Last Updated: October 22nd, 2016
Bank is in the business of providing banking services to individuals and entities (collectively the “Customers”). Bank, or one of its affiliates, also maintains a relationship with a principal member of MasterCard International (the “Member Bank”) under which the Member Bank maintains, operates and administers a co-branded prepaid debit card program to facilitate the Bank’s payments.
How and What Non-Public Personal Information the Bank Collects
If you visit the Bank’s website (“Site”) for informational purposes only, the Bank will not require you to provide any personal information. You will remain anonymous unless you register for any of our services or otherwise elect to disclose your identity. However, the Bank may collect and store certain visitor data including, but not limited to, browser type, Internet Protocol (“IP”) address, and geo-location information.
At other times, the Bank may collect certain Customer-related personal information, such as:
- If an individual registers for an account with the Bank, the Bank will request information which includes the individual’s name, email address, physical address, country of residence, contact phone numbers, date of birth, social security number (or equivalent in the individual’s country of residence), employment information, and the Bank may request bank account details and credit and/or debit card details;
- If an entity registers for an account with the Bank, the Bank will request information from certain owners, directors and authorized individuals for the entity which includes those individuals’ names, email addresses, physical addresses, contact phone numbers, dates of birth, and government issued identification numbers;
- Before a Customer utilizes any of the Bank’s services and throughout our relationship with a Customer, the Bank may require a Customer to provide additional information to verify an individual’s identity, address or other data to manage risk and compliance. We may also obtain information from third parties providing services such as identity verification, fraud prevention and similar services;
- If you choose to participate in a customer survey, the Bank may ask for your name, email address and other information required by the particular survey; and
- If you report a problem or submit a customer review, the Bank will ask you to provide information such as your name, email address, and account number.
Additionally, when a Customer has registered for an account with the Bank and logs into the account, the Bank may collect the IP address, standard log-in information and certain geo-location information.
The Bank does not knowingly collect information about any person under the age of 18.
How the Bank Uses the Data It Collects
The Bank will use personal information to conduct certain activities related to a Customer’s use of the Site and to service any account a Customer maintains with the Bank. Such use will include:
- Evaluating a Customer for the Bank services a Customer requests;
- Registering a Customer as a client and opening an account;
- Contacting a Customer to verify or reconfirm the accuracy of the information provided;
- Facilitating payments and transactions as directed by a Customer;
- Verifying the existence and availability of funds;
- Administering a Customer’s account;
- Assisting in the provision of other services or products requested by a Customer;
- Resolving disputes and troubleshooting problems;
- Preventing potentially fraudulent, prohibited or illegal activities and enforcing our contracts with a Customer;
- Complying with legal process such as subpoenas and court orders and performing other duties as required by law;
- Researching the demographics and behaviors of the Bank’s Customers; and
- Reporting to law enforcement authorities if the Bank believes a crime has been committed.
How the Bank Protects the Security of Your Personal Information
The Bank has implemented technical and managerial procedures to maintain accurate, current and complete information as well as to protect personal information from loss, misuse or alteration when it is under the Bank’s control.
Personally identifiable information will be stored on the Bank’s secure servers or stored on third party servers located in secure data centers in Russia and Romania. The Bank has ensured that or has ensured that third parties maintaining the servers have appropriate safeguards such as firewalls and data encryption and that appropriate physical access controls to the files is enforced. The Bank authorizes access to personal information only for those employees who require it to fulfill their job responsibilities.
Personal information is also password protected so that access is limited to Customers and those with whom a Customer shares their password, the Bank, as well as third party access facilitated by the Bank in relation to performance of the services offered by the Bank.
The Bank has also taken steps to protect the integrity of its Customers’ personal financial information when they initiate a transaction on the Bank’s Site.
Despite the Bank’s reasonable efforts to protect personal information, the Bank cannot guaranty the personal information will not be accessed, disclosed, altered or destroyed.
How the Bank Shares Your Personal Information with Others
- The Bank may attempt to place cookies on a computer to track a visitor’s use of the Site;
You have several choices with respect to cookies. You can modify your browser preferences to accept all cookies, to notify you when a cookie is set, or to reject all cookies. However, the Bank’s Site may use cookie-based authentication. Accordingly, if you choose to reject all cookies, you may not be able to log onto the Site and/or use the Bank’s services.
How You Can Update Your Personal Information
You may review and edit your personal information by logging into your account at the Site and/or contacting the Bank directly by visiting our Contact Us page.