WHAT DOES Austin Capital Bank SSB DO WITH YOUR PERSONAL INFORMATION?

Why?
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?
The types of personal information we collect and share depend on the product or service you have with us. This information can include:
Social Security Number and Payment History
Account Balances and Transaction History
Credit History and Overdraft History

When you are no longer a customer, we continue to share your information as described in this notice.

How?
All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Austin Capital Bank SSB chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information	Does Austin Capital Bank SSB share?	Can you limit this sharing?
For our everyday business purposes- such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus	Yes	No
For our marketing purposes- to offer our products and services to you	Yes	No
For joint marketing with other financial companies	No	We don’t share
For our affiliates’ everyday business purposes- information about your transactions and experiences	No	We don’t share
For our affiliates’ everyday business purposes- information about your creditworthiness	No	We don’t share
For nonaffiliates to market to you	No	We don’t share

Questions?
Call 512-693-3600 or go to https://www.austincapitalbank.com/contact-us/

Who we are

Who is providing this notice?
Austin Capital Bank SSB

What we do
How does Austin Capital Bank SSB protect my personal information?
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secure files and buildings.

How does Austin Capital Bank SSB collect my personal information?
We collect your personal information, for example, when you

• Open an account or Use your credit or debit card
• Pay your bills or Apply for a loan
• Make deposits or withdrawals from your account

We also collect your personal information from other companies.

Why can’t I limit all sharing?
Federal law gives you the right to limit only

• sharing for affiliates’ everyday business purposes — information about your creditworthiness
• affiliates from using your information to market to you
• sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

Definitions

Affiliates
Companies related by common ownership or control. They can be financial and nonfinancial companies.Greenback, Fincorp, Inc a bank holding company.

Nonaffiliates
Companies not related by common ownership or control. They can be financial and nonfinancial companies. Nonaffiliates we share with can include marketing service providers

Joint marketing
A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Nonaffiliate joint marketing partners include financial services companies

Other important information

Special Notice for Texas State Residents: HOW TO FILE A COMPLAINT. Austin Capital Bank SSB is chartered under the laws of the State of Texas and by state law is subject to regulatory oversight by the Department of Savings and Mortgage Lending. Any consumer wishing to file a complaint against Austin Capital Bank SSB should contact the Department of Savings and Mortgage Lending through one of the means indicated below: In person or by Mail: 2601 North Lamar Boulevard, Suite 201 Austin, Texas 78705-4294 Phone: (877) 276-5550 Fax: (512) 936-2003, or through the Department’s website at http://www.sml.texas.gov

Special Notice for Nevada State Residents: We may contact our existing customers by telephone to offer additional financial products that we believe may be of interest to you.  You have the right to opt out of these calls by adding your name to our interna do-not-call list.  To opt out of these calls, or for more information about your opt out rights, please contact our customer service department.  You may reach us by calling 512-693-3600, clicking on the “contact us” link at www.austincapitalbank.com, or writing to Austin Capital Bank, 8100 Shoal Creek Blvd, Austin, TX 78757.  You are being provided this notice under Nevada law.  In addition to contacting Austin Capital Bank, Nevada residents can contact the Nevada Attorney General for more information about your opt out rights by calling 775-684-1100, emailing [email protected], or by writing to: Officer of the Attorney General, Nevada, Department of Justice, Bureau of Consumer Protection, 100 North Carson St, Carson, NV 89701-4717.

Privacy Statement – California

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statement of Austin Capital Bank, SSB {“we”, “us”, or “our”} and applies solely to visitors, users, and others who reside in the State of California {“consumers” or “you”}.  We adopt this notice to comply with the California Consumer Privacy Act of 2018 as supplemented by the California Privacy Rights Act of 2020 {collectively “CCPA”} and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer, household or device {“personal information”}.  In particular, we have collected the following categories of personal information from consumers within the past twelve {12} months:

CATEGORY	EXAMPLES	COLLECTED
A.  Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes
B. Personal information categories	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.  Some personal information in this category may overlap with other categories.	Yes
C. Protected classification characteristics	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	Yes
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other personal purchasing or consuming histories or tendencies.	Yes
E. Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	Yes
F. Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes
G. Geolocation data	Physical location or movements.	Yes
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	No
I. Professional or employment-related information	Current or past job history or performance evaluations.	Yes
J. Non-public education information	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope, such as:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 {HIPAA} and the California Confidentiality of Medical Information Act {CMIA} or clinical trial data;
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act {FCRA}, the Gramm-Leach-Bliley Act {GLBA} or California Financial Information Privacy Act {FIPA}, and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from our clients or their agents.  For example, from documents that our clients provide to us related to the services for which they engage us.
• Indirectly from our clients or their agents.  For example, through information we collect from our clients in the course of providing services to them.
• Directly and indirectly from activity on our website www.austincapitalbank.com.  For example, from submissions through our website portal or website usage details collected automatically.
• From third parties that interact with us in connection with the services we perform.  For example, from credit reporting agencies when obtaining consumer reports in connection with an account/loan application or review.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided.  For example, if you provide us with personal information in order for us to complete, evaluate, and decision a credit application, we will use that information to do so.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
• To improve our website and present its contents to you.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our clients, or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

Under CCPA, the sharing of personal information means sharing, renting, disclosing, disseminating, making available or otherwise communicating a consumer’s personal information to a third party for uses such as targeted advertising for the benefit of the business (us).

California residents have certain rights under the CCPA around limiting the sharing of their personal information.

Sharing of Personal Information for a Commercial Purpose

Sharing of personal information for a commercial purpose is defined as including the sale of a customer’s personal information monetary or other consideration paid to the sharing business.

In the preceding twelve {12} months, we have not shared your information for a commercial purpose.

Disclosure of Personal Information for a Business Purpose

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that information confidential and not to use if for any purpose except performing the contract.

In the preceding twelve {12} months, we have disclosed the following categories of personal information for a business purpose:

            Category A: Identifiers

            Category B: Personal information categories

            Category C: Protected classification characteristics

            Category D: Commercial information

            Category I: Professional or employment-related information

We disclose your personal information for a business purpose to the following categories of third parties:

Service providers.

Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

Sales of Personal Information

In the preceding twelve {12} months, we have not sold personal information.

Retention Period

We may retain your personal information for up to seven {7} years after we finish providing you services or you close an account, complying with our legal obligations, resolving disputes, and enforcing our agreements.  In each case, we will retain your information for no longer than is reasonably necessary.

Your Rights and Choices

The CCPA provides consumers {California residents} with specific rights regarding their personal information.  This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.  Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • Sales, identifying the personal information categories that each category of recipient purchased; and
  • Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.  Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or one of our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act.
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you have previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

            Calling us at (512) 693-3600

            Visiting www.austincapitalbank.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.  You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.  The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time {up to 90 days}, we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.  Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time.  When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (512) 693-3600

Website: www.austincapitalbank.com

Postal Address: 8100 Shoal Creek Blvd, Austin, TX 78757