Baker Boyer California Consumer Privacy Act (CCPA) Notice
Effective January 1, 2020
- Introduction
This California Consumer Privacy Act Disclosure explains how Baker Boyer Bancorp, a Washington corporation and its wholly-owned subsidiary, Baker Boyer National Bank (“Baker Boyer”, “bank” “our” and “we”) collects, uses and discloses personal information relating to California residents covered by the California Consumer Privacy Act of 2018 (”CCPA”). This notice is provided pursuant to the CCPA.
Under the CCPA, ‘Personal Information’ is information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular California resident. The CCPA, however, does not apply to certain information, such as information subject to the Gramm-Leach-Bliley Act (“GLBA”).
- Collection and Disclosure of Personal Information
Information We Collect
In order to meet your banking and financial service needs, we may collect personal information from the following categories:
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- Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
- Personal information including categories such as account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
- Characteristics of protected classifications under California or federal law such as race and gender.
- Commercial information, including personal property records, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Biometric information.
- Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with a website, application, or advertisement.
- Geolocation data.
- Audio, electronic, visual, thermal or similar information.
- Professional or employment-related information.
- Education information.
- Inferences drawn from any of the information above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Sources of Personal Information
Baker Boyer may obtain personal information from the following sources:
A. Directly from the consumer or consumer’s representatives;
B. Credit bureaus;
C. State and federal bureaus, agencies, and departments;
D. Public websites and social media;
E. Vendors and service providers;
F. Other financial institutions;
G. Transactional counterparties; and
H. Employee and customer referrals.
Sharing Personal Information:
Baker Boyer shares Personal Information with the following categories of third parties:
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- Accountants, auditors, lawyers and other outside professional advisors to Baker Boyer, subject to confidentiality.
- Third-party service providers.
- Governmental, legal, regulatory, or other similar authorities and/or local government agencies, upon request or where required.
- Other third parties to comply with legal requirements such as the demands of applicable subpoenas and court orders; to verify or enforce our terms of use, our other rights, or other applicable policies; to address fraud, security or technical issues; to respond to an emergency; or otherwise to protect the rights, property or security of our customers or third parties.
III. Use of Personal Information
The bank uses the personal information collected to operate, manage, and maintain its business, to provide products and services, and to accomplish its business purposes and objectives, including the following:
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- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, facilitating and/or engaging in deposit account activities, responding to credit requests/providing financing, providing trust-related services, providing advertising or marketing services, or providing similar services.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Retaining video from our ATMs at the time that transactions occur and inside our branches and offices for security, to resolve disputes, comply with legal and regulatory obligations, and to prevent fraud.
- Undertaking activities to verify or maintain the quality or safety of a service controlled by the bank, and to improve, upgrade, or enhance the service controlled by the bank.
- Debugging to identify and repair errors that impair existing intended functionality.
- Undertaking internal research for technological development and demonstration.
- Complying with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reflecting legal or regulatory guidance, codes or opinions)
IV. Sale of Personal Information
Baker Boyer Bank does not engage in the sale of personal information.
V. Your Rights
If you are a California resident, you have the right to:
1. Request the bank disclose to you the following information covering the 12 months preceding your request:
a. the categories of Personal Information the bank has collected about you;
b. the categories of sources from which the Personal Information was collected;
c. the purpose for collecting your Personal Information;
d. the categories of third parties with whom the bank disclosed your Personal Information, and the categories of Personal Information that was disclosed if applicable) and the purpose for disclosing your Personal Information; and
e. the specific pieces of Personal Information the bank collected about you;
2. Request that the bank delete your Personal Information, unless the CCPA exception applies;
3. Give or withhold consent for the bank to sell your personal information; and
4. Be free from unlawful discrimination for exercising your rights under CCPA
We will acknowledge receipt of your request and advise you how long we expect it will take to respond if we are able to verify your identity. We will work to process all verified requests within 45 days pursuant to the CCPA. If we need an extension for up to an additional 45 days in order to process your request, we will provide you with an explanation for the delay.
If you submit a request on behalf of another person, we may require proof of authorization and verification of identity directly from the person for whom you are submitting a request.
In some instances, we may not be able to honor your request. For example, we will not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual. Additionally, we will not honor your request where an exception applies, such as where the Personal Information that we maintain about you is not subject to the CCPA’s access or deletion rights. We will advise you in our response if we are not able to honor your request.
How to Exercise Your Rights
If you are a California resident, you may submit a request by:
1. Completing the CCPA Request Form and submit it to the address on the form
2. Calling (800) 234-7923
VI. Questions or Concerns
You may contact us with questions or concerns about this Disclosure and our practice by:
1. Writing us at: Marketing Department
Baker Boyer Baker
PO Box 1796
Walla Walla, WA 99362
2. Emailing us at: info@bakerboyer.com
VII. Changes to This California Consumer Privacy Act Disclosure
We may change or update this Disclosure from time to time. When we do, we will post the revised Disclosure on this page with a new “Last Updated” date.