing fraud risk, and detecting fraudulent transactions.
• Security – Like monitoring network logs, detecting incidents, conducting investigations, and protecting against malicious activities.
• Advertising – Like sending you offers, displaying online ads, targeting offers or promotions, providing sweepstakes, conducting market research, and improving our marketing.
• Analytics – Like analyzing website usage, performance, mobile application features, user interface and experience, feature testing, and debugging.
• Improving Products and Services – Like personalizing and optimizing website and mobile experiences, troubleshooting problems, recognizing users across devices and browsers, enhancing existing products and services, and developing new ones.
• Legal and Business Purposes – Like complying with laws, responding to lawsuits and investigations, defending legal claims, exercising our rights (including for collections on delinquent accounts), resolving disputes, conducting credit risk analysis and reporting, performing compliance and institutional risk control activities, protecting the personal safety of users of the Site or the public, to prevent and defend claims, to resolve dispute managing human resources, and overall business operations.
• Aggregating or Deidentifying Information – Like using or modifying information to prevent identification of you, for example, compiling aggregated statistics to understand trends or feature usage. Aggregated and de-identified data is not subject to this Online Privacy Policy.

Disclosure of your information

We may disclose personal information that we collect or you provide as follows:

• Mergers and Acquisitions–We may share information with a buyer or other successor in connection with a business transaction or potential business transaction, such as a merger, consolidation, acquisition, reorganization, or sale of assets
• Business Partners – We may share information with companies that we have partnered with to offer or enhance products and services.
• Advertising Providers – We may allow companies to collect information through our Site to provide us with advertising services, including targeted or behavioral advertising.
• Service Providers – We may share your information with service providers who assist us with website administration, surveys, technical support, payment processing, and service fulfillment.
• Credit Reporting Agencies – We share information with credit reporting agencies like Experian, Transunion, and Equifax to report or learn about your financial history and for other lawful purposes.
• Legal Obligations – We may disclose information due to legal requirements, such as subpoenas, warrants, court orders or other legal process. Information may also be shared to establish or exercise our rights, defend against legal claims, investigate illegal activities, suspected fraud, safety issues, or policy violations, or to fulfill your request for third-party services.
• Other Third Parties With Your Consent – We may disclose your information to third parties with your consent. For example, you might authorize third parties to access your information for financial services like account aggregation, payments, or tax preparation. Their privacy policies govern the use of your data. We may block third-party access without notice for security reasons.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. The following may provide you with certain control over your information:

• [Universal Opt-Out – We support the Global Privacy Control (GPC), which is a setting that allows you to communicate your privacy preferences to websites and online services that you visit. When we detect a GPC signal from a browser, our Site treats the browser as opted out and to stop sharing personal information for certain targeted advertising purposes, in accordance with applicable laws. Please visit the Global Privacy Control website to learn more about the setting and how to enable it on your browser.]
• Interest-Based Advertising – We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving some targeted ads by visiting the Digital Advertising Alliance Opt Out Page, Network Advertising Initiative Opt Out Page, and TrustArc Preference Manager and by adjusting the privacy settings on your mobile device.
• Manage Cookies On Your Device – You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly. Please note that due to a lack of consistent standards across browsers, our Site does not respond to “do not track” browser settings.
• Google – The Site sends aggregated information to Google Analytics for the purpose of providing us with the ability to conduct technical and statistical analysis on the Site’s performance. Google also uses cookies and other tracking technology to target ads based on a user's browsing history, online activity, and previous interactions with ads. Please review Google’s privacy policy for more information on Google’s privacy practices: https://policies.google.com/privacy. You can opt-out of having your Site activity available to Google Analytics by installing the Google Analytics opt-out browser add-on for the Chrome browser: https://chromewebstore.google.com/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh?hl=en. You can manage your advertising preferences on Google sites and apps (including YouTube) here: https://myadcenter.google.com/.
• Microsoft –Microsoft Clarity and Microsoft Advertising captures how you use and interact with our Site through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. Please review Microsoft’s privacy statement for more information on Microsoft’s privacy practices: https://www.microsoft.com/en-us/privacy/privacystatement. You can manage the use of your data for personalized advertising from Microsoft here: https://account.microsoft.com/privacy/ad-settings.
• Meta (Facebook and Instagram) – The Meta pixel relies on Facebook and Instagram cookies, which enable Meta to match Site visitors to their respective Facebook and Instagram user accounts to deliver targeted advertisements. The Meta Pixel also allows us to track the effectiveness of Facebook and Instagram ads for statistical and market research purposes. Please review Meta’s privacy policy for more information on Meta’s privacy practices: https://www.facebook.com/policy.php and https://privacycenter.instagram.com/policy. You can manage your advertising preferences on Facebook and Instagram here: https://accountscenter.facebook.com/ads/ and https://accountscenter.instagram.com/ads/.
• LinkedIn –The LinkedIn Insight Tag allows us to optimize our marketing campaigns on LinkedIn and retarget advertisements on LinkedIn to visitors of our Site. For more information on the LinkedIn Privacy Policy, go to https://www.linkedin.com/legal/privacy-policy. Please review LinkedIn’s privacy policy for more information on LinkedIn’s privacy practices: https://www.linkedin.com/legal/privacy-policy. You can opt out of retargeting on LinkedIn here: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
• X (Twitter) – X pixels and cookies share information about your interactions on our Site, which enable X to match Site visitors to X user accounts to deliver targeted advertisements. X pixels and cookies also allow us to track the effectiveness of X ads for statistical and market research purposes. Please review X’s privacy policy for more information on X’s privacy practices: https://x.com/en/privacy. You can manage your advertising preferences on X here: https://help.x.com/en/safety-and-security/privacy-controls-for-tailored-ads.

Please note that your preferences will apply only to the specific browser or device from which you disable cookies/opt out. You will need to disable cookies/opt out separately on all your browsers and devices. If you delete cookies, change web browsers, reset your mobile advertising ID, or use a different device, you may need to opt out again.

For certain consumers of our financial products and services, our consumer Privacy Notice governs how we share certain information with our affiliates and third parties, including for their direct marketing purposes, and will enable you to opt out of certain types of sharing.

Data Security

To protect personal information about you from unauthorized access and use, we maintain administrative, technical, and physical measures that are designed to protect information within our company, including security measures required to comply with applicable federal and state laws. We also require our service providers and business partners to whom we disclose the information to do the same. When you transmit sensitive information (such as a debit or credit card number) through the Site, we encrypt the transmission of that information using secure socket layer technology (SSL). We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Data Retention

We will retain, protect, use and share personal information about you as long as it is reasonably required for the purposes described in this Online Privacy Policy, and as required by law, including but not limited to for risk management, regulatory compliance, and audit purposes.

Mobile application access to information stored in you device

The GBC Mobile Banking application requests access to information stored on your device such as location, camera, contacts, or other features you are enrolled in to enrich and simplify the user’s experience and improve services, as well as provide additional security to protect your account. It is important for you to understand that:

• Before granting access to this information, you will be prompted to give the application that permission.
• If you do not wish to grant that permission, you may decline.
• If you later change your mind, those permissions can be updated in your device's settings.
• Alerts about important account activities and certain changes made to your online banking account will be sent to the email address you provided GBC Bank for online banking. E-mail and secure messaging can also be used to send and receive messages from GBC Bank while in the GBC Mobile Banking application.

Application permissions are required to use specific features in the GBC Mobile Banking application:

• Camera

Access to the mobile device camera is required to use remote deposit capture. Remote deposit information is also shared with our third-party check processor.

• Biometrics

Access for identification purposes. The GBC Mobile Banking application does not store biometric information.

• Location

Access to location services for mapping, like to find the nearest branch or ATM.

The GBC Mobile Banking application also stores records of past payments and payments scheduled for the future.

Social Media

We have official pages on social media platforms like Meta/Facebook/Instagram, X/Twitter, and LinkedIn. When you engage with us there, we may gather information such as your likes, interests, and preferences. Social media companies may collect and share information about you with us.

Posts on our social media pages—including pictures, comments, suggestions, or complaints—are visible to other users. Avoid sharing sensitive personal or confidential information in your posts. Please review the privacy policies of our social media partners when using those platforms.

Children’s Privacy

The Site and the services offered through the Site, including the GBC Bank Mobile Banking application, are offered only to individual residents of the United States, excluding its territories, who can form legally binding contracts under applicable law. Without limiting the foregoing, the Service is not offered to minors. Other restrictions and eligibility requirements for the mobile banking service apply as described in the GBC Bank Mobile Banking Terms of Use. We do not knowingly collect any personal information from or about individuals under 18 years of age. Please do not submit such information to us, and as a parent or legal guardian, please do not allow your children to submit personal information without your permission.

Changes to our privacy policy

We may amend this Online Privacy Policy at any time by posting a revised version on the Site. The revised version will be effective immediately at the time it is posted unless a delayed effective date is expressly stated therein. You may (in our discretion) also be provided with an email notification of such amendments. If we make any change in how we use your personal information, we will notify you by email or by means of a notice in the GBC Bank Mobile Banking application prior to the change becoming effective. You may (in our discretion) be required to affirmatively acknowledge or accept the revised Online Privacy Policy in order to continue using the Site. Any use of the Site after a notice of change will constitute your express agreement to such change.

Contact information

To ask questions about this privacy policy and our privacy practices please contact us here.