This Privacy Notice describes what personal information we collect, how we collect and use your personal information, who we disclose it to and why, the measures we take to protect your personal information, and the choices you may have regarding our use of your personal information. It covers our websites and mobile apps and services where this Privacy Notice is posted (“Sites”).

What Personal Information Do We Collect?

We may collect or receive the categories of personal information listed below, which may depend on the products or services you use as well as your device and account settings. Not all categories of personal information will be collected or received about every individual.

  • Basic Personal Identifiers such as name, telephone number, physical address, email address, government-issued identifiers (e.g. national identification numbers, driver’s license numbers), and signatures.
  • Device and Online Identifiers such as account login information, Mac address, IP address, cookie IDs, mobile ad IDs, and social media information.
  • Internet and Other Network Activity Information such as information about your browsing or search activity, as well as your interactions with our websites, mobile applications, emails, or advertisements, such as keystroke patterns (these tell us if it’s you who is interacting with us or a bot).
  • Commercial Information such as purchase and transaction history information (such as products or services you have purchased, rented, or returned), product reviews, travel and vacation information, and sweepstakes and contest entries.
  • Communications: Communication details (such as the content of emails, text messages, or other communications), call logs, and calendar information where CBZ Holdings is a party to the exchange.
  • Demographic Information such as age, gender, citizenship, ethnicity, date of birth, family or marital status, household income, education, professional and employment information, family health, number of children, number of cars owned, and software or virtual assets owned.
  • Financial Information such as credit or debit card numbers and financial account numbers.
  • Biometric Information such as voice prints, imagery of the iris or retina, face geometry, and palm prints or fingerprints.
  • Geolocation: Data about the location of your device which may be imprecise (i.e. inferred from your device’s IP address). If you provide your consent, this data may be precise.
  • Sensory Information: Audio, visual information, and other sensory information such as photographs and audio and video recordings.
  • Background Information: Background and criminal information such as background checks and criminal convictions.
  • Inferences: Individual preferences and characteristics such as inferences drawn from and related to shopping patterns and behaviors, intelligence, and aptitudes.

How Do We Use Personal Information?

We use personal information to provide you with products and services and to operate and improve our business. Circumstances that require us to use personal information include:

  • Performing services including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services.
  • Performing and providing advertising and marketing services including targeted advertising.
  • To conduct auditing and monitoring of transactions and engagement including auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance.
  • Short-term transient use such as non-personalized advertising shown as part of your current interaction with us.
  • Helping to ensure security and integrity and prevent fraud.
  • Undertaking activities to verify or maintain the quality or safety of our services or devices and to improve, upgrade, or enhance them.
  • Debugging to identify and repair errors.
  • Conducting business analysis such as analytics, projections, identifying areas for operational improvement.
  • Conducting research and development including undertaking internal research for technological development and demonstration.
  • Fulfilling our legal functions or obligations.

How Do We Collect Personal Information?

We may obtain and combine personal information from different sources collected online and offline, including information from third-party sources across different types of technology and devices.

Provided Directly by You

When you visit us in our Branches, Business Units, or online, you may share different types of personal information with us when you engage in the activities below:

  • Conduct a transaction in the Branch or online or request a service where we collect information (including when required by law).
  • Request customer service or contact us.
  • Interact with various types of technologies, applications, and features including our chatbot.
  • Post a rating, review, or other user-generated content on one of our websites or mobile services, or post a review or comment on one of our social media pages.
  • Participate in a contest, sweepstake, promotion, or survey.
  • Use features of our websites or mobile services that enable us, with your consent, to access the camera, microphone, or contacts on your computer or mobile device to provide you with functionality such as voice search, scanning bar codes for online search or mobile scan & go, or importing your mobile contacts. You must give us your permission before we access these features and you can opt out of providing access to them at any time by adjusting the settings on your device.

Collected Through Automated Means

We may obtain personal information about you, such as device and online identifiers and internet or other network activity information via automated means through your use of technology, such as when you visit our websites, use our mobile applications or services, or click on advertisements or links in emails you receive from us.

Also, depending on your device’s settings, we may collect precise geolocation information. You can control our ability to do this by adjusting the location-sharing settings on your mobile device at any time.

Collected Through Technology

We may collect your personal information from technology we use in Branches and Business Units. For example, our point-of-sale terminals process your credit/debit card information when you complete your purchase and we operate cameras for security and operational purposes such as to help deter theft or improve Branch design to better serve our customers.

Obtained from Other Companies within CBZ Holdings

We may obtain your personal information from another company within the Group.

Obtained from External Third-Party Sources

We may obtain personal information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our services, increase the appeal and relevance of advertising, and to prevent or detect fraud. We also may obtain device and browsing information from third parties for marketing purposes.

Collected from another Solution or Asset

For instance, when you speak to customer service, we collect your personal information using call recording technology in accordance with applicable law.

Who Do We Disclose To and Why?

In processing personal data, the Group may share some personal data with internal and external recipients. The transferring of personal data takes place between the following:

  • Business Units within Subsidiaries of CBZ Holdings
  • External recipients of data – The Group transfers personal data in the course of conducting its usual business or if legal, regulatory, or market practice requirements demand it to the following external recipients or if you have given your consent (e.g. to process a transaction you have ordered us to fulfill):
    • To public entities and institutions (e.g. financial authorities and law enforcement agencies) either upon providing a legal or regulatory request or as part of our legislative and regulatory reporting requirements.
    • To other credit and financial service institutions or comparable institutions in order to carry out a business relationship with you (depending on the contract e.g. correspondent banks, custodian banks, brokers, stock exchanges, credit rating agencies).
    • To third parties (for example, correspondent banks, brokers, exchanges, trade repositories, processing units, and third-party custodians, issuers, authorities, and their representatives) for the purpose of ensuring that we can meet the requirements of applicable law, contractual provisions, market practices, and compliance standards in connection with transactions you enter into and the services that we provide you with.
    • To a natural or legal person, public authority, agency, or body for which you have given us your consent to transfer personal data to or for which you have released us from banking confidentiality.
  • Service Providers and Agents – The Group transfers personal data to service providers and agents for the purposes given subject to maintaining banking confidentiality. These are companies in the categories of banking services, IT services, logistics, printing services, telecommunications, collection, advice and consulting, and sales and marketing.

How Do We Secure Your Personal Information?

Whether you are using our websites or mobile services or visiting Branches and Business Units, we use reasonable information security measures including physical, administrative, and technical safeguards.

How Long Do We Retain Your Personal Information?

We will keep the personal information we collect about you for as long as necessary to carry out the purposes set forth in this Privacy Notice or any other notice provided at the time of data collection, but no longer than as required or permitted under applicable law or internal Policies on personal data. We dispose of the personal information we collect in accordance with CBZ Holdings retention policies and procedures.

Links to Third-Party Services and Features

We want to improve your online experience and make it easier to discover new products and services through our Sites. We may provide you with links to other online services (such as websites or social media platforms) and may include third-party features such as apps, tools, widgets, and plug-ins. We may not own or control these linked online services or third-party features and we are not responsible for the information practices of the third parties that have ownership or control over them. In some cases, these third parties operate independently from us, which means their privacy practices are not covered in this Notice. We recommend that you review their privacy statements to learn about these third parties’ privacy practices, including details on the personal information they may collect about you.

How Can You Set Your Preferences?

By providing your personal information, you consent to our collection, use, and sharing of this information as described in our Privacy Notice. You can manage your preferences and opt out of specific uses of your data at any time through your account settings or by contacting us at [email protected].

You have the right to control how your personal information is used. You can opt out of specific uses of your data including:

  • Marketing communications.
  • Sharing your information with third parties.

To opt out, please use the following mechanisms:

  • Account Settings: Log in to your account and navigate to the privacy settings to manage your preferences.
  • Email Requests: Send a request to [email protected] to update your preferences.
  • Cookie Consent Banner: Use the cookie consent banner on our website to opt out of non-essential cookies.

Please note that opting out of certain uses of your data may affect your experience with our services.