The privacy of your information matters to us.
Agreement to Policy
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contained on our Services site is accurate and up-to-date, but there may inaccuracies, typographical errors or outdated information, we therefore make no representations about our Services or any information contained therein.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.
- Categories Of Information We Collect
- How We Collect Information
- How We May Use Information
- How We May Disclose Information
- Protecting Personal Information
- Children’s Privacy
- Online User Activity including Web Cookies
- Your Privacy Choices
- Notice for California Residents
- Advertising; Links to Other Websites and Third Party Content
- Warning Regarding Consolidation Websites and Sharing Credentials With Third Parties
- International Data Transfers and Use
- Changes to this Policy
- Contact Us
1. ) Categories Of Information We Collect
We may collect the following categories of information from you while using our Services and where we believe it is reasonably required for ordinary business purposes:
- Personal information you voluntarily provide: This includes a username and password, contact information (such as name, email address, mailing address, telephone number) and financial information. We may also collect payment card information, social security numbers, and driver’s license numbers (or comparable) that you provide where we believe it is reasonably required for ordinary business purposes such as user authentication and credit reporting. We also receive 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.
- Transactional information associated with banking and other financial services we provide to you: This includes information relating to account management, deposits, withdrawals and other financing and lending activities.
- Information received from third parties: We may receive personal information about you from additional online and offline sources and third parties (e.g., credit reporting agencies) to supplement the information we receive from you.
- Device information: We may collect a unique device identifier or other device information such as browser and operating system in order to provide the Services. We may also collect, use and store information about your location (e.g., GPS or cell tower information). Your personal information and mobile device information (e.g., location and device identifier) may be used for security and user authentication purposes.
- Online User Activity: We also collect certain information in connection with your use of the Services through cookies and other similar technology as described further below.
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.) How We Collect Information
Certain information is collected just by your use of our Services (such as Online User Activity described below). We may offer you the ability to register a user account to access information about your financial account(s) online, in which case you may be asked to provide contact information such as name, address, telephone number and e-mail address, and other information needed to verify your identity and create the account. 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. If you fill out an online application for a new product or service we offer (such as in connection with financial services, we may ask for additional personal and financial information to process the application.
3.) How We May Use Information
We use the personal information and other information referenced above for the following purposes:
- Provide our Services, including to provide access to financial accounts, information and preferences, to process account applications and transactions, to facilitate other account activities, and to provide customer support;
- Operate and improve our business and operations, including internal administration and troubleshooting for our Services;
- Contact you with announcements, promotions, and marketing regarding our products and services, including personalized content or information that you may be interested in;
- Monitor metrics such as total number of visitors, traffic, and demographic patterns; and
- Provide, improve, test, and monitor the effectiveness of the Services, diagnose and fix technology issues, and develop and test new products and features.
We may also use information we collect as we believe to be necessary or appropriate for certain essential purposes, including: (i) for identity verification and to maintain security measures; (ii) to detect, prevent, investigate and respond to fraud, suspicious or other illegal activities, or violations of our terms; (iii) to comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our company policies; and (iv) to protect our rights, privacy, safety or property, operations, security and/or that of our affiliates, business partners, you or others.
When you send us a communication (e.g., email, online chat) we may retain your message and our response for quality assurance, customer service and legal purposes. It is important to remember that regular (non-encrypted) email is not secure. Please do not send us any personal or account information via unsecure channels like email. If you need to communicate sensitive information of this nature to us, please contact the appropriate customer service or lending representative for your account.
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.
4.) How We May Disclose Information
We do not share, rent or sell your information with third parties, except to provide products or services you request and as permitted by law in the following circumstances:
- To our legal affiliates and agents;
- To our third-party service providers that we believe need the information to perform a technology, business, professional, or insurance function for us (e.g., IT services, maintenance and hosting of our website, payment processors), but we only provide information so these individuals or entities can perform their required functions on our behalf;
- To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock;
- Consumer reporting agencies;
- To comply with legal requirements, including, but not limited to, regulatory, court, and law enforcement demands (e.g., subpoenas, court orders, etc.);
- To address fraud, security or technical issues; and
- To respond to an emergency or otherwise to protect the rights, property or security of our company, customers or third parties.
5.) Protecting Personal Information
By registering for or otherwise using the Services you consent to the transfer and use of your personal information anywhere where the Services or our service providers maintain facilities, consistent with this Policy. We keep personal information at least as long as necessary for business purposes, our retention policy, and legal requirements.
We implement commercially-reasonable administrative, physical and technical security measures designed to protect your personal information from unauthorized access, such as by using secured servers and encryption that should prevent unauthorized parties from viewing that information.
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. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your personal information. To the extent the law of your jurisdiction allows for notification of a security or privacy incident via e-mail or the Services, you agree to accept notice in that form.
6.) 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.
7.) Online User Activity including Web Cookies
When you use our Services, we may store a small amount of data on your computer, which is known as a “Cookie.” Cookies act as a way to record passwords, orders, and preferences for visiting a website. Cookies also help us review website traffic patterns, improve the website, and determine what Services are popular. We can also use such information to deliver customized content and advertising to users of the Services whose behavior indicates that they are interested in a particular subject area. We, together with vendors we use, may collect information about your use of our Services by such automated means, including but not limited to cookies and other similar technologies such as pixels. We do not use these tools to track your activity across third party websites.
When you use the Services, the information we may collect by automated means includes, for example: your interaction with our Services (such as the date, time, and length of visits, and specific pages or content accessed during the visits, search terms, frequency of the visits, referring website addresses); device information including the IP address and other details of a device that you use to connect with our Services (such as device type and unique device identifier, operating system, browser type, mobile network information, and the device’s telephone number); and location information where you choose to provide the website with access to information about your device’s location.
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 screen 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. Because there is not yet a consensus on how companies should respond to web browser-based do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals.
8.) Your Privacy Choices
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.
- 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. Popular advertising services you may opt out of targeted advertising from include Google, Facebook, the Network Advertising Initiative and Digital Advertising Alliance.
- User Account: You may address any questions, concerns or issues with your account information by contacting our customer support team
9.) Notice for California Residents
This Section is provided specifically for California residents. Information we collect from or about individuals in connection with any banking activities 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, we may be exempt from other general privacy laws.
Under California privacy laws, to the extent we are not otherwise subject to available exemptions, you may request a copy of the following: (1) the categories of personal information we collected about you; (2) the categories of sources from which the personal information is collected; (3) the business or commercial purpose for collecting or selling (if applicable) the personal information; (4) the categories of third parties with whom we shared personal information, and the categories of personal information shared; and (5) the specific pieces of your personal information that we have collected, used, disclosed, or sold. You may also request that we (and our service providers) correct your personal information if it is inaccurate or delete it. 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 described in this Policy.
In addition to the rights above, you have the right at any time to opt out of (i) any selling or sharing of your personal information to a third party (excluding service providers or other exceptions permitted by law); (ii) any third-party targeted advertising (i.e., cross-context behavioral advertising); and (iii) any use of sensitive personal information (such as precise geo-location or financial information) except for the purposes it was collected and as otherwise permitted by law. Privacy laws may provide you with other opt-out rights which are inapplicable to us. In particular, we do not engage in impactful profiling activities with respect to our customers that is in the scope of California’s general privacy law.
We do not provide a financial incentive or a price or service difference to customers in exchange for the retention or sale of their personal information. We may send promotions or offers to customers or other individuals who subscribe to marketing communications, and unless a customer has opted out of such communications, the customer will continue to receive such notices irrespective of whether any information privacy request described here has been submitted. We do not offer financial incentives to deter customers from making such requests. We do not discriminate against any customer for exercising any privacy rights, including those provided by applicable laws. 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 concern you. We will endeavor to provide a prompt response.
Note that California privacy rights apply to all individuals (not just consumers), including job applicants, current and former employees, contractors and business partners. Due to the nature of these relationships, the collection and use of personal information can vary, but in general terms and in addition to all the disclosures above:
- Job applicants may provide us with personal information as part of an employment application and review process that includes the applicant’s contact information, education and employment history, resume and cover letter. We do not use this information for any purpose other than to evaluate the individual for employment with us and manage our careers program. Job applicants may provide additional information for routine background checks to a third party provider of such services, under specific privacy terms and consents that will be provided at the time of collection.
- Employees receive disclosures during and after onboarding that provides additional details regarding our employee privacy practices.
- We collect contact information and other personal information reasonably necessary to engage and work with contractors and business partners in the course of a business relationship.
California residents can contact us as provided below to request additional information about our privacy practices with respect to their information, as well as submit access, deletion, correction and opt-out requests as described above.
10.) 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 Forbright 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 service 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.
11.) Warning Regarding Consolidation Websites and Sharing Credentials With Third Parties
Please use caution when using consolidation sites. Consolidation sites are websites that offer the ability to access or aggregate all of your personal financial information on one website. In some cases, you may be encouraged to provide a consolidation site with your confidential credentials (such as username and password, bank account number and PIN code). NEVER PROVIDE THIS INFORMATION TO A WEBSITE THAT YOU DO NOT RECOGNIZE AND FULLY TRUST. All transactions initiated by a consolidation site 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.
12.) International Data Transfers and Use
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. Any information you provide through use of the Services may be stored and processed, transferred between and accessed from the United States and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your personal information in accordance with this Policy regardless of where your personal information is stored or accessed.
13.) Changes to this Policy
This Policy should be reviewed periodically as it is subject to change from time to time. When a change has been made, we will post the revised policy on this page with a new “Last Updated” date at the bottom of the page. All changes will become effective when posted unless indicated otherwise.
14.) 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: 12/01/2022