Internet Privacy Policy

The privacy of your information matters to us.

This Privacy Policy (“Policy”) describes how Forbright, Inc. and its subsidiaries and affiliates, including Forbright Bank, Alliance Partners LLC, The Energy Loan Network, LLC, and Solar Servicing LLC (collectively, “Forbright,” “we,” “us,” or “our”), collect, use, disclose, and protect personal information in connection with your online or offline interactions with us through our websites, portals, mobile applications, and other products or services (collectively, the “Services”). This Policy applies to all Services that link to this Policy, as well as to personal information we process in connection with employment and business relationships. This Policy also serves as our Notice at Collection.

By accessing or using our Services, you consent and agree to all of our posted terms and disclaimers, including this Policy in regard to our use and disclosure of information as described below.

We use reasonable efforts to ensure that information contained on our Services site is accurate and up-to-date, but there may inaccuracies, typographical errors or outdated information, we therefore make no representations about our Services or any information contained therein. Forbright does not warrant that the services will operate error free or be free of computer viruses or other harmful transmissions, and we are not liable if any such computer virus or other transmission causes harm to your computer or data. Our services are offered strictly on an “as is” and “as available” basis, without warranties of any kind, including implied warranties of merchantability, noninfringement or fitness for a particular purpose.

1) Categories Of Information We Collect
We collect personal information that you provide directly to us, that we obtain automatically when you use the Services, and that we receive from third parties. The categories of personal information we collect may include:

  • Personal identifiers: This includes contact information (such as name, email address, mailing address, telephone number), online identifiers, device identifiers, IP address, your signature, Social Security number, driver’s license number, and other government-issued identification numbers.
  • Financial/ transactional information associated with Services: This includes account information; payment card information; information about deposits, withdrawals, and other transactions; lending agreements; servicing and lending activity; and other financial transaction details.
  • Characteristics of protected classifications: This includes your date of birth, gender, military/veteran status, marital status, nationality, and citizenship.
  • Commercial information: This includes records of personal property; products or services that you purchase, obtain, or consider; or other purchasing or consuming histories or tendencies.
  • Biometric data: We may collect biometric data if you choose to provide it for purposes such as user authentication and identity verification.
  • Device & online activity information: We may collect certain personal information automatically when you use our Services, such as your IP address, user settings, MAC address, cookie identifiers, mobile advertising and other unique identifiers, browser or device information, and location information (including approximate location derived from IP address). We may also automatically collect personal information regarding your use of our Services, such as pages that you visit before, during, and after using our Services; and information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services. We may collect this information through cookies and other similar technologies as described further below.
  • Geolocation data: We may collect information about your location (e.g., geographic/geolocation data, GPS, or cell tower information).
  • Audio, electronic, visual, or similar information: This includes recordings of conversations with customer service agents or CCTV footage if you visit one of our locations.
  • Professional or employment information: This includes your title, business contact information, and information about your current employment and employment history.
  • Education information: This includes details about your education and qualifications, such as degrees conferred.
  • Inferences drawn from the information described above.
  • Sensitive personal information: Some of the information that we collect, including Social Security number, driver’s license number, and other government identifiers; financial account log-in information; biometric data; information about your citizenship; geolocation data; and biometric data, may be considered “sensitive” data under applicable privacy laws.

We may also collect other information about you during the course of our relationship, including, but not limited to, information you may provide through the Services (e.g., feedback, inquiries, etc.) and communications between you and us, such as emails or messages regarding the Services. Certain information is collected just by your use of our Services (such as Online User Activity described below). We may also request information when a product or demo is accessed, for regulatory or legal requirements, for newsletter subscriptions, or when additional information about our products or Services is requested.

We may also collect information that you provide to us about other individuals, such as your beneficiaries. If you provide us with information regarding one or more other individual(s), you represent that you have their consent to give us their information and to permit us to use their information in accordance with this Policy.

2) Sources of Information
We collect information directly from you (e.g., through applications, portal use, support communications), automatically via the Services (e.g., using cookies, pixels), and from third parties (e.g., credit bureaus, service providers, advertising/analytics partners). We may receive personal information about you from additional online and offline sources and third parties to supplement the information we receive from you.

3) How We May Use Information
We use the personal information described above for the following purposes:

  • To provide our Services, including to provide you with Services you have requested, manage financial accounts and services, process account applications and transactions, facilitate other account activities, and provide customer or technical support.
  • To consider your application for employment.
  • To maintain a business relationship with you, for example, if you are employed by one of our service providers or business partners.
  • To support our business operations, including accounting, auditing, reporting, and other internal administration.
  • To communicate with you about the Services, such as through announcements, promotions, and marketing regarding products and services, including personalized content or information we think may be of interest to you.
  • To manage, improve, and develop the Services, including monitoring the effectiveness of the Services; diagnosing and fixing technology issues; and enhancing, developing, and testing new products and features.
  • For security and risk management purposes, including for identity verification; to maintain security measures; to detect, prevent, investigate and respond to fraud, suspicious or other illegal activities, or violations of our terms; or to otherwise protect our rights, privacy, safety or property, operations, security, and/or that of our affiliates, business partners, you, or others.
  • For other legal purposes, including to comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations, and our company policies.
  • For any of our other legitimate business purposes.

We may process sensitive personal information for the following purposes:

  • To provide the Services that you request, including to review your application for financial services or for employment.
  • To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information,
  • To resist malicious, deceptive, fraudulent, or illegal actions directed at us or our customers, employees, applicants, or business partners, or to prosecute those responsible for those actions.
  • To ensure the physical safety of natural persons.
  • For short-term transient use, such as non-personalized advertising.
  • For business purposes such as maintaining or servicing accounts, providing customer service, processing or fulfilling transactions, verifying customer information, processing payments, or analytics.
  • To verify the quality or safety of our Services and to improve, upgrade, or enhance the Services.

We do not process sensitive personal information for the purpose of inferring characteristics about you.

We may aggregate data we collect on an anonymous basis that does not identify you for any purpose otherwise allowed by applicable law, such as for research, analysis, modeling, marketing, and advertising, as well as improvement of our Services. We will not attempt to re-identify data that has been deidentified.

4) How We May Disclose Information
We may disclose any of the categories of personal information described in the “How We Collect Personal Information” to any of the following categories of third parties:

  • Affiliates and agents controlling, controlled by, or under common control with our company.
  • Non affiliated third parties as allowable by law and as disclosed in our Privacy Notice. You may have some rights to opt-out in certain circumstances. To exercise those rights, please contact us.
  • Service providers who perform services for us such as technology, business, professional, or insurance services (e.g., IT services, maintenance and hosting of our website, payment processors).
  • Third parties involved in corporate transactions in the event of any proposed or actual reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock.
  • Consumer reporting agencies (as applicable).
  • Government agencies, courts, or law enforcement to comply with legal requests, including, but not limited to, regulatory, court, and law enforcement demands.
  • Emergency/other permitted purposes to protect the rights, property or security of our company, customers, or third parties.
  • With other third parties for legitimate business purposes. We may disclose your personal information to third parties as appropriate to provide the Services or otherwise carry out our business operations.
  • To third parties with your consent. We may disclose your personal information to other third parties with your consent.

Personal data, including phone numbers, collected through the short code program will not be shared with any third parties for their own reasons/purposes. The above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

5) Cookies, Analytics, and Advertising Technologies
We and our partners use cookies, pixel tags/web beacons, session replay, and other analytics tools (“Technologies”) to operate our Services, measure performance, enhance functionality, and deliver content and advertising.

  • Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories:

  • Operationally Necessary. This includes Technologies that allow you access to our Services or its functionality or are required for purposes such as to identify irregular website behavior, prevent fraudulent activity, or improve security.
  • Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below).
  • Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed.
  • Advertising or Targeting-Related. We may use first-party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party digital properties. See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.
  • Analytics. We may use Technologies and other third-party tools for analytics on our Services. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services.

Most web browsers allow you to erase cookies, block cookies, or receive a warning before a cookie is stored. Please refer to your browser instructions or help page to learn more about these functions. If you choose to delete or block cookies, you may not be able to fully experience the interactive features our Services provide.

Certain laws require that operators of websites disclose how they respond to a “Do Not Track” (“DNT”) signal. However, because there is not yet a consensus on how companies should respond to web browser-based DNT mechanisms, we do not currently respond to DNT signals. We may respond to other types of opt-out preference signals.

6) Advertising; Links to Other Websites and Third-Party Content
From time to time, we may establish a relationship with other companies and vendors to provide you with additional value and new products we may not offer ourselves. Our website may offer access to other sites either through the use of hyperlinks or through “co-branded” sites in which both we and the other company share the same URL, domain name or pages within a domain name on the Internet. In some cases, the other site will also collect information from you. This information may include, but is not limited to, name, address, Social Security number, account numbers and date of birth. Please review the privacy policies of these third parties prior to providing any information to them when you link to their website to determine the extent to which third parties may disclose your information.

Our Services may also contain links to other websites or online services, including social media. Please be aware that we are not responsible for the content or privacy practices of such other websites or services, and we encourage you to be aware when you leave our Services and to read the privacy notice of any other website or service that collects personal information.

You may see us advertising on various websites, web pages, social media and other platforms. Please note that online advertising services do not always provide us with complete information about the platforms or website on which our advertising may appear. If you believe that our advertising is being displayed through websites or channels that promote inappropriate or offensive content, please contact us.

7) Account Aggregation & Credential Sharing Warning
Please use caution when using third-party data aggregation services that offer you the ability to access, aggregate, or analyze all of your personal financial information through the service. In some cases, you may be encouraged to provide the third-party provider with your confidential credentials (such as username and password, bank account number and PIN code). NEVER PROVIDE THIS INFORMATION TO A THIRD PARTY THAT YOU DO NOT RECOGNIZE AND FULLY TRUST. All transactions initiated by a third party using access information you provide are considered to be authorized by you, whether or not you were aware of the specific transaction. You are also solely responsible for any fraud, loss of funds, or other harm that results from your sharing confidential credentials with any third party.

8) Protecting Personal Information

We implement commercially-reasonable administrative, physical, and technical security measures designed to protect your personal information from unauthorized access.

However, no data transmission or storage is 100% secure, and we cannot guarantee that information you send to us online or via email, or information that we maintain about you, will not be accessed, disclosed, altered, or destroyed without authorization. Please exercise caution when disclosing your personal information online.

9) Retention of Personal Information

We retain the personal information that we collect for as long as needed to provide the Services and to comply with our legal obligations and operate our business. The criteria for determining the duration for which we will retain your personal information includes: the Services you request from us, the nature of our relationship with you (e.g., customer, business, employment), legally-required retention periods, business needs, and whether there are any relevant legal proceedings.

10) Children’s Privacy

We provide general audience Services and do not knowingly collect personal information from children under the age of 13 or anyone that is not of legal age to agree to our posted terms and this Policy. Please notify us if you believe we received personal information from a child under 13 through the Services. In the event we learn that we received personal information from a child under 13 without parental consent, we will endeavor to promptly delete that information.

11) Your Privacy Choices and Rights

We offer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you.

  • Accessing and Correcting Your Information: Keeping your account information up-to-date is very important. You can generally review or update your personal information and transactions by logging in to the Services or by contacting us. If parts of our Services have been transferred to another entity, then you will have to update your personal profile with that entity. You will be provided with notice of any Services transfer in writing. If you believe that information reported by the credit reporting agencies is inaccurate, please contact the credit bureaus to make any changes.
  • Marketing Emails: From time to time, we may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. You may unsubscribe from a particular e-mail marketing list at any time by selecting the “unsubscribe” option within the body of the e-mail. Even if you opt out of receiving such communications, we will continue sending you non-marketing email communications, such as administrative or transaction alerts, or information about changes to our terms of service.
  • Cookies: As noted above, web browsers may offer users the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our Services may not function correctly.
  • Targeted Advertising: We may potentially work with advertising partners who collect information about your online activities and provide you with choices regarding the use of your browsing behavior for purposes of targeted advertising. You may opt out of targeted advertising using provider-specific mechanisms or industry-opt out tools provided by https://optout.aboutads.info/
  • User Account: You may report any questions, concerns, or issues with your account information by contacting our customer support team.

Depending on your state, you may have additional data privacy rights, subject to legal exceptions. Due to the regulated nature of our industry, we are generally not able to delete consumer transactional data or certain demographic or account information.

This Section is provided specifically for residents of states that confer additional privacy rights. Information we collect from or about individuals in connection with any financial services is treated in accordance with applicable federal and state laws, which may include the Gramm-Leach-Bliley Act (“GLBA”) and Fair Credit Reporting Act (“FCRA”). As a financial institution subject to specific privacy and security laws and regulations, the data we collect may be exempt from certain requirements under other privacy laws.

Notice at Collection: You can find a list of the categories of personal information that we collect, including the categories of sensitive personal information, in the “Categories of Information We Collect” section above. For details regarding the business and commercial purposes for which we collect personal information and how long we retain personal information, see the “How We May Use Personal Information” and “Retention of Personal Information” sections, respectively.

You may have the following rights in your state of residence, subject to certain exceptions:

  • Right to know: You may have the right to know what information we have collected about you, including: (1) the categories of personal information; (2) the categories of sources from which we collect personal information; (3) the business or commercial purpose for collecting or selling (if applicable) the personal information; and (4) the categories of third parties to whom we disclosed personal information, and the categories of personal information disclosed.
  • Right to access: You may have the right to access the specific pieces of personal information that we have collected about you.
  • Right to correct inaccurate personal information: You may request that we (and our service providers) correct your personal information if it is inaccurate.
  • Right to delete: You may have the right to request that we delete personal information we maintain about you. Deletion requests are subject to certain limitations, for example, we may retain information as permitted by law, such as for tax or other record keeping purposes; to maintain an active account; to process transactions and facilitate customer requests; and for certain other internal business purposes.
  • Right to opt-out of the sale of personal information or sharing for cross-context behavioral advertising: You may have the right to opt out of the sale or sharing of your personal information. You may opt out of such disclosures by clicking here.
  • Right to limit our use and disclosure of sensitive personal information: You may have the right to request that we limit our use and disclosure of sensitive personal information to purposes permitted under applicable law. You may submit that request by clicking here.

We will not discriminate or retaliate against anyone for exercising any privacy rights.

You may submit requests by completing the online form or by emailing privacyrightsrequests@forbrightbank.com. When submitting via email, please include your full name, type of request and the email address associated with your account. This email address is intended solely for processing your privacy requests. Before processing a verifiable consumer request, we will take reasonable steps to verify the identity of the individual submitting the request. Verification may include confirmation through the consumer’s email address and/or submission of a valid government-issued ID, such as a driver’s license. We may request additional information as necessary to verify the request and protect personal information from unauthorized access or disclosure.

You may designate an authorized agent to submit a request on your behalf. To do so, you must: (1) provide that authorized agent written and signed permission to submit such request; and (2) verify your own identity directly with us. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

If we deny a privacy request, you may appeal the decision to us at the contact information provided below. To the extent possible, please describe the basis for your appeal and if there is any specific personal information that concerns you. We will endeavor to provide a prompt response.

12) International Data Transfers
Our Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than those of the United States.

If you use the Services, your personal information may be processed by us or our service providers in the U.S. or other jurisdictions where privacy laws may be less stringent than the laws in the jurisdiction in which you reside. By using the Services, you agree to the transfer, storage, and processing of your personal information in jurisdictions in which we or our service providers operate, including but not necessarily limited to, the United States.

13) Updates to this Policy
We may update this Policy from time to time in our sole discretion to reflect changes in our practices, applicable law, or other circumstances. When we make changes to this Policy, we will post the revised Policy on this page with a new “Last Updated” date at the bottom of the page. If we make material changes, we may provide you with notice in accordance with applicable law. All changes will become effective when posted unless indicated otherwise. Please visit this page periodically to review the most up-to-date version of this Policy.

14) How to Contact Us
If you have any questions about our privacy practices, want to make any requests regarding your personal information, or having any other related concerns, please refer to our Contact page.

Last Updated: 08/2026