Online Privacy Policy
Effective as of January 1, 2023

Vivid Crest Bank and each of its affiliate companies (collectively, “Vivid Crest Bank ”, “we” or “us”) is committed to protecting your privacy at all times.

Please read this Online Privacy Policy (the “Policy”) carefully before using the Vivid Crest Bank (“Bank”) website (the “Site”). The Bank, a federal savings bank headquartered in Utah, is the owner of the Site and the services provided through them (the “Services”), although software, hosting and other functions and content may be provided by the Bank’s service providers, affiliates or business partners. This Site is exclusively directed to, and intended for, legal residents of the United States who are adults of a capacity to contemplate and enter into a lawful contract for banking purposes. The Bank does not knowingly solicit information from, and does not knowingly market any products or services to, minors or non-U.S. residents. If you are under the age of 18, you are not permitted to set up an account through the Site, and do not enter your personal information.

This Policy, together with the Website Usage Agreement which is incorporated herein by reference and attached at the end of this Policy, describes the types of information we may collect from visitors to the Site, what we do with this information, and how visitors can update and control the use of information they provide on the Site. This Policy applies solely to information collected through this Site. This Policy does not apply to other data we collect, including data collected on other websites, such as separate websites operated by our affiliates or business partners, or information visitors may provide to us through unsolicited email or other means.

INFORMATION COLLECTED

Through the use of or access to our Site for online inquiry regarding the products and services we offer (“Services”) or otherwise, we may collect personal information about you, which is information that identifies you as an individual, relates to you as an individual, or that, along with other information, could identify you (“Personal Information”). We do not require you to provide any Personal Information in order to navigate our Site. However, we collect the following types of Personal Information:

Information Provided by You

We collect Personal Information from you when you:

Information Collected Automatically

We may automatically collect the following Personal Information as you use our Site or Services:

Information Obtained from Third Parties

We may obtain Personal Information about you from third parties, such as credit bureaus and demographic firms, when you use our Site or Services.

Cookies and Other Tracking Technologies

Cookies. “Cookies” are small pieces of data stored by your Internet browser on your computer’s hard drive. If you visit our Site, a cookie is used to help us measure the number of visits, average time spent, page views and other statistics relating to our Site. This cookie by itself does not tell us your email address or who you are. If you decide to register online or request information, products or services from us, we may collect additional information to provide tailored offerings or content to you or to deliver such products and services. In this case, we use cookies to allow us to recognize you on subsequent visits, enhance your online experience and make our provision of products and services more efficient. We do not use cookies to get data from your hard drive or to get your email address. Third parties may also place and store Internet cookies on your hard drive for web analytics and analytics advertising services. These third-party cookies collect information about our Site traffic by tracking users across websites and across time and generating reports for us to better understand our Site users and to create audiences for our advertisements based on such understanding.

Google and Adobe Analytics. We use tools called “Google Analytics” and “Adobe Analytics” to collect some information we listed above about your use of the Services or visits to the Site. We use the information we get from Google Analytics and Adobe Analytics to improve the Services. In order to collect this information, Google Analytics and Adobe Analytics may set cookies on your browser or mobile device, or read cookies that are already there. Google Analytics and Adobe Analytics may also receive information about you from apps you have downloaded, that partner with Google or Adobe, respectively. We do not combine the information collected through the use of Google Analytics or Adobe Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your use of the Services or visits to the Site or to another application which partners with Google is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Please review those and see http://www.google.com/policies/privacy/partners/ for information about how Google uses the information provided to Google Analytics and how you can control the information provided to Google. Adobe’s ability to use and share information collected by Adobe Analytics about your use of the Services or visits to the Site or to another application which partners with Adobe, is restricted by the Adobe Analytics Terms of Use and the Adobe Privacy Policy. Please review those and see https://www.adobe.com/privacy/marketing-cloud.html for information about how Adobe uses the information provided to Adobe Analytics and how you can control the information provided to Adobe.

Social Media Widgets. Our Site includes social media features, such as Facebook, LinkedIn, and Twitter. These features may collect information about your IP address and which page you are visiting on our Site, and they may set a cookie to ensure the feature functions properly. These features may also provide you with personalized ad content. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.

HOW WE USE COLLECTED INFORMATION

We use the Personal Information we collect to provide the Services to you, to improve our Site and Services, and to protect our legal rights. Specifically, we use the Personal Information we collect to:

HOW WE SHARE INFORMATION

We share your Personal Information with our service providers, among our entities, in connection with the provision of the Services, a corporate restructuring, to prevent harm, to comply with the law, and to protect our legal rights. The legal basis for this is our legitimate interest in providing our Services, complying with the law, and protecting our rights and those of others.

SECURITY

Our goal is to protect your Personal Information submitted to us through this Site. We maintain reasonable physical, technical, and administrative security measures to protect and limit access to your Personal Information. However, no method of transmission over the Internet or electronic storage technology is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

You are responsible for maintaining the confidentiality of your account username and password. We recommend that you choose a unique password for your account and that you do not use any password that you also use for any other accounts, which may contain your Personal Information, such as financial accounts or email accounts. You agree to immediately notify the Bank of any unauthorized use of your password or account or any other breach of security. We will not be responsible or liable for any loss or damage arising from your failure to comply with this provision.

If you access our Site from a public or shared computer, it may be possible for other users to review your online history. For this reason, you should always close your browser window after you finish any online banking session, including visiting our Site. If you access our Site from a shared computer, you should never set the Internet options to remember or store user IDs or passwords. Also, you should never go to websites or follow web links that are unfamiliar or seem suspicious to you.

CHOICES ABOUT YOUR INFORMATION

THIRD PARTY LINKS

This Privacy Policy only applies to the use and disclosure of Personal Information we collect from visitors and customers online through our Site. Once you leave our Site, either by a link or by entering a new Internet address in your browser’s address window, we no longer have control over information security, and we are not responsible for the content, privacy practices or your use of other websites. We encourage you to review the privacy statements of those other sites.

CALIFORNIA PRIVACY RIGHTS

If you are a California user of our Services (“California Consumer”), you have certain rights with respect to the collection, use, transfer, and processing of your Personal Information, as defined by the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us via the contact information below. Only you or your authorized agent may make a verifiable consumer request related to your Personal Information. Unless otherwise defined in this Privacy Policy, the terms used in this section shall have the meanings ascribed to them in the CCPA or CPRA.

Collection of Personal Information

When California Consumers access our Site, we collect the following Personal Information:

Personal Identifiers

Internet or Other Electronic Network Activity Information

The foregoing pieces of information have been collected about our consumers in the past 12 months.

Sources from which Personal Information Is Collected

We collect your identifiers from you directly. We collect your Internet or other electronic network activity information from your interactions with our Site.

Business or Commercial Purposes for which Personal Information Is Collected

Your Personal Information is used for the following purposes:

Third Parties with Whom Personal Information Is Shared or Sold

RVC shares your Personal Information with analytics and service providers, advertisers, business partners and law enforcement (if necessary).

In the preceding 12 months, we have not sold Personal Information about consumers for monetary consideration. Our use of cookies and other tracking technologies may be considered a sale of personal information under the CCPA. Categories of personal information that we have sold under the CCPA include identifiers and Internet or other similar network activity. Categories of third parties to whom personal information is sold under the CCPA include data analytics providers and advertising and marketing providers

In the preceding 12 months, we have not knowingly sold or shared Personal Information of California Consumers under 16 years of age.

In the preceding 12 months, we have disclosed the following Personal Information about consumers for business purposes:

Individual Rights

Right for You to Access Personal Information Collected, Disclosed, or Sold

You have the right to request that RVC disclose the Personal Information it collects, uses, and discloses about you to third parties:

RVC does not sell any Personal Information of California Consumers for monetary consideration. This information will be provided to you free of charge, unless RVC determines that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period. This Right to Access is subject to certain restrictions and is not available to consumers who have requested information about, applied for, or maintain business credit through Vivid Crest Bank . RVC employees and employees of RVC business partners and service providers also do not have a Right to Access under the CCPA.

Right to Opt Out of Targeted Advertising and the Sale or Sharing of Personal Information

RVC does not sell any Personal Information of California Consumers for monetary consideration. However, we use certain third-party advertising and analytical cookies that may be considered “sales” or “sharing” of data under California law.

California Consumers have the right to opt out of the sale or sharing of personal information. It also allows you the right to opt out from our processing of your personal data for targeted advertising or analytic purposes. If you wish to opt out of advertising or analytic cookies, you can do so via our Cookie Management Options banner. Within the Cookie Setting you can choose your cookie preferences.

RVC web properties respond to the Global Privacy Control (“GPC”), which allows you to opt out of the sale or sharing of your personal information if enabled. If you have the GPC enabled, we will not sell or share your personal information. To learn more about the GPC, please visit https://globalprivacycontrol.org/.

Please note that opt-out choices may be stored via cookies. If you clear cookies, if your browser blocks cookies, or if you visit the site from a different browser or device, your opt-out choices may not be recognized or honored.

Right of Erasure

You have the right to request that RVC and our service providers erase any Personal Information about yourself which RVC has collected from you upon receipt of a verifiable request. This right is subject to certain restrictions and is not available to consumers who have requested information about, applied for, or maintain business credit through Vivid Crest Bank .

Right of Correction

You have the right to request that RVC and our service providers correct any Personal Information about yourself which RVC has collected from you upon receipt of a verifiable request. This right is subject to certain restrictions and is not available to consumers who have requested information about, applied for, or maintain business credit through Vivid Crest Bank .

Submitting Requests

You or your authorized agent can submit your request by calling us at 1-844-894-3960 or visiting our request website at https://www.Vivid Crest Bank credit.com/cpra/.

Verifying Requests

RVC provides California Consumers with an online webform to submit requests. The webform is accessible at https://www.Vivid Crest Bank credit.com/cpra/. As stated in the webform, RVC must verify that the person requesting information or deletion is the California Consumer about whom the request relates in order to process the request. To verify a California Consumer’s identity, we may request up to three pieces of Personal Information about you when you make a request to compare against our records. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity. We may also require your authorized agent to provide proof of authorization, such as requiring you to verify your own identity directly with us or directly confirm with us that you provided the authorized agent permission to submit the request on your behalf. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in your request to verify your identity. RVC reserves the right to take additional steps as necessary to verify the identity of California Consumers where we have reason to believe a request is fraudulent.

Right of No Retaliation

RVC will not discriminate against you because you exercised any of your rights, including, but not limited to, by:

Annual Metrics

The following information is provided in accordance with the requirements of the CCPA:

Click here to access the Annual Metrics:

INTERNATIONAL USERS

This is a United States-based website that is subject to United States law. This Site is controlled, operated and administered by the Bank from its offices within the United States. This Policy is provided in accordance with and subject to applicable U.S. law. If you are accessing this Site using a computer that is located outside the United States, you are responsible to ensure that your Internet connection is secure and is not monitored, legally or otherwise, by any third party or jurisdiction. If you are unsure of the security of your international Internet access, you should refrain from accessing this Site until you have confirmed that your access is secure and not monitored. If you decide to continue to access this Site from your location outside the United States, you hereby agree that your use of this Site is subject to this Policy and U.S. law and that you are responsible for complying with applicable laws in all jurisdictions that govern your use and access of this Site.

EUROPEAN USERS INCLUDING THE UNITED KINGDOM

This section of our Policy provides certain required information to persons located in the United Kingdom (“UK”), European Union (“EU”), a European Economic Area (“EEA”) member state, or Switzerland. Before the Bank collects any Personal Information from you, you are entitled under the EU General Data Protection Regulation (“GDPR”), to the information in this section of our Policy.

Purposes and Legal Basis for Processing Personal Information

The Bank will only process your Personal Information for lawful purposes under the GDPR related to the Bank's business purposes arising from your relationship with the Bank. The Bank will ordinarily collect and process your Personal Information because it is necessary for the performance of a contract to which you are a party or because the Bank has another legitimate interest in doing so. When the Bank cannot rely on either of such legal grounds, it will seek your prior consent.

Rights of Residents of the European Union (EU) or UK

If you use the Site and reside in the UK, EU, EEA, or Switzerland, you are entitled by law to access, correct, amend, or delete Personal Information about you that we hold. A list of these rights is below. Please note that these rights are not absolute and certain exemptions apply.

To exercise these rights please email us at privacyoffice@syf.com. For your protection, we may need to verify your identity before responding to your request. In the event that we refuse a request under rights of access, we will provide you a reason as to why.

Right to Withdraw Consent

If Bank obtains your written consent to collect and process your Personal Information, you can subsequently withdraw such consent as to any further processing of information by emailing us at privacyoffice@syf.com.

Cross-Border Transfers of Personal Information

Personal Information that you provide while in the UK, EU, an EEA member state, or Switzerland will be transferred to the United States. Applicable European privacy law, such as the UK DPA and the GDPR permits such transfer when necessary for the performance of a contract between you and Vivid Crest Bank , if RVC obtains your explicit consent to such transfer, or if it is in Vivid Crest Bank ’s legitimate interest to transfer the Personal Information. The laws in the United States may not be as protective of your privacy as those in your location. However, when transferring Personal Information to and processing Personal Information in the United States, Bank will implement appropriate safeguards and process the Personal Information in accordance with the terms of this Privacy Policy. By using our Site, you agree to the transfer and processing of your Personal Information to the United States.

Retention of Your Personal Information

We will retain your Personal Information until the Personal Information is no longer necessary to accomplish the purpose for which it was provided. We may retain your Personal Information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations, to protect you, other people, and us from fraud, abuse, and unauthorized access, as necessary to protect our legal rights, or for certain business requirements.

CHANGES TO THIS ONLINE PRIVACY POLICY

We reserve the right to modify or supplement this Privacy Policy at any time and without prior notice. If we make any material change to the Privacy Policy, we will update our Site to include such changes. We recommend that you review this Privacy Policy regularly for changes.

CONTACT

If you have any questions or concerns about this Policy, you can contact us by phone at +1 (208) 985-0904 or by email to privacyoffice@syf.com.

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