FFL Card Shield Privacy Policy

Effective as of January 01, 2021

1. Introduction. This Privacy Policy describes the types of "Personal Information" (information that is identifiable to a particular person) that is collected (directly or through service providers) in connection with the Card Shield downloadable application ("App") and related services (collectively, the "Service") offered by your financial institution ("we" or "us"). This Privacy Policy is intended to supplement the disclosures in any Privacy Policy that you may have already been presented by us in connection with online banking or other services.

2. Eligibility. The Service is offered only to individual residents of the United States, excluding its territories, who can form legally binding contracts under applicable law. Without limiting the foregoing, the Service is not offered to minors. Other restrictions and eligibility requirements for the Service apply as described in the Card Shield Terms of Use. We do not knowingly collect any Personal Information from or about individuals under 18 years of age. Please do not submit such information to us, and as a parent or legal guardian, please do not allow your children to submit Personal Information without your permission. By using the App or the Service, you represent that you meet these requirements and that you agree to the terms of this Privacy Policy.

3. What Types of Personal Information We May Collect? We may collect information regarding your mobile device such as device settings, unique device identifiers, information about your location, and analytical information that may assist with diagnostics and performance. For your convenience, you may be asked to grant permission for access to your mobile device's geolocation data. This information may be collected when you use certain services that are dependent on your mobile device’s location (such as the location of an ATM or in store transactions).  We may collect Personal Information about you, which may include: name, postal address, zip code, e-mail address, telephone number, account numbers, payment card expiration date, payment card identification or verification numbers, social security number, mobile device location, and other information that we can use to contact you, verify your identity, provide the functionality available through use of the App and the Service, and manage risks, such as information maintained about you by identity verification services and consumer reporting agencies, including credit bureaus, and payment and other transaction information, and history for payments and other transactions in which you participate through the Service, and any Personal Information that you may enter into information blocks present in the App interface or made available through the Service.

4. How We May Collect Personal Information About You. We may collect Personal Information about you from the following sources:
a. Information that you input to the App or that the App collects automatically;
b. Your use of the App and the Service, and your interactions with customer care, including information you enter or speak, and information transmitted by your computer or mobile device or other devices you use as part of your receipt of the Service; and
c. We may also collect Personal Information about you from others, such as Affiliates, or other companies (such as for fraud detection).

5. How We May Share Personal Information About You. Click here to view our Privacy Policy. 

6. How We Protect Personal Information About You. To protect Personal Information about you from unauthorized access and use, we maintain physical, electronic, and procedural safeguards, including but not limited to security measures that comply with applicable federal and state laws. We also require our service providers and business partners to whom we disclose the information to do the same. When you enter sensitive information (such as a debit or credit card number) into the App, we encrypt the transmission of that information using secure socket layer technology (SSL). We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

7. Data Retention. We will retain, protect, use and share Personal Information about you as long as it is reasonably required for the purposes described in this Privacy Policy, and as required by law, including but not limited to for risk management, regulatory compliance, and audit purposes.

8. Amendments. We may amend this policy at any time by posting a revised version in the App. The revised version will be effective immediately at the time it is posted unless a delayed effective date is expressly stated therein. You may (in our discretion) also be provided with an email notification of such amendments. If we make any change in how we use your Personal Information, we will notify you by email or by means of a notice in the App prior to the change becoming effective. You may (in our discretion) be required to affirmatively acknowledge or accept the revised Privacy Policy in order to continue using the App and the Service. Any use of the App or the Service after a notice of change will constitute your express agreement to such changes.

9.  Contacting Us.  If you have any questions about this Privacy Policy or wish to provide updates or corrections to information about you, you may contact us by calling us at (216) 529-2700, or writing to us at the address of our main office.