Today, safeguarding ones personal and financial information is increasingly challenging. That’s why at InVestra, we make it a priority and provide you with access to the information you need to protect yourself and to help keep your information secure.

Online Privacy Notice

(Last Updated January 1, 2012)

This Online Privacy Notice (Notice) applies to this InVestra website and any InVestra affiliate website that links to this Notice, (each, a Site, and, collectively, Sites). This Notice explains how InVestra collects, uses and shares information from or about you when you visit a Site, provides information on how we advertise, both on our Sites and on other websites, and how we collect information based on your interactions with our online ads. In addition to this Notice, depending on your relationship with InVestra, you may receive and be covered by other privacy disclosures within account opening documents and other privacy and security rules as may be applicable to the relevant InVestra affiliate.

Changes to the Online Privacy Notice

Collecting Information

When you visit our Sites, we may collect certain categories of information from you, such as personal information that you provide via forms, surveys, applications, or using other online fields. We may also collect information about you from your online browsing and transactions, including your preferences, pages visited and technical information regarding your computer and operating systems; such as your Internet Protocol (IP) address, domain name, system configuration and settings. Personal information means personally identifiable information and does not include aggregated and de-identified data that the bank may create or compile from various sources, including accounts and transactions. This information, which does not identify individual customers, is used by the bank for its business purposes, which may include offering products or services, research, marketing or analyzing market trends, and other purposes consistent with applicable laws. Please see the Cookies, Flash objects, other technologies and Advertising sections below for more information.

Cookies

Cookies are pieces of information stored directly on the computer you are using. InVestra, or our third-party service providers (including advertising service providers – see the Advertising section below for more information on these advertisers) may place cookies or Flash objects on your hard drive for security purposes, to facilitate site navigation and to personalize your experience. Cookies allow us to:

  • Offer you more relevant products and services;
  • Collect technical and navigational information, such as browser type, time spent on our Sites and pages visited;
  • Monitor viewing and responses to InVestra advertisements.

When you visit our Sites we use cookies to monitor your experience. When you apply for a product on one of our Sites, we use cookies to remember you and to provide you information on products and services that best fit your needs. If you have an account with us and access your accounts online, we will maintain information about your visits to personalize your browsing experience and the products and services we offer. If you do not have an account with us and do not wish us to maintain information, please delete your cookies. To do this, you will need to follow your browser’s instructions for disabling or deleting cookies.

Cookies and other technologies provide us the capability to monitor the use of our Sites so we can continually improve the design and functionality to better serve you. Cookies we use do not contain or capture unencrypted personal information. If you choose not to accept cookies from our Sites, then you may not be able to access and use all or part of the Sites or benefit from the information and services offered. If you choose not to accept cookies, you will still receive advertisements on our Sites, however, they will not be tailored to your interests or needs.

Flash objects

InVestra uses Flash objects (sometimes referred to as “Local Shared Objects”) in two ways. First, as part of our security solution for online authentication, we use Flash objects to help us recognize you and your computer when you come back to our site. Second, for our pages running Adobe® Flash® content (demos and tutorials with moving content), we use Flash objects to determine your browser type and version of Adobe Flash in order for you to view the content. As with cookies, we never store personal information in these Flash object files unless encrypted. We do not use Flash objects for any online behavioral advertising purpose. Deleting cookies does not delete Flash objects. You can learn more about Flash objects – including how to control and disable them – through the Adobe interface. If you choose to delete Flash objects from our Sites, then you may not be able to access and use all or part of the Site or benefit from the information and services offered.

Other technologies

We contract with advertising service providers who may serve advertising to you through the use of web beacons. A web beacon is placed on a web page and, in addition to setting cookies, can capture information such as IP address, time, web browser, time zone and domain. Other technologies we use may capture customer specific data to help us understand how customers use our Sites and to assist us with resolving customers’ questions regarding the use of our Sites.

Advertising

InVestra advertises on pages within the Sites as well as on other websites not affiliated with InVestra. Information collected by our advertising service providers through cookies and other technologies includes the number of people who look at each of the pages on the Sites, search engine referrals, browsing patterns within the Sites, and responses to advertisements and promotions on the Sites and on websites where we advertise.

Advertising on our Sites

InVestra advertises its products and services on pages within the Sites. These advertisements may take the form of banner ads, splash ads (ads that appear as you sign on or sign off of your online accounts), and other formats. We may use information about your relationship with us, such as types of accounts you have, transactional information, or the state in which you bank to tailor advertisements that may be of interest to you.

Online Behavioral Advertising on our Sites

We also use advertising service providers to help us determine which of our advertisements are most likely to be of interest to you using non-personal behavioral information. We limit access and collection of information for specific purposes by advertising service providers.

• If you prefer not to have non-personal information used in this way, you may opt out of online behavioral advertising on our Sites.

Please note that if you opt out, you may still receive online advertising from InVestra.  Opting out from a specific advertising provider means that the ads you do receive will not be based on your preferences or behavior.

Advertising on other websites

InVestra contracts with advertising companies such as Google, Yahoo, Advertising.com and MSN, to advertise our accounts and services on websites not affiliated with us.

Online Behavioral advertising on other websites

Some of ads you may encounter are online behavioral advertising and may contain cookies that allow monitoring of your response to our advertisements. Cookies placed by these companies do not collect personal information. We limit companies that place our ads from using information for any purpose other than to assist us in our advertising efforts.

If you prefer that our advertising service providers not know which InVestra website pages you have viewed, you may opt out at Network Advertising Initiative.

Please note that if you opt out, you may still receive online advertising from InVestra. Opting out from a specific advertising provider means that the ads you do receive will not be based on your preferences or behavior.

In order for behavioral advertising opt-outs to work on your computer, your browser must be set to accept cookies. If you delete cookies, buy a new computer, access the Sites from a different computer, login under a different screen name, or change web browsers, you will need to opt out again. If your browser has scripting disabled, you do not need to opt out, as online behavioral advertising technology does not work when scripting is disabled. Please check your browser’s security settings to validate whether scripting is active or disabled.

Online surveys and sweepstakes

From time to time, you may be asked to participate in online surveys or sweepstakes. You are not required to complete online surveys, sweepstakes or promotions, however, online surveys are used so that we can gather information to better serve you. Based on the information you provide to us, we may inform you of accounts and services from InVestra.

Planning tools

InVestra provides users visiting our websites with a variety of planning tools, such as mortgage, savings and retirement calculators. Information that you enter into one of these planning tools or calculators may be stored for your future access and use. We will let you know when we plan to store information, and we will give you the option not to have this information saved.

Aggregation services

InVestra offers aggregation services.  InVestra uses the information collected through these services to provide you with requested services and to understand what account or service offers may be of interest to you.

Using other aggregation sites

Other companies offer aggregation sites and services that allow you to consolidate your financial account information from different sources (such as InVestra or other financial institutions) so that you can view all your account information at one online location. To do this, an aggregation provider may request access to your personal information, including financial information, your usernames and passwords. You should use caution and ensure that the aggregator company has appropriate policies and practices to protect the privacy and security of any information you provide or to which they are gaining access. If you provide username, password or other information about your InVestra accounts to an aggregation site, we will consider that you have authorized all transactions initiated by an aggregation site using access information you provide, whether or not you were aware of a specific transaction. If you decide to revoke the authority you have given an aggregation site, we strongly recommend that you change your InVestra password to ensure that the aggregation site cannot continue to access your account. We are not responsible for the use or disclosure of any personal information accessed by any company or person to whom you provide your Site username and password.

Using and Sharing Information

At times, InVestra may make information available to third parties that are financial and non-financial companies not related by common ownership or control, such as service providers, credit bureaus, insurance agencies, mortgage brokers, retailers, travel companies, membership organizations, government agencies, courts, legal investigators, and other non-affiliated third parties as requested by you or your authorized representative, or otherwise when required or permitted by law. Unless otherwise described in this Notice, for U.S. account holders, we will use and share any information that we collect from or about you that is covered by this Notice in accordance with the InVestra U.S. Consumer Privacy Notice, which provides consumers additional direct marketing choices. For Non-U.S. account holders, we will use and share your information in accordance with the privacy disclosure that covers your account and with the privacy and security rules applicable to the relevant InVestra affiliate.

Additional Information

Social media
InVestra provides experiences on social media platforms such as Facebook,® Twitter® and LinkedIn® that enable online sharing and collaboration among users who have registered to use them. Any content you post, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms, is subject to the Terms of Use and Privacy Policies of those platforms. Please refer to them to better understand your rights and obligations with regard to such content.

Making sure information is accurate
Keeping your account information accurate and up to date is very important. If your account information is incomplete, inaccurate or not current, please use the Contact Us option on our Site, or call or write to us at the telephone numbers or appropriate address for changes listed on your account statements, records, online or other account materials. You can also speak to a customer representative at a banking center, or to your financial advisor or account representative.

Linking to other sites
We may provide links to non-InVestra websites, such as credit bureaus or merchants. If you follow links to websites not controlled by InVestra, you should review their privacy policies and other terms, as they may be different from those of our sites. InVestra does not guarantee and is not responsible for the privacy or security of these websites, including the accuracy, completeness, reliability or suitability of their information.

Protecting children’s privacy online
We do not knowingly collect information from children under 13 without parental consent. If you are under 13, please do not enter your personal information. For more information about the Children’s Online Privacy Protection Act (COPPA), visit the Federal Trade Commission website.

Changes to the Online Privacy Notice
This Online Privacy Notice is subject to change. Please review it periodically. If we make changes to the Online Privacy Notice, we will revise the “Last Updated” date at the top of this Notice. Any changes to this Notice will become effective when we post the revised Notice on the Site. Your use of the Site following these changes means that you accept the revised Notice.

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