Digital Privacy Guidelines

Citizens Bank is committed to protecting your personal information and adheres to the highest standards established by federal and state regulations.  This document will provide guidance on the types of information we collect through our website or banking apps, how it is used, and about the steps we have taken to ensure the appropriate handling of your personal and financial information.

 

Personal data, or personal information, means any information about an individual from which that person can be identified. When you visit our website, we do not collect any information that could identify you personally unless you choose to provide it to us. You are welcome to browse our website at any time anonymously and privately without revealing any personal or financial information about yourself. Most of the information we collect is voluntarily provided directly from you. We have grouped this data as follows:

The choice to provide us with personal information is always yours. In financial dealings, however, your decision to withhold details may limit or prevent us from providing the services you have asked for or that we are able to provide and may make it more difficult for us to advise you or suggest appropriate alternatives. Different activities will call for various levels of information. If we are unable to accommodate your request based on the information that has been provided, we may ask for additional details to identify other ways to be of assistance. Occasionally we may also maintain a file containing contact history that is used for customer inquiry purposes.

 

We may collect, use, store, and transfer different kinds of personal data about you to provide you with the financial services you have requested, or to offer you additional products and services. Some information is collected to comply with legal obligations or state or federal regulations.

 

The anonymous/non-personal information gathered from the Web or mobile apps is used primarily for technical, research and analytical purposes like evaluating the various sections of our website, this information is not personally identifiable. If you grant permission to use phone information, our processor will use the phone number to pre-populate forms that expect a personal phone number for contacting you. If you grant permission to use your device's location, our processor will use the data when checking for nearby branch and ATM locations. If you grant permission to access photos, media or other files stored on your device, our processor will use that information to add an image to a transaction, attach a document to chat, and add a photo to your profile. If you grant permission to use a camera, our processor will use it when taking a picture to add an image to a transaction or to capture images of a check that is being deposited or to add a photo to your profile.

 

We use Cookies and similar tracking technologies to track the activity of our service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our service. The technologies we use may include:

 

Cookies - a cookie is a small file placed on your device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our service. Unless you have adjusted your browser setting so that it will refuse Cookies, our service may use Cookies.

 

Web Beacons - certain sections of our service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Bank, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

 

We may share your information with authorized employees and service suppliers to fulfill your requests and as required by law.

 

During daily operations, access to private, sensitive and confidential information is restricted to authorized employees who have a legitimate business purpose and reason for accessing it. As a condition of employment, employees are required to abide by the privacy standards established by Citizens Bank. They are also required to work within the principles of ethical behavior as set out in our internal Employee Code of Ethics and must follow all applicable laws and regulations. Unauthorized access to and/or disclosure of client information by an employee of Citizens Bank is strictly prohibited. All employees always maintain the confidentiality of customer information and failing to do so will result in appropriate disciplinary measures, which may include dismissal.

 

We sometimes contract with outside organizations to perform specialized services such as check printing, market research or data processing. Our trusted service suppliers may at times be responsible for processing and handling some information we receive from you. For example, we give our check-printing agent the information requested to display on the face of your checks. Our service processor may access records held by Citizens Bank for such information as your phone number, home address or email address. Our Processor will use this contact information to alert you about Service-related events or actions that require your attention.

 

The information we are legally required to disclose most often relates to governmental tax reporting requirements. In some instances, such as a legal proceeding or court order, we may be required to disclose certain information to the authorities. Only the information specifically requested is disclosed and it is our practice to validate the legitimacy of a request.

 

We may disclose your personal information to authorized Citizens Bank employees and third parties when permitted by law and as necessary for the following purposes:

It is important that your personal and financial information is accurate and complete. As a customer, you may access, verify and amend the information held in your personal and financial files whenever you wish. Most of this information is available in the form of transaction records and account statements are generally the best source for this type of information.

 

Should you have questions concerning a decision we have made, we may inform you of the reasons for those decisions if we are permitted to do so by law. We will, upon request, provide you with the name(s) and address(es) of any consumer agencies that provided information to us on your behalf if it was relevant to our final decision.

 

Should you identify any information in your file(s) that needs to be adjusted, we will make the proper changes in our files. Where appropriate, we will use every reasonable effort to communicate these changes to other parties who may have unintentionally received incorrect information from us.

 

Account deletion options cannot be added to the online or mobile applications as this option falls under Federal Regulations. Deleting a bank account would be in direct violation of several federal regulations and acts. The Federal Deposit Insurance Corporation (FDIC) and Bank Secrecy Act (BSA) requires banks and other financial institutions to implement Customer Identification Programs to prevent money laundering. These programs mandate that banks obtain and retain checking and savings account customer data, including contact, identification, and tax information. FDIC and BSA regulations stipulate that banks must keep this information for at least five years after the account is closed. These regulations are only a subset of regulations that financial institutions are required to comply with.

 

To request a change to the personal contact information contained in your file, please contact us at 262-363-6500.

 

We maintain security standards to ensure that your personal and financial information is protected against unauthorized access, disclosure, inappropriate alteration, or misuse.  Electronic files are kept in a highly secure environment with restricted access. Paper-based files are stored in secured filing cabinets. Access is highly restricted. Wisconsin law prohibits financial institutions from disposing of records that contain personal information unless the information is first “rendered undiscoverable”. This means that Citizens Bank will only dispose of records after shredding paper documents where your personal information may appear.

 

We manage our server environment appropriately and our firewall infrastructure is strictly adhered to. Our security practices are reviewed on a regular basis, and we routinely employ current technologies to ensure that the confidentiality and privacy of your information is not compromised.

 

We use, at a minimum, Secure Socket Layer (SSL) and 128-bit encryption technologies to enhance security when you visit the secured areas of our Web site. SSL is the industry standard tool for protecting and maintaining the security of message transmissions over the Internet. When you access your accounts or send information, encryption will scramble your data into an unreadable format to inhibit unauthorized access by others.

 

To safeguard against unauthorized access to your accounts, you are required to “sign-on” using an encrypted password and two factor authentication to certain secure areas of our website. If you are unable to provide the correct password or two factor code, you will not be able to access these sections.

 

Your password information is encrypted, which is presently the most effective way to secure data. To protect your Online Banking activity, our systems are designed to automatically terminate your session if extended inactivity is detected. If your session is terminated, you will be required to sign-on again to continue banking.

 

When you call one of our branch locations, you will be required to verify your identity by providing your account number and/or some personally identifying information.

 

On occasion Citizens Bank may provide links on its website to other websites operated by third parties. If you use these links, you will leave Citizens Bank’s website, and your browser will be redirected to websites over which Citizens Bank has no control. You should acquaint yourself with these other websites, as they may have privacy guidelines that differ significantly from Citizens Bank. Although we endeavor to only link to sites with high privacy standards, our privacy guidelines will no longer apply once you leave our Web site. Additionally, we are not responsible for the privacy practices employed by other third-party Web sites. Therefore, we suggest that you examine the privacy statements of those sites to learn how your information may be collected, used, and disclosed.

 

We do not knowingly solicit data from children, and we do not knowingly market to children. We recognize that protecting children’s identities and privacy online is important and that the responsibility to do so rests with both the online industry and with parents.

 

We believe there are measures you should take to protect and safeguard your personal and financial information. The following is a list of things you can do to protect yourself against fraud and uninvited intrusion.

 

Verifying your identity when you call us on the phone is a requirement before we can give out any information. Employees are required to ask you a series of questions concerning your personal information and relationship with Citizens Bank to verify your identity prior to releasing any information over the phone.

 

Passwords are necessary to identify you and authenticate your permission to access your accounts. You should take precautions in handling your passwords. When selecting a password, we suggest that you use a combination of letters, numbers, and special characters and do not use words that can be easily associated with you such as the name of a child, a pet or the street on which you live. We also suggest that you change your password regularly.

 

You should not share personal or financial information such as your Personal Identification Number (PIN), Social Security Number, or credit/debit card number with others unless you clearly understand the purpose of their request and you know with whom you are dealing.

 

To make sure your connection to the protected areas of our Web site is secured, look for either a ‘closed lock’ or an ‘unbroken key’ icon located at the top or bottom right-hand side of your browser’s task bar. You may also check the Address bar to determine if SSL (Secure Socket Layer) is active by looking at the beginning of the address. If it starts with “https” rather than the standard ‘http”, then SSL is operating.

 

In addition, you should avoid utilizing public wi-fi when accessing your online banking account, avoid clicking suspicious links or opening suspicious documents, and limiting the amount of personal information you share online.

 

You should use 2FA whenever possible. This security measure is another way to help protect your information. You will be required to use it when logging into your Online Banking. At no time will we ever ask you for those codes.

 

As we update these guidelines, we will revise the effective date. Any updates to the guidelines become effective when we post the updates on the Site. To the extent permitted by applicable law, your use of the Site or our services following the update to the guidelines means that you accept the updated guidelines.