Privacy Policy

Recognition of your expectation of privacy

We recognize and respect the privacy expectations of our clients. To meet those expectations, City National Bank of Florida, Total Bank, and BciCapital (the “Bank”, “we”, “us”, or “our”) maintains policies and procedures to safeguard your personal information. All consumer personal information collected, processed, or disclosed is pursuant to the Federal Gramm-Leach-Bliley Act (Public Law 106-102) and implied regulations. Please read this Privacy Policy carefully to understand how we handle user privacy.

Protecting online applications

When you apply online for accounts or services, enroll in online banking, and/or download the Bank’s application, which may be available on platforms that include but are not limited to, Google Play and Apple’s App Store, you provide personal information that is necessary for us to process your application, and/or provide features of our online bank and mobile app to you. This includes but is not limited to, getting real time balances for your accounts, managing your account, viewing your transactions and statements, making transfers, managing/paying your bills, and depositing checks. To ensure that your application remains confidential, the information is sent to us in a "secure session". After you have submitted your application online, we recommend that you end your browser session before leaving your computer. We, along with the outside companies with which we work, if applicable, may keep the information you provide to us, along with information we collect from outside sources, so that we can offer you accounts and services related to your financial needs.

How we use your information

In general, we use the information collected through your use of and interaction with our banking services, online banking services, and mobile application, to respond to any requests that you submit, provide you services that you request, and to help serve you better. This includes but is not limited to, the creation of and maintaining your account, identifying you as a legitimate user when accessing our online banking services or mobile application, improving the quality of our banking services, sending you administrative notifications, and sending surveys and promotions offers.

Our online banking services and/or mobile application may create de-identified information records from personal information by excluding certain information (such as your name) that makes the information personally identifiable to you. We may use this information in a form that does not personally identify you to analyze request patterns and usage patterns to enhance our products and services. We reserve the right to use and disclose non-identifiable information to third parties in our discretion.

Disclosure of personal information

We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to (i)satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof, (iii)detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to support requests, or (v) protect our rights, property or safety, and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention. We may employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share personal information with our Agents in order to provide products or banking services to you. Unless we tell you differently, our Agents do not have any right to use personal information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of personal information with our Agents.

How we handle email

We preserve the content of your e-mail, your e-mail address and our response so that we can more efficiently handle any follow-up questions you may have. We also do this to meet legal and regulatory requirements. If we think that a particular Bank account or service might apply to your situation, we may occasionally contact you at your e-mail address to inform you of potential benefits and availability.

What we do with online surveys

The information you provide on surveys and promotions on our website will be used for internal marketing purposes, including developing website information and services that you may find helpful. In addition, we may inform you of new accounts and services from the Bank based on the information you provide to us.

No "data" capture with planning tools

There are many planning tools throughout the site to help you make the financial decisions that are right for you in the privacy of your home. We encourage you to try all of your "what-if" scenarios as often as you like. Examples include the mortgage principal and interest calculator and the savings goal calculators. When you use various planning tools on our website, the calculations run on your PC or our server. We do not capture the personal information you provide on these planning tools.

Maintenance of accurate information

We have standards and procedures to ensure that your financial information is accurate, current and complete in accordance with commercial standards. We will respond to your request to review and correct inaccurate information in a timely manner.

Protecting your online banking

When you bank online with us and/or access our mobile app, we, along with the outside companies we work with to bring these services to you, have access to your information. Information is retained on our system or the system of the appropriate outside company, depending on what is required to serve you. We use state-of-the-art Internet technology, supported by the outside companies we work with, to make online banking secure and to protect your personal information. We also require a username and password and, as applicable, we may require an out of band authentication code delivered to you via text, email, voice/voicemail, or generated via an Authenticator in order to access your accounts. If you do not provide this information, we cannot establish an online banking service for you. You can also help maintain the security of your banking information by not sharing your username or password with anyone, by changing your password regularly, and by remembering to sign off.

When information is collected and not collected

Some areas of our website and/or mobile app require personally identifiable information, such as your name, e-mail address, phone number, physical address, financial information, social security number, your account number, or access to your contacts to enable you to perform certain tasks (for example, review your accounts or correspond with us). In these cases, we collect your information if necessary to interact with you and/or provide our banking services. In addition, we will collect financial and transactional information necessary to provide you with our banking services. This includes but is not limited to, payment card identification, payment card expiration date, verification numbers, and transaction and payment history.If you do not interact with us, you browse our website anonymously, any personal information, such as your e-mail address, is not collected. If you provide feedback or contact us via email, we will collect your name, email address, as well as any other content included in the email or contact form, to send you a reply. We gather and analyze data regarding usage of our website and/or mobile app, including domain name, number of hits, pages visited, length of user session, etc., to evaluate the usefulness of our services.Personally identifiable information and non-public contact information will not be disclosed other than for purposes described herein.

Information collected from third parties

We may collect certain information from identity verification services and consumer reporting agencies, including credit bureaus, in order to provide our banking services.

Location data

Your precise location (linked to your identity) and/or approximate location may be collected to help target advertisements and for internal marketing purposes based on your location. If you have enabled location services on your mobile device and agree to the collection of your location when prompted, we will collect location data when you use the Bank’s mobile application, or when the mobile application is closed. If you do not want us to collect location data, you may decline the collection of the data when prompted or adjust the location service settings on your mobile device.

About "cookies" and "unique identifiers"

To provide better service and a more effective website, we use "cookies" as part of our interaction with your browser. A "cookie" is a small text file placed on your hard drive by our web page server. These cookies do not collect personally identifiable information, and we do not combine information collected through cookies with other personal information to determine who you are or your e-mail address.Cookies are commonly used on websites and do not harm your system. By configuring your preferences or options in your browser, you determine if and how a cookie will be accepted. We use cookies to determine if you have previously visited our web site and for a number of administrative purposes.

In addition, our mobile app may use unique identifiers, including but not limited to, a string of characters specific to your mobile device, GPS location, camera and/or photos access, and information about the network your mobile device is connected to, and your IP address. Any time you access the mobile app we collect and receive information about the different devices you use and how you use them. We may use this information to measure the frequency of users accessing specific features and/or functions of the mobile app, to help us make the app more useful for users, fraud prevention, as well as security and compliance purposes.

Online activity data

Data such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before accessing our online banking services, navigation paths between pages and screens, or information about your activity on a page or screen, access times, and duration of access may be tracked and collected. Local storage technologies, like HTML5 and Flash, provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your web browser in connection with mobile applications. Web beacons, also known as pixel tags or clear GIF’s, may be used to track that a webpage or email was accessed or opened, or that certain content was viewed or clicked on.

Third parties and links

This privacy policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third-party websites, services, and applications (“Third-Party Services”) that you elect to access through. While we attempt to facilitate access only to those Third-Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third-Party Services. We encourage you to carefully review the privacy policies of any Third-Party Services you access. You may also access links to other websites. These links and plug-ins are for your convenience. The linked websites are not necessarily under our control, and we shall have no responsibility or liability whatsoever for the content or privacy practices of any linked websites, or any link or linking program at any time.

Limiting employee access to information

We have procedures to limit employee access to your personal information to those with a business reason for knowing such information. We educate our employees to understand the importance of confidentiality and client privacy. We take appropriate disciplinary measures to enforce employee privacy responsibilities.