Privacy

Privacy Policy

California Consumer Privacy Act

CCPA Notice at Collection

Internet Privacy Statement

Mobile Privacy Policy

Privacy Policy 

Rev. 1/2011

California Consumer Privacy Act Policy

Last Updated January 1, 2023

This California Consumer Privacy Act Policy (“Privacy Policy”) is being provided to comply with the California
Consumer Privacy Act of 2018 (“CCPA”) and is applicable to individuals that are California residents (as defined in
the CCPA). This Privacy Policy explains how we collect, use, and disclose personal information concerning California
residents and explains certain rights that California residents have under the CCPA.

Personal information is information that identifies, relates to, or could reasonably be linked directly or indirectly
with a California resident. The specific personal information that we collect, use, and disclose will vary based on your
relationship or interactions with us. For example, we collect personal information to provide consumer and business
financial products and services, for our general business purposes, and for our employment and human resource
purposes. The CCPA, however, does not apply to certain information, such as information that we collect about
consumers who apply for or obtain our financial products and services for personal, family, or household purposes
which are subject to the Gramm-Leach-Bliley Act (“GLBA”). For information about how we collect, disclose, and
secure information relating to these customers, please refer to our GLBA Privacy Notice.

Collection and Disclosure of Personal Information

In the past 12 months, we may have collected and disclosed to third parties, for our business purposes, the following categories of personal information.

• Identifiers, Identifiers such as a real name, alias, postal address, unique personal identifier, online
  identifier, Internet Protocol (IP) address, email address, account name. This category includes the
  collection of sensitive personal information including social security number, driver’s license, state
  identification card, or passport number.
• Additional Data Subject to California Civil Code Section 1798.80 such as your telephone number,
  signature, and physical description.
• Characteristics of protected classifications under California or federal law such as citizenship, age, sex,
  and marital status. This category includes the collection of sensitive personal information including racial
  or ethnic origin.
• Commercial Information such as products or services obtained or considered, bank information,
  transaction histories, and account and card numbers.
• Biometric Information such as fingerprints and voiceprints. This category includes the collection of
  sensitive personal information such as hand/palm scan, fingerprints, and facial recognition.
• Internet or Network Activity such as interactions with our website, mobile applications, IP address and
  username.
• Geolocation Data such as device location and IP address location.
• Sensory Information, audio, electronic, visual, and similar information, such as call and video recordings.
• Professional or Employment-Related Information such occupation and employer, income, employment
  history and prior employer contact information.
• Education Information such as school related information
• Inferences based on information about an individual to create a summary about, such as an individual’s
  preferences and characteristics, intelligence, abilities, and aptitudes.

We collect the personal information referenced above from the following sources

• Directly from you or an individual acting on your behalf.
• Service providers in connection with banking products and services.
• Service providers or other third parties who provide services on our behalf, such as credit agencies.
• Service providers in connection with human resource activities and workforce management.
• Government entities and other publicly available sources.
• Website/mobile app activity/social media.
• Information from client directed third parties or institutions representing a client/prospect.
• Information from business clients about individuals associated with the business (e.g., a guarantor for a
  business loan, authorized signer for a business account, an employee or board member).

We have disclosed each of the above-listed categories of personal information concerning California residents for
our business purposes to one or more of the following categories of third parties.

• Our affiliate that may use the personal information consistent with this policy.
• Service providers to conduct day-to-day business, including to maintain or service accounts, provide
  customer service, process transactions and payments, verify customer information, provide online and
  mobile services, fraud and security monitoring and protection services, maintain websites and technology
  infrastructure.
• Service providers and professional services organizations who provide services on our behalf, such as
  auditors, accountants, and law firms.
• Service providers that provide human resource and employment related services.
• Government entities and related third parties as required to comply with laws and regulations.
• Data analytics providers.
• Operating systems and platforms.

In the past 12 months, we have used personal information concerning California residents to operate, manage, and
maintain our business, to provide our products and services, and to accomplish our business purposes and
objectives, including the following.

• Performing services, including maintaining or servicing accounts, providing customer service, processing
  transactions and payments, verifying customer information, providing financing, engaging in advertising
  or marketing, performing analytics or similar services.
• Performing business operations including vendor contract negotiations and payments.
• Auditing compliance with our policies, procedures, applicable legal and regulatory laws and regulations.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and
  prosecuting those responsible for that activity.
• Undertaking activities to verify or maintain the quality or safety of a product or service controlled by us,
  and to improve, upgrade, or enhance the service.
• Debugging to identify and repair errors that impair existing or intended functionality.
• Undertaking internal research for technological development and demonstration.
• Employment related services, including evaluating job applicants, administering and servicing
  employment records and benefits, processing payroll, tracking time and attendance, obtaining and
  verifying background checks.
• Complying with laws and regulations and to comply with other legal processes and law enforcement
  requirements.

Personal Information Sold or Shared

In the past 12 months, we have not sold or shared, as defined in the CCPA, personal information or sensitive
information, including personal or sensitive information of minors under the age of 16.

Sensitive Personal Information
We only use or disclose sensitive personal information for the following purposes consistent with the CCPA
regulations.

• To provide requested products or services.
• To detect and investigate security incidents.
• To resist malicious, deceptive, fraudulent, or illegal actions and to prosecute those responsible.
• To ensure the physical safety of natural persons.
• To perform services including maintaining and servicing accounts, providing customer service, processing
  transactions and payments, verifying a California resident’s information, providing financing, or providing
  similar services.
• To verify or maintain the quality or safety of a product or service and to improve or enhance the product
  or service.
• For short-term transient use.

Rights under the CCPA

If you are a California resident you have the right to request that we:

1.  Disclose to you the following information covering the 12-month period prior to your request:

• The categories of personal information collected and the categories of sources from which we collected
  the personal information,
• The business or commercial purpose for collecting the personal information,
• The categories of third parties with whom we shared the personal information, and the categories of
  personal information shared,
• The specific pieces of personal information we collected about you.

2.  Delete personal information we collected from you; and

3.  Correct inaccurate personal information that we maintain about you.

Please be aware that there are circumstances in which the law does not require or allow us to fulfill your request.

We will not discriminate against you because you exercised your rights under the CCPA, Including an employee’s,
applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights.

To Make a Request

You may make a request by:

• Calling our toll-free number at 800-652-2871, option #7;
• Inquiring at a branch office, or
• Completing an online Personal Information Request.

When you make a request, we will verify your identity using standard verification methods, utilizing information that
we already have about you. We will ask you to provide verifying information, such as your name, email, postal
address, and phone number. We may also ask you to certify under penalty of perjury that you are a California
resident. We will review the information provided and may request additional information to ensure we are
interacting with the correct individual. 

Your authorized agent may also make a request on your behalf. When submitting a request on behalf of another
person, we may require proof of authorization and verification of identity directly from the person for whom you
are submitting a request

Changes to Our Privacy Notice

We may change or update our Privacy Policy from time to time. When we do, we will post the updated Privacy
Policy to our website.

Contact for More Information

If you have any questions or concerns about our privacy practices or this Privacy Policy, you may call us at (951)
766-4100 or write us at HCN Bank, Client Services, P.O. Box 12002, Hemet, CA 92546-8002. 

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Internet Privacy Statement

Visitors to Our Website

Visitors to our website remain anonymous, unless they register for a service or otherwise elect to disclose their identity to us. Although we do not collect personally identifying information about persons who simply visit our site, we do collect certain limited information about visitors, such as their IP address (a unique numeric address assigned automatically to computers when they access the Internet). We also may place "cookies" on a computer to track a visitor's use of our website through Google Analytics. A cookie is a small piece of data that is stored on your hard drive. We sometimes use cookies to help estimate the number of visitors to our site and to determine which areas are most popular. The cookie does not provide us with any personally identifying information about you, such as your name or address unless you register with us for a service such as our Online Banking service.

You may refuse to accept these cookies through the privacy settings on your internet devices and browsers. However, if you do not accept these cookies; you may experience some inconvenience in your use of our website and some online products and services. For example, we will not be able to recognize your device for online banking and you will need to answer a challenge question each time you log on.

California Do Not Track Disclosure - There are no current standards for "Do Not Track" consumer browser settings on commercial websites; therefore, we do not respond or take action with respect to the "Do Not Track" configuration set on your browser.

IP Address

An Internet Protocol ("IP) address is a unique string of numbers that is assigned to your computer by your Internet Service Provider. Web servers automatically identify your computer by it IP address. We may use your IP address to help diagnose problems with our server and to administer our website. Your IP address also may be used to gather broad demographic information.

Links to Other Sites

Our website may contain hyperlinks and pointers to internet sites maintained by third parties. These links are provided for your reference only. We do not control or operate such third-party sites. Many third-party sites have their own privacy policies that differ from ours. This privacy notice only covers our website and does not cover any other site. While we make every effort to keep our information secure, we do not control the policies of other sites.

Children's Privacy

We do not knowingly solicit data from persons under the age of 13, and we do not knowingly market to persons under the age of 13. We recognize that protecting children's identities and privacy online is important and that the responsibility to do so rests with both the online industry and with parents.

If you a have any questions about this Privacy Notice, please contact us by calling (951) 766-4100.

The accuracy of the information HCN Bank maintains is very important. If you believe we have information about you that is incorrect, outdated or incomplete, or if the information you think is wrong appears on a statement or notice from us, you should call us at (951) 766-4100 or the telephone number shown on the statement or notice. We will look into this matter and correct our records as appropriate.

HCN Bank may update this Privacy Policy from time to time. If we make any material change to this Statement or in how we use your personally identifiable information, we will prominently post such change prior to implementing it.

Mobile Privacy Policy

HCN Bank Mobile Banking (the “App”)—powered by Fiserv—helps you manage your money, view your transactions and accounts, making it easy to manage your finances on the go.

This Privacy Notice, in combination with other relevant privacy notices (e.g., pursuant to financial privacy laws), informs you of the policies and practices regarding the collection, use and disclosure of any personal information that the App collects from or about users in connection with our mobile application. You can find more information about our privacy policies on our website or by contacting us.

The App allows you to:

• Get real-time balances for your accounts.
• Manage your money.
• View your transactions and statements.
• Make transfers.
• Pay your bills and manage billers.
• Deposit a check.
• Receive alerts.
• Manage cards.

THE TYPES OF INFORMATION COLLECTED

 The App may collect personal information from you in the following ways:

(a) Personal Information You Provide to Us

• We may collect personal information from you, such as your first and last name, address, email, User IDs, telephone number, and social security number when you create an account and use the App. This information could include your address or contacts where you choose to make them available (e.g., to make P2P (peer to peer) payments using Zelle or other payments functionality).
• We may collect the financial and transaction information necessary to provide you with the App, including account numbers, payment card expiration date, payment card identification, verification numbers, and transaction and payment history.
• If you provide feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply.
• We also collect other types of personal information that you provide voluntarily, such as any information if you contact us via email regarding support for the App.

(b) Personal Information Collected from Third Parties—We may collect certain information from identity verification services and consumer reporting agencies, including credit bureaus.
(c) Personal Information Collected Via Technology—We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with the App, our communications, and other online services, such as:

• Device data, such as your computer's or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state, or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
• Cookies, which are text files that websites store on a visitor’s browser to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that an email was accessed or opened, or that certain content was viewed or clicked.
• Location Information. If you have enabled location services on your phone and agree to the collection of your location when prompted by the App, we will collect your location information when you use the App; for example, to provide our fraud detection services. If you do not want us to collect this information, you may decline the collection of your location when prompted or adjust the location services settings on your device.

HOW WE USE YOUR INFORMATION COLLECTED IN THE APP
(a) General Use—In general, we use your personal information to respond to your requests as submitted through the App, to provide you the services you request, and to help serve you better. We use your personal information in the following ways:

• Facilitate the creation of, and secure and maintain your account;
• Identify you as a legitimate user in our system;
• Provide improved administration of the App;
• Provide the services you request;
• Improve the quality of experience when you interact with the App;
• Send you administrative email notifications, such as security or support and maintenance advisories; and
• Send surveys, offers, and other promotional materials related to the App.  

(b) Compliance and protection—We may use your personal information to:

• Comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities;
• Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• Audit our internal processes for compliance with legal and contractual requirements and internal policies;
• Enforce the terms and conditions that govern the App; and
• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

(c) Creation of Non-Identifiable Data— We may create de-identified information records from personal information by excluding certain information (such as your name) that makes the information personally identifiable to you. We may use this information in a form that does not personally identify you to analyze request patterns and usage patterns to enhance our products and services. We reserve the right to use and disclose non-identifiable information to third parties in our discretion.

DISCLOSURE OF YOUR PERSONAL INFORMATION
We disclose your personal information as described below.
(a) In Accordance with Our Other Privacy Notices—Other than as described in this Privacy Policy in connection with the App, this Privacy Policy does not apply to the processing of your information by us or third parties with whom we share information.
(b) Third Party Service Providers—We may share your personal information with third party or affiliated service providers that perform services for or on our behalf for the purposes described in this Privacy Policy, including: to provide you with the App; to conduct quality assurance testing; to facilitate the creation of accounts; to optimize the performance of the App; to provide technical support; and/or to provide other services to the App.
(c) Corporate Restructuring - We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction involving the sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If our business or assets are acquired by another company, that company will possess the personal information collected by us and the company will assume the rights and obligations regarding your personal information as described in this Privacy Notice.
(d) Authorities and Others—Regardless of any choices you make regarding your personal information, we may disclose your personal information to law enforcement, government authorities, and private parties, for the compliance and protection services described above.

LINKS TO OTHER SITES
The App may contain links to third party websites. When you click on a link to any other website or location, you will leave the App and go to another site, and another entity may collect personal and/or anonymous information from you. Our provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites. We encourage you to read the privacy policy of every website you visit.

YOUR CHOICES REGARDING YOUR INFORMATION
You have several choices regarding use of information on the App.

(a) How We Respond to Do Not Track Signals—Some web browsers transmit “do not track” signals to the websites and other online services with which your web browser communicates. There is currently no standard that governs what, if anything, websites should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard is established, we may revise its policy on responding to these signals.

(b) Access, Update, or Correct Your Information—You can access, update, or correct your information by changing preferences in your account. For additional requests, please contact us.

(c) Opting Out of Email or SMS Communications—If you have signed-up to receive our email marketing communications, you can unsubscribe any time by clicking the "unsubscribe" link included at the bottom of the email or other electronic communication. Alternatively, you can opt out of receiving marketing communications by contacting us at the contact information under "Contact Us" below. If you provide your phone number through the App, we may send you notifications by SMS, such as provide a fraud alert. You may opt out of SMS communications by unlinking your mobile phone number through the App.

(d) Opting Out of Location Tracking—If you initially consented to the collection of geo-location information through the App, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. Please note, however, that if you withdraw consent to our collection of location information, you may no longer be able to use some features of the App.

SAFEGUARDS AND RETENTION
We implement reasonable administrative, technical, and physical measures in an effort to safeguard the information in our custody and control against theft, loss and unauthorized access, use, modification, and disclosure. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information.

A NOTE ABOUT CHILDREN
The Services are not directed towards individuals under the age of 13, and we do not intentionally gather personal information about visitors who are under the age of 13. If a child under 13 submits personal information to us and we learn that the personal information is the information of a child under 13, we will attempt to delete the information as soon as possible.

PRIVACY NOTICE UPDATES
This Privacy Notice is subject to occasional revision. We will notify you of any material changes in its collection, use, or disclosure of your personal information by posting a notice on the App. Any material changes to this Privacy Notice will be effective thirty (30) calendar days following notice of the changes on the Services or immediately where no notice is given. These changes will be effective immediately for new users of the App. If you object to any such changes, you must notify us prior to the effective date of such changes that you wish to deactivate your account. Continued use of the App following notice of any such changes (or use of the App after such changes) shall indicate your acknowledgement of such changes.

CONTACT US
If you have any questions or complaints about this Privacy Notice or our data collection or processing practices, or if you want to report any security violations to us, please contact us by email at: hcnclientservices@hcnbank.com; or by mail at:
HCN Bank
PO Box 12002
Hemet, CA 92546-8002