Website Privacy Policy
Column, N.A. (“Company,” “we,” or “us”) wants you to be familiar with how we collect, use, and disclose information online. This Website Privacy Policy describes our practices in connection with information that we collect through:
- Our websites located at www.column.com and www.norcalbank.com and their related webpages (the "Websites");
- Our social media pages; and
- Email messages that we send to you that link to this Policy or other communications with you.
Collectively, we refer to the Websites, social media pages, and emails as the "Services".
Please note that this Policy does not apply to third-party websites and applications from which you may apply for or access our financial products and services.
This Policy also does not apply to information that we process on behalf of our enterprise customers as a service provider. Our use of such information is governed by our agreements with those businesses.
If you are a consumer of our financial products and services that are intended for personal, family or household purposes, you may also refer to our GLBA Notice for information about how we handle information subject to the Gramm-Leach-Bliley Act. If you are a California resident, please see our California Consumer Privacy Policy for additional information about our handling of information and privacy rights you may have under the California Consumer Privacy Act.
PERSONAL INFORMATION
"Personal Information" is information that identifies you as an individual or relates to an identifiable individual. The Services collect Personal Information, including:
- Name
- Unique personal identifiers and government-issued identifiers
- Mailing address
- Telephone number
- Email address
- Business information
- Transaction information
- Login information
- Online Identifiers such as Internet Protocol (IP) address (we may also derive your approximate location from your IP address)
Collection of Personal Information
We and our service providers collect Personal Information in a variety of ways, including:
- Through the Services.
- We collect Personal Information through the Services, for example, when you sign up for information, register an account to access the Services, or contact customer service.
- From Other Sources.
- We receive Personal Information from other sources, for example:
- publicly available databases;
- marketing partners; and
- business partners.
We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services.
Use of Personal Information
We and our service providers use Personal Information for the following purposes:
- Providing the functionality of the Services and fulfilling your requests.
- To provide the Services' functionality to you, such as arranging access to your registered account, and providing you with related benefits or customer service.
- To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments, or complaints, or when you request information about our Services.
- To complete your transactions, verify your information, and provide you with related benefits, or customer service.
- To send administrative information to you, such as changes to our terms, conditions, and policies.
- Providing you with our newsletter and/or other marketing materials.
- To send you marketing related emails, with information about our services, new products and other news about our company.
- Analyzing Personal Information for business reporting and providing personalized services.
- To analyze or predict our users' preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
- To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
- To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
- Aggregating and/or anonymizing Personal Information.
- We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
- Accomplishing our business purposes.
- For data analysis, for example, to improve the efficiency of our Services.
- For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements.
- For fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
- For developing new products and services.
- For enhancing, improving, repairing, maintaining, or modifying our Services, as well as undertaking quality assurance measures.
- For identifying usage trends, for example, understanding which parts of our Services are of most interest to users.
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
- For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users' interests.
Disclosure of Personal Information
We disclose Personal Information to our third-party service providers, in order to facilitate services that they provide to us. These can include providers of services such as website hosting, data analysis, payment processing, fraud prevention, information technology and related infrastructure provision, customer service or related benefits (including special promotions), email delivery, auditing, and other services.
We may also use and disclose Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, to respond to requests from public and government authorities, to cooperate with law enforcement, or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, and/or that of you or others. We may use, disclose or transfer your information 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 assets or stock (including in connection with any bankruptcy or similar proceedings).
OTHER INFORMATION
"Other Information" is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:
- Browser and device information
- Usage data
- Information collected through cookies, pixel tags and other technologies
- Demographic information and other information provided by you that does not reveal your specific identity
- Information that has been aggregated in a manner such that it no longer reveals your specific identity
Collection of Other Information
We and our service providers may collect Other Information in a variety of ways, including:
- Your browser or device.
- Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the version of the Services you are using. We use this information to ensure that the Services function properly.
- Cookies.
- Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them to you. We may also use cookies or other technologies in online advertising to track responses to our ads. We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. You also may not receive advertising or other offers from us that are relevant to your interests and needs.
- Pixel tags and other similar technologies.
- Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
- Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google's practices by going to www.google.com/policies/privacy/partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
- Invisible reCAPTCHA. We use Google's invisible reCAPTCHA application on our Services in order to protect against spam and other automated abuse. The reCAPTCHA tool may make use of cookies, as well as other information like IP address, date, time, language, screen size and resolution, and mouse movements. The use of the reCAPTCHA tool and any information collected through the tool are subject to Google's privacy policy, available at https://policies.google.com/privacy, and Google's terms of service, available at https://policies.google.com/terms?hl=en.
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
SECURITY
We seek to use organizational, technical, and administrative measures that are designed to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the "Contacting Us" section below.
MARKETING CHOICES
If you no longer want to receive marketing-related emails from us, you may opt out by following the unsubscribe option in the communication. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.
THIRD-PARTY SERVICES
This Website Privacy Policy does not address, and we are not responsible for, the privacy, security, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us.
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, or any other social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with our Services.
USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of 13, and we do not knowingly collect Personal Information from individuals under 13.
UPDATES TO THIS WEBSITE PRIVACY POLICY
The "LAST UPDATED" legend at the top of this Website Privacy Policy indicates when this Policy was last revised. Any changes will become effective when we post the revised Policy on the Services. If we make any material changes to our data privacy practices, we will notify you in accordance with applicable legal requirements.
CONTACTING US
If you have any questions about this Website Privacy Policy, please contact us at privacy@column.com, or:
Column National Association
A4-700 1 Letterman Drive
San Francisco, CA 94129