Privacy Statement

Information Collected by First Commercial Bank

• If you use First Commercial Bank’s websites, mobile applications, or other banking services, First Commercial Bank may collect information about you, including your personal information, information from your mobile device, and other information.
• We may collect information from a variety of sources, including from you directly, from your use of the First Commercial Bank websites, and from third party sources.
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How First Commercial Bank Uses and Shares Collected Information

• We may use information we collect from you to provide you with the banking services, to maintain your account, to communicate with you, to offer you products or services, and for other purposes.
• We may share certain information we collect from you (including personal information) with third parties acting on our behalf, with other financial companies for joint marketing purposes, with credit bureaus, and with other third parties.
• We may share aggregated data with our business partners and other third parties.
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Correcting Personal Information and Opting Out

• You may review and update certain personal information by signing in to your account or by contacting us.
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• You may opt out of receiving certain communications from First Commercial Bank, such as communications regarding marketing or promotions, by clicking on the email opt out link.
• You may change your text message and push notification preferences on your First Commercial Bank mobile application.
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Safeguarding Your Information

• First Commercial Bank is committed to maintaining the security of the data you provide us. However, please note that there is always some risk in transmitting information over the Internet.
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Your California Privacy Rights

• If you reside in the State of California, please follow the "read more" link below to review our privacy notice and policy for California residents to learn about additional rights you may have regarding our handling of your personal information.
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Tracking and Analytics; Location Information

• The First Commercial Bank websites currently do not respond to “Do Not Track” signals from browsers.
• We work with third-party analytics service providers, including but not limited to Google Analytics, and other similar providers, such as search engine optimization (SEO) providers, to help us better understand how you use First Commercial Bank websites. These third parties may collect certain information from you about your online activities over time and across different websites when you use the First Commercial Bank Websites.
• If you install or use a First Commercial Bank Mobile Application, we may collect and use information regarding your mobile device, including technical information about your mobile device and geolocation information.
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Exclusions

• This Privacy Statement does not apply to websites owned by other companies.
• We do not seek to collect, nor do we knowingly collect, information from children under 13.
• If you are located outside of the United States and are using the financial services, you consent to our transfer, processing, and storage of your information in the United States.
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Updates to Privacy Statement

• If we update this Privacy Statement, we will note at the top of this page the date that any changes are made or become effective.
• Your inaction or continued use of the banking services, including access to the First Commercial Bank websites, after any such updates or notices will tell us that you agree to these changes.
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1. INTRODUCTION
   First Commercial Bank, FSB (collectively, “First Commercial Bank” or “we”) is committed to respecting and protecting the privacy of our online visitors and our customers. We recognize that individuals need to understand how their privacy is protected, so we have established the following privacy statement (this “Privacy Statement”) for our users. This Privacy Statement explains what Personal Information First Commercial Bank will collect about you via the First Commercial Bank Websites and the First Commercial Bank Mobile Applications (both as defined below) (collectively, the “Online Services”), as well as from third party sources, and how we will use, protect, and disclose that information to provide you with the Online Services and other banking services (collectively, the “Banking Services”). This Privacy Statement should be read in conjunction with the terms of use for the applicable First Commercial Bank Website, including but not limited to the First Commercial Bank Website Terms of Use. By using the Banking Services or by otherwise providing Personal Information to First Commercial Bank, you consent to First Commercial Bank’s collection, use, and sharing of the data as described in this Privacy Statement.
   
   If you have a financial account with First Commercial Bank (i.e., you are a customer), First Commercial Bank uses and shares your Personal Information in accordance with the First Commercial Bank Customer Privacy Notice, available at https://www.suncrestcontinental.com/content/dam/scb/pdfs/about-scb/PrivacyPolicy.pdf (the “Customer Privacy Notice”).
   
   “Personal Information” means personally identifiable information, such as your name, email address, telephone number, and account numbers. Aggregated data, de-identified data, and other information that is related to you but is studied as a group or does not otherwise identify you specifically (such as information collected through cookies, pixel tags and other technologies) is not considered to be Personal Information.
   
   The “First Commercial Bank Websites” are our websites that are located on the suncrestcontinental.com domain, and that link to this Privacy Statement. The “First Commercial Bank Mobile Applications” include our mobile applications and services, including the First Commercial Bank App.
   
   
2. INFORMATION COLLECTED BY First Commercial Bank
   In order to provide you with the benefits of the Banking Services, First Commercial Bank collects certain information from you, from your devices and applications that you use to access the Banking Services, and from third party sources.
   
   1. Information that You Provide to First Commercial Bank
      You may provide Personal Information, including but not limited to your name, address, email address and phone number, directly to First Commercial Bank. You may provide Personal Information to First Commercial Bank online when you complete an online application form on a First Commercial Bank Website. You may also provide information through your use of the MyLoans websites, provide feedback to us through the First Commercial Bank Websites, provide information to First Commercial Bank customer service representatives online, respond to surveys and questionnaires that we send you, subscribe to newsletters or other communications from First Commercial Bank, or provide Personal Information to us through other online means.
      When you sign up for or maintain a financial account with First Commercial Bank, you may provide the types of Personal Information described in the Customer Privacy Notice, including but not limited to your social security number, date of birth, and checking account information.
      
      
   2. Information Automatically Collected by First Commercial Bank
      In addition to the information you provide, when you use the Online Services, First Commercial Bank may also automatically collect the following types of information (“Automatic Data”) from your devices and applications that you use to access the Online Services. None of the Automatic Data by itself (i.e., when it is not associated with other Personal Information) is deemed to be Personal Information.
      
      • First Commercial Bank Website: If you use the First Commercial Bank Websites, First Commercial Bank may collect certain information from your computer or web browser, including but not limited to your IP address, your browser type, your geographic location, date and time of your visit, and the First Commercial Bank Website pages that you visit (the “Website Data”). We may collect this information through the use of cookies, pixel tags, web beacons and log files. Visit our online privacy preference center to review and manage your preferences.
      • First Commercial Bank Mobile Application: If you choose to use a First Commercial Bank Mobile Application, First Commercial Bank may collect certain information from your First Commercial Bank mobile application and your mobile device, including but not limited to unique device identifier information, GPS/location information, contacts, and Website Data (as defined above). If the First Commercial Bank Mobile Application collects any sensitive information that is not identified here from your mobile device, then First Commercial Bank will notify you before doing so.
   
   
   3. Information Collected from Third Party Sources
      In addition to Personal Information that you provide to First Commercial Bank, First Commercial Bank may also collect information about you, including Personal Information, from third party sources, including but not limited to credit reports from consumer reporting agencies (“Third Party Data”). This includes, but is not limited to, instances in which you affirmatively authorize third parties to provide us with information. Third Party Data includes both Personal Information and information that is not personally identifiable to you.
      
      When you sign up for a financial account with First Commercial Bank, First Commercial Bank may also collect information about you, including Personal Information, from third party sources as described in the Customer Privacy Notice, including but not limited to your credit history, payment history and account balances.
   
   
   4. Information Collected from Online Tools
      First Commercial Bank may feature certain tools through its Online Services, such as online calculators (“Online Tools”). To the extent these Online Tools do not require you to log in or enter your contact information to use the tool, the information you provide as part of the Online Tool is not associated with you or your account and, for purposes of this Privacy Statement, is not considered to be Personal Information.
   
   
3. USE AND SHARING OF COLLECTED INFORMATION
   
   1. Collected Information
      First Commercial Bank may use your Personal Information, Automatic Data, Third Party Data, and Website Data (collectively, the “Collected Information”) to:
      
      • Provide you with the Banking Services or other products, services, and information that you have requested or in connection with the Banking Services;
        
      • Maintain your account and process your transactions;
        
      • Allow you to apply for products or services and process your applications and transactions;
        
      • Manage our business, including performing accounting, auditing, and other internal functions;
        
      • Verify your identity and/or location and authenticate you (such as when you request access to your account information or when you conduct online transactions);
        
      • Communicate with you, including about your account, in response to your requests, to inform you about important information regarding the Banking Services, and to provide you with other administrative information;
        
      • Provide you with customer service;
        
      • Communicate with you about special offers, ads, events, or new products or services that may be of interest to you;
        
      • Evaluate and improve our websites and other offerings;
        
      • Personalize and tailor our services and otherwise enhance the customer experience;
        
      • Conduct research, perform analysis and identify usage trends in order to measure, maintain, protect, develop, and improve our products and services;
        
      • For risk control and fraud detection and prevention;
        
      • To comply with laws and regulations, legal investigations, contractual obligations, and our own internal policies; and
        
      • For other purposes as permitted by applicable law.
        First Commercial Bank may share or disclose Collected Information (including Personal Information) in the following situations:
        
      • With third parties acting on our behalf, such as call center operators, shippers, servicers, marketing providers, people who analyze data for us, and other service providers;
        
      • With other financial companies for joint marketing purposes (i.e., to bring you co-branded services or products);
        
      • If First Commercial Bank is involved in any merger, acquisition, sale of company assets, transition of service to another provider, or insolvency, bankruptcy or receivership, we reserve the right to transfer your Collected Information (including Personal Information) in connection with such transaction;
        
      • If we determine a website or policy violation has occurred, or to enforce the applicable First Commercial Bank Website Terms of Use;
        
      • If we believe such disclosure is necessary to identify, contract or bring legal action regarding injury or interference with the rights and property of First Commercial Bank, including to enforce First Commercial Bank’s rights against unauthorized access or attempted unauthorized access to First Commercial Bank’s information technology assets or against other inappropriate use of the Banking Services;
        
      • To report to credit bureaus;
        
      • To comply with laws, regulations, court orders and subpoenas or similar requests for information by authorities, or as otherwise required by law;
        
      • To respond to an emergency;
        
      • To protect the rights, property, safety and security of you and others; and
        
      • To assist us in fraud, security or technical issues prevention or investigation or otherwise manage risks
        
        
      If you are a First Commercial Bank customer, First Commercial Bank may use and share your Personal Information as described in the Customer Privacy Notice. The Customer Privacy Notice also provides information about whether you may limit certain types of sharing.
      First Commercial Bank does not share your Personal Information with our affiliates and non-affiliated third parties for their own marketing purposes.
   
   
   2. Aggregated Data
      First Commercial Bank may aggregate the Collected Information it collects from its various users (so that it no longer identifies you specifically) and share it with First Commercial Bank’s business partners, marketing partners and other third parties. First Commercial Bank may also store such aggregated data for a reasonable period of time after you terminate your Banking Services account or stop using the Banking Services. The aggregated data may be used by First Commercial Bank or the third parties for analysis and research purposes (including for campaign targeting and generation purposes and to help First Commercial Bank improve its products) or to allow companies to develop better products for First Commercial Bank’s users, among other uses.
   
   
   3. Automatic Data
      In addition to the uses described above, First Commercial Bank may use Automatic Data to improve the Banking Services and to help First Commercial Bank understand how users are using the Banking Services. This information is also collected for statistical analysis, to determine what information is of most and least interest to our users, to improve the utility of the material available on the Banking Services, and for other purposes described in this Privacy Statement. First Commercial Bank may share Automatic Data with First Commercial Bank’s business partners and other third parties (including for the reasons listed above).
   
   
4. REVIEW AND CORRECTION OF PERSONAL INFORMATION
   You may review, correct, and update certain Personal Information (such as your name and contact information) by signing in to your account on the First Commercial Bank Website or the First Commercial Bank Mobile Application and editing your Personal Information in your account.
   
   You may also correct or update your Personal Information by contacting us via the Online Services’ chat functions, through the “Contact Us” section below, or by making the request by postal mail.
   
   
5. OPTING OUT
   
   1. Email Communications
      From time to time, you may receive email communications from First Commercial Bank, including communications regarding product or service information, marketing or promotions, research, and/or other topics.  To contact you, First Commercial Bank may use the information you provide to us, including email, direct (postal) mail, or phone.  You may, at any time, inform us that you do not want First Commercial Bank to contact you with marketing or promotional communications by sending your request using the contact information in the “Contact Us” section below.  You may also opt out of promotional email communications from First Commercial Bank by clicking on a link provided in the marketing or promotional email message. Depending on your opt-out method, your opt-out request may apply to your account or to a specific contact method. After opting out, you will no longer receive marketing or promotional communications but will continue to receive other transactional messages, such as notifications and information relating to your account and your Banking Services.
   
   
   2. Text Messages and Push Notifications
      You may choose to have text messages or push notifications sent to you regarding your account and your Banking Services. You may change your preferences regarding these notifications, including which notifications to receive or disabling such notifications, by logging in to your account through the First Commercial Bank Website or your First Commercial Bank Mobile Application.
   
   
6. SAFEGUARDING YOUR INFORMATION
   First Commercial Bank is committed to maintaining the security of the data you provide us. We use security controls that comply with applicable federal laws to protect against unauthorized access and use of your Personal Information in our custody or control. These measures may include computer safeguards and secured files and buildings. While we are focused on the security of your Personal Information, you must remember that the Internet is a global communications vehicle open to threats, viruses, and intrusions from others. For this reason, First Commercial Bank cannot promise, and you should not expect, that we will be able to protect your Personal Information at all times and in all circumstances. First Commercial Bank cannot guarantee the security and privacy of transmissions via the Internet, and we will not be liable for any lack of security relating to the use of the Banking Services by you. You agree that you will not hold First Commercial Bank liable for any damages resulting from any loss of privacy or security occurring in connection with any such communications.
   
   
7. TRACKING; THIRD PARTY ANALYTICS PROVIDERS; LOCATION INFORMATION
   
   1. Do Not Track Disclosure
      Certain web browsers may provide an option by which you may ask your browser to inform websites you visit that you do not wish your activities to be tracked by cookies or other persistent identifiers, commonly called “Do Not Track Signals.” Because there is not yet a common understanding of how to interpret web browser-based DNT signals other than cookies, the First Commercial Bank Websites do not respond to Do Not Track Signals.
      
      
   2. Third Party Analytics Providers; Google Analytics
      We work with third party analytics service providers, including but not limited to Google Analytics, and other similar providers, such as search engine optimization (SEO) providers, to help us better understand how you use the First Commercial Bank Websites. As a result, these third parties may collect certain information from you about your online activities over time and across different websites when you use the First Commercial Bank Websites.
      For example, we use Google Analytics to learn more about the types of users that visit the First Commercial Bank Websites and to help improve the First Commercial Bank Websites. Google Analytics provides us with certain data regarding the demographics of the users that visit the First Commercial Bank Websites. To provide this service, Google Analytics may collect certain information about you from your computer, including but not limited to: information regarding your visit (such as the pages you visit and the length of your visit), information about your device (such as your IP address), how you got to the website, and other information about you. You can learn more about Google Analytics and how it collects and processes data (including how to control the information sent to Google) by visiting: www.google.com/policies/privacy/partners/. You can opt-out of Google Analytics by using the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout/.
      
      
   3. First Commercial Bank Mobile Applications and Location Information
      If you install or use a First Commercial Bank Mobile Application, we may collect and use information regarding your mobile device, including technical information about your mobile device. In addition, if you allow your device to share location information with our First Commercial Bank Mobile Application, we may be able to collect the location of your mobile device, including GPS location, which is the real-time geographic location of your mobile device. We may use your location information to provide certain features provided through the First Commercial Bank Mobile Application, such as to enable us to provide you with information about branches near you, and to authenticate you. You may choose not to share your location details with us by adjusting or turning off your mobile device’s location services settings, although doing so will prevent certain features in the First Commercial Bank Mobile Application from working properly.
   
   
8. EXCLUSIONS
   The First Commercial Bank Website and the First Commercial Bank Mobile Applications may contain links to websites owned by other companies. Because First Commercial Bank has no control over the privacy practices or content of these linked sites, we recommend that you carefully review the privacy statement of each website you visit. First Commercial Bank is not responsible for the content or privacy practices of websites owned by other companies.
   Unless otherwise specified, the First Commercial Bank Websites and the First Commercial Bank Mobile Applications, including the information provided therein, are intended for use within the U.S.  Accordingly, if you do not reside in the U.S. and are using the Online Services, if you provide Personal Information to us, it may be transferred to and processed on computers in the U.S. and other countries.  The data protection and privacy laws of such other countries, including the U.S., may not afford you the same level of protection as those in your own country. Do not provide your Personal Information to us if you do not want this information to be transferred outside of your country, or if the laws in your country restrict these types of transfers.  Your provision of Personal Information to us will be handled in accordance with this Privacy Statement.  By doing business or interacting with First Commercial Bank, using the Banking Services, or by otherwise providing Personal Information to us, you agree to the terms of this Privacy Statement and are consenting to the transfer, storage, and processing of your personal information to and within facilities located in the U.S. and other facility locations selected by First Commercial Bank.
   This Privacy Statement addresses First Commercial Bank’s procedures for handling the Personal Information of customers in the United States who are at least 13 years old. We do not seek to, nor do we knowingly collect, information from children. If a child has provided us with Personal Information, a parent or guardian of that child may contact us to have the information deleted from our records. To do so, contact First Commercial Bank through the information provided below in the “Contact Us” section.
   
   
9. CONTACT US
   To contact us or to update or change any of the Personal Information that First Commercial Bank has about you, please visit the Contact Us page.
   
   
10. UPDATES TO PRIVACY STATEMENT; CONSENT
    Each time you use the Banking Services, you are indicating your acknowledgement and consent to the collection, use, and disclosure of your Personal Information as set forth in this Privacy Statement.
    
    From time to time, we may update this Privacy Statement. If we do, we will note near the top of this page the date that any changes are made and/or when they become effective. If the changes being made are material (that is, we make a major change in the important points of this Privacy Statement), we may notify you of the changes in a more prominent way, such as through an email. Your inaction or continued use of the Banking Services after the revised Privacy Statement is posted or after any such notices are sent will tell us that you agree to these changes. If you do not accept the terms outlined in this Privacy Statement or the revised Privacy Statement, please do not provide us with Personal Information or use the Banking Services.