CollegeData Privacy Center

What is the purpose of this Privacy Policy?

At CollegeData, a service provided by 1st Financial Bank USA, your privacy is important to us. We have established standards that govern our collection, use, retention, and protection of information about you in connection with your use of this Site.

What information do we collect from users and how is it used?

1st Financial Bank USA is the sole owner of the information collected on this Site. We will not sell, share, or rent this information to others or use it in ways different from what is disclosed in this policy.

1st Financial Bank USA collects information from our users at several different points on our Site.

Sign Up
When you sign up for CollegeData, we ask that you provide to us certain personally identifiable information. We request this information in order to verify compliance with the CollegeData Site User Agreement and applicable federal, state and local law and for identification and security purposes. We may also ask that you provide to us certain other information, such as how you heard about CollegeData and what college planning resources you are using or have used.

Data Locker
When you use certain tools on this Site and when you save items to your Data Locker, such information will be retained in a file specific to you.

Collection of Personal Information from Children Under Thirteen
1st Financial Bank USA does not knowingly allow children under the age of thirteen (13) to sign up for our services.

Do-Not-Track Signals from Users' Browsers
We do not use technology that responds to Do-Not-Track signals from your web browser.

Collection and Use of Information
We collect information on this Site that you provide to us. We also use "cookies" to collect aggregate information about Site usage and our users' browsing activities, which information is not user specific. A "cookie" is a small text file that a Web site may provide to your browser when you visit the site. We use cookies on the Site which enable third parties to provide us with better insights into the use of the Site or user demographics or to provide relevant advertising to you. The Site may also link to third parties' sites, which parties may collect information about a consumer's online activities over time and across different websites. We do not use "cookies" to collect or store personally identifiable information, provided that we use a "cookie" to store a unique identification number assigned to you that may be used to customize Site content and services for individual users. While you may modify the settings of your browser to prevent acceptance of "cookies," you must enable "cookies" to access areas of the Site that require log in. The information we collect on this Site may be used to market our financial products and services to you and also allows us to improve our marketing and promotional efforts, to statistically analyze Site usage, and to improve and customize our content, product offerings, and services.

Can users access their information to correct or update it?

Users who have signed up for CollegeData can access the information they have previously entered to correct or update it by logging into the Site and going to their Data Locker or other feature in which they initially entered the information.

Information that is captured automatically by our site (such as visit date and time, IP address, device type, and pages visited) is not information that the user enters directly, and they cannot access or change it.

Whom does 1st Financial Bank USA disclose personal information to?

With unaffiliated third parties. We may reveal information about you to third parties not affiliated with 1st Financial Bank: (1) if you request or authorize it; (2) if the information is provided to help complete a transaction for you; (3) if the information is provided to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, to enforce our Terms of Use or other agreements, or to protect our rights, property or safety or the rights, property or safety of our users or others (e.g., to a consumer reporting agency for fraud protection etc.); (4) if the information is provided to applicable rating agencies of the financial institution, persons assessing the institution's compliance with industry standards, and the institution's attorneys, accountants, and auditors; (5) if the disclosure is done as part of a purchase, transfer or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, customer information may be one of the transferred assets); (6) if the information is provided to our agents, outside vendors or service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.), or in connection with a proposed or actual securitization, secondary market sale (including sales of servicing rights), or similar transaction related to a transaction of the consumer; or (7) as otherwise described in this Privacy Policy.

With affiliated third parties. We may reveal information about you to third parties affiliated with 1st Financial Bank USA to assist us with important risk management, legal, Internet, securitization, account-acquisition and marketing services.

What are the policies of 1st Financial Bank USA regarding promotional emails it may send?

A user has the right to opt out of promotional e-mails sent by us or one of our agents by clicking the unsubscribe link included in the e-mail to indicate that the user wants to opt out of receiving future promotional e-mails. We may send you e-mails about transactions with us or about your account even though you may have opted out of receiving promotional e-mails.

What are the policies of linked sites and other third parties?

This Privacy Policy only addresses our use and disclosure of information we collect from you. You should be aware that when you are on the Site, you can be directed to other Web sites that are beyond our control, and 1st Financial Bank USA is not responsible for the privacy practices of third parties or the content of those linked Web sites. We encourage you to read the posted privacy policy whenever interacting with any Web site.

What security measures does the Site employ?

We maintain physical, electronic, and procedural safeguards that are designed to guard your personally identifiable information, including the information we collect on this Site. Our security procedures are aimed at preventing unauthorized access to such information and are reviewed and audited periodically for compliance with federal standards. To help protect the privacy of data you transmit through use of this Site, all communication of personally identifiable information is transmitted over HTTPS using Transport Layer Security (TLS). Your registration and log in information are always transmitted using TLS, as is information submitted on an Admissions Profile or when using the EFC Calculator. We also recommend users access the Site with a browser that supports 128-bit encryption.

We require registering users to select a password to protect access to their information. Please do not share this information with others; any interaction with the Site using your e-mail address and password will be considered authorized by you.

How will I know about changes in the Privacy Policy?

1st Financial Bank USA reserves the right to update this Privacy Policy from time to time. Please visit this page periodically so that you will be apprised of any changes.

How to Contact Us

If you have any questions about this privacy policy or the practices of this Site, you may request more information by writing to us at:

Privacy
1st Financial Bank USA
P.O. 7300
North Sioux City, SD 57049

Last Updated: December 2nd, 2019

SUPPLEMENTAL PRIVACY POLICY FOR CALIFORNIA CONSUMERS
TO COMPLY WITH THE CALIFORNIA CONSUMER PRIVACY ACT

This Supplemental Privacy Policy for California Consumers to comply with the California Consumer Privacy Act (“Privacy Policy”) applies solely to natural persons who are California residents (“California consumers”, “you” or “your”) and supplements the privacy policy of CollegeData, a service of 1st Financial Bank USA (“Bank”, “we,” “us” or “our”). The Privacy Policy is adopted to comply with the California Consumer Privacy Act of 2018, as amended (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this Privacy Policy.

  1. Categories of Personal Information Collected

We collect the following information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”) and within the preceding 12 months collected the following categories of personal information from California consumers:

Category

Examples

Identifiers

Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.

Education information

Name of high school attending or attended, year of high graduation, expected year of college graduation, grades, transcripts, standardized test scores, college financial aid information, or other similar education information.

Internet or other electronic network activity information

Browsing history, search history, information concerning a consumer’s interaction with a website, application or advertisement.


Publicly available information from government records.Personal information that we may collect does not include the following information (“Exempt Personal Information”):

  • De-identified or aggregated consumer information.
  • Activity involving the collection, maintenance, disclosure, sale, communication, or use of any personal information bearing on a consumer’s credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living by a consumer reporting agency by a furnisher of information that provides information for use in a consumer report and by a user of a consumer report.
  • Personal information collected, processed, sold or disclosed pursuant to the Gramm Leach Bliley Act (15 U.S.C. §§ 6801-6809), the California Financial Information Privacy Act (Cal. Fin. Code §§ 4050-4060), or the Driver's Privacy Protection Act of 1994 (18 U.S.C. § 2721et.seq.).

Exempt Personal Information that we may collect is not subject to this Privacy Policy.

  1. Source of Categories of Personal Information Collected

We obtain the categories of personal information set forth in the table above from the following categories of sources:

  • Directly from customers, applicants and other consumers, such as from documents they provide to us related to the products and/or services they obtain or seek to obtain from us.
  • Indirectly from customers, applicants and other consumers in the course of providing products and/or services to them.
  • From and/or through activity on our website and mobile app, such as website and mobile app usage details and through submissions provided on or through the website or mobile app.
  1. Business or Commercial Purpose for Collection of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To perform services on behalf of the Bank, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services and providing similar services on behalf of the Bank.
  • To audit related to a current interaction with customers, applicants and other consumers and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

  1. Sharing Personal Information

We may disclose your personal information to service providers for a business purpose pursuant to a written contract that prohibits the service provider receiving the information from retaining, using or disclosing the personal information for any purpose other than the specific purpose of performing the services specified in the contract.

We have disclosed the following categories of personal information to service providers for a business purpose within the preceding 12 months:

  • Identifiers
  • Education information
  • Internet or other electronic network activity information

We do not sell personal information collected about you to third parties.

  1. Your Rights and Choices

The CCPA provides California consumers with specific rights regarding their personal information. This information below describes your CCPA rights and explains how to exercise those rights.

Right to Know/Access to Information. You have the right to request that we disclose certain information to you about our collection, use, disclosure and sale of your personal information. You may request any or all of the following information:

  • The categories of personal information we have collected about you in the preceding 12 months.
  • The categories of sources from which personal information about you is collected.
  • The business or commercial purpose for collecting personal information about you.
  • The categories of third parties to whom we sold or disclosed personal information about you.
  • The specific pieces of personal information we have collected about you.

Right to Delete. You have the right to request that we delete (and direct our service providers to delete) any of the personal information we collected or maintain about you subject to certain exceptions. We may deny your request to delete your personal information if it is necessary for us to maintain your personal information for any of the following reasons:

  • To complete the transaction for which the personal information was collected, provide a good or service that you requested or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity.
  • To debug to identify and repair errors that impair existing intended functionality.
  • To exercise free speech, ensure the right of another consumer to exercise his or her free speech rights, or exercise another right provided for by law.
  • To comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • To engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, where our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
  • To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  • To comply with a legal obligation.
  • To otherwise use the personal information, internally, in a lawful manner that is compatible with the context in which you provided it.

Exercising Right to Know and Right to Delete. To exercise your right to know and right to delete, you must submit a verifiable consumer request. To submit a request, you may call the Bank at 1-800-733-1732 or send a message through CollegeData’s website at www.collegedata.com/en/contact-us/.

We cannot respond to a right to know request or right to delete request unless we are able to determine that the consumer making the request is the consumer about whom we have collected personal information. A verifiable consumer request must:

  • Provide sufficient information to allow us to match the identifying information provided about you in the request to the information we already maintain about you or to otherwise reasonably verify you are the consumer about whom the request relates or an authorized agent of the consumer.
  • Describe your request with sufficient detail to allow us to fully and properly understand, evaluate and respond to it.

Only you or an agent registered with the California Secretary of State that you have authorized to act on your behalf may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. Before acting on a request from an authorized agent, we may require that you verify your identity and provide your written permission authorizing the agent to make a request on your behalf. We may deny a request from an authorized agent who does not submit proof that you authorized him, her or it to act on your behalf.

You do not need to create an account with us to make a verifiable consumer request. Any personal information provided in a verifiable consumer request will be used for the sole purpose of verifying your identity or authority to make the request.

We will confirm receipt of right to know and right to delete requests within 10 days of receipt and provide information about how we will process the request and when you should expect a response. We will use reasonable efforts to respond to a request within 45 days of receipt. If we require more time (up to a total of 90 days), we will notify you of the extended response period and reason for the extension. We will provide our response at your option by mail or electronically, and if provided electronically, it will be in a portable and, to the extent technically feasible, in a readily useable format that allows you to transmit the information to another entity without hindrance. The information we provide in response to a right to know request will cover the 12-month period preceding our receipt of the request. If we cannot comply with a request, our response will explain the reason we cannot comply.

We will not respond to a right to know request more than twice in a 12-month period.

Right to Be Free from Discrimination. You have the right not to receive discriminatory treatment by us for exercising any of your rights under the CCPA, including, but not limited, to:

  • Denying you goods or services.
  • Charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
  • Providing you a different level or quality of goods or services.
  • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
  1. Contact Us for More Information

For questions or concerns about our privacy policies or practices, the ways in which we collect and use your personal information, your rights and choices regarding such collection or use, or to exercise your rights under the CCPA, you may contact the Bank at 1-800-733-1732 or send us a message through CollegeData’s website at www.collegedata.com/en/contact-us/.

  1. Changes to Privacy Policy

We may, at any time and from time to time in our sole discretion, amend this Privacy Policy for California consumers. We will notify you of any changes by email, through a notice on our website homepage and mobile app landing page, or other permissible means.

If you are a California resident, we may share your information with others for their marketing use unless you tell us not to. If you are a California resident and want to opt-out, click here to log in to the Update Account section of your Data Locker on the Site and check the box to indicate that you do not want us to share your information with others for their marketing use. We will not share your information after we have received and processed your opt-out.

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