Privacy & Other Policies

Your privacy is important to us. This California Consumer Privacy Act (“CCPA”) Disclosure is provided by Farm Bureau Bank (“Bank”), a wholly owned subsidiary of FB BankCorp. This Disclosure explains how we collect, use and disclose personal information relating to California residents that are subject to the CCPA.

FARM BUREAU BANK DOES NOT SELL YOUR PERSONAL INFORMATION.

WHAT IS PERSONAL INFORMATION

Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a California resident (“consumer(s)”), household, or another person authorized to act on behalf of the customer. The CCPA; however, does not apply to certain information subject to federal privacy laws, such as the Gramm-Leach-Bliley Act and the Health Insurance Portability and Accountability Act (“HIPAA”).

This disclosure does not apply with respect to information that we collect about California residents who request or obtain our financial products and services for personal family household purposes. For more information about how the Bank collects, discloses, and secures information, please refer to Farm Bureau Bank’s Privacy Policy.

YOUR RIGHTS

Upon a verifiable consumer request, the CCPA requires a business to disclose the following information to the requesting consumer:

• What personal information the Bank has collected about you during the prior twelve (12) months;
• Whether the Bank sells your personal information, and if so, to whom;
• Give or withhold consent for the Bank to sell your personal information;
• Request that Farm Bureau Bank disclose to you:
  • The categories of personal information the Bank has collected about you;
  • The categories of sources from which the personal information is collected;
  • The purpose for collecting the personal information;
  • The categories of third parties with whom the Bank shares personal information; and
  • The specific pieces of personal information that the Bank has collected about you.
• Request that the Bank delete your personal information, to the extent possible; and
• Receive non-discriminatory services and product pricing from Farm Bureau Bank, regardless of whether you exercise your privacy rights under the CCPA.

Please note that identities of individuals requesting deletion or disclosure of their personal information must first be verified to protect you and the Bank from fraud and identity theft.

WHAT PERSONAL INFORMATION IS COVERED?

• Personal information defined under the CCPA to include any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with a customer or household. Examples include:
• Identifiers such as name, mailing address, physical address, online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number, or similar identifiers;
• Characteristics of protected classifications under California or Federal law;
• Commercial information, including, records of personal property, 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 a consumer’s interaction with a website, application, or advertisement;
• Geolocation data;
• Audio, electronic, visual, thermal, olfactory, or similar information;
• Professional or employment-related information;
• Education information.

WHAT PERSONAL INFORMATION IS NOT COVERED?

Much of the personal information that the Bank collects is already regulated by Federal and state laws and therefore, is exempt from the CCPA. For instance, the CCPA does not apply to personal information collected or disclosed in connection with financial products or services that are used primarily for personal, family, or household purposes. For information regarding how Farm Bureau Bank uses personal information collected in connection with these financial products and services, please see the Bank’s Privacy Policy.

The CCPA also does not apply to information that is governed by the privacy, security and breach notification rules issued by the U.S. Department of Health and Human Services pursuant to Health Insurance and Portability and Accountability Act.

The CCPA does not apply to personal information that reflects a communication or transaction between the Bank and another company, partnership, sole proprietorship, non-profit, or government agency, so long as that communication or transaction involves due diligence about the Bank or other business, or the Bank is providing or receiving a product or service.

The CCPA does not afford access or deletion rights to you if your information was collected and used by the Bank in the context of your role as a job applicant, employee, director, officer, medical staff member, or contractor of the Bank.

PERSONAL DATA COLLECTION AND DISCLOSURES

Farm Bureau Bank uses Personal Information for the purposes of operating, managing, and maintaining the business, providing products and services, and accomplishing business purposes and objectives, including using Person Information for the following:

• Provide and manage products and services:
  • Establish and process transactions for products and servicing, including checking accounts, credit cards, loans, as well as additional products for businesses such as commercial financing and payment services; and
  • Support the ongoing management and maintenance of products and services including to provide account statements, online banking access, customer service, payments and collections, and account notification.
• Supporting everyday operations, including to meet risk, legal and compliance requirements:
  • Perform accounting, monitoring and reporting;
  • Enable information security and anti-fraud operations, underwriting and due diligence;
  • Support audit and investigations, legal requests and demands, and exercise and defend legal claims;
  • Enable the use of service providers for business purposes; and
  • Comply with policies, procedures, and contractual obligation.
• Manage, improve and develop our business:
  • Market, personalize, develop, and improve our products and services;
  • Conduct research and analysis to drive product and services innovation;
  • Support customer relationship management; and
  • Evaluate and engage in mergers, acquisitions, and other transactions involving transfers of all or part of a business, or a set of assets;
• Support employment, infrastructure, and human resource management:
  • Provide benefits to employees and dependents, including healthcare and retirement plans;
  • Management pay and compensation activities;
  • Manage and operate facilities and infrastructure; and
  • Process employment applications.

SOURCES OF PERSONAL DATA

The sources from which the Bank collects Personal Data depend on the Bank’s relationship or interaction with a specific California resident. The information below lists the categories of sources from which we collect Personal Data in different contexts:

• From California residents directly, or other individuals acting on their behalf, through physical (e.g., paper application), audible (e.g., phone), or electronic (e.g., website, social media) sources;
• Public records or widely available sources, including information from the media, and other records and information that are made available by Federal, state, or local government entities;
• Outside companies or organizations that provide data to support activities such as fraud prevention, underwriting, and marketing;
• Outside companies or organizations from whom we collect Personal Data to support human resource and workforce management activities; and
• Outside companies or organizations from whom we collect Personal Data as part of providing products and services, completing transactions, supporting the Bank’s everyday operations, or business management and development. Examples include companies or organizations to whom the Bank provides products and services, other parties, partners and financial institutions, and parties involved with mergers, acquisitions and other transactions involving transfers of all or part of a business, or a set of assets.

CATEGORIES OF THIRD PARTIES WITH WHOM WE SHARE PERSONAL DATA

The categories of third parties with whom Farm Bureau Bank shares Personal Data depends on the Bank’s relationship or interaction with a specific California resident. The information below lists the categories with whom the Bank shares Personal Data in different contexts:

• Lawful requests for information from law enforcement, regulators, judicial authorities and court-appointed trustees, supervisors, and other third parties pursuant to subpoenas, or document requests; therefore, the Bank may share information with authorized issuers, processors or facilitators of subpoenas, summons, search warrants, levies, garnishments and similar legal processes;
• Consumer credit reporting agencies and specialty deposit consumer reporting agencies;
• State and Federal Bureaus, agencies, and departments;
• Vendors and service providers;
• Other financial institutions;
• Transactional counterparties; and
• Employee and customer referrals.

EXCEPTIONS TO THE REQUIREMENT TO DELETE CONSUMER PERSONAL INFORMATION

• Farm Bureau Bank does not sell personal information. If in the future, the Bank seeks to sell the personal information of California residents, it will provide notice and opportunity to opt-out. By default, if the Bank knows of California residents that are under the age of 16, they will be opted out of the sale of their personal information. The CCPA lists several exceptions to a customer’s right to require the Bank to delete personal information. Specifically, a business may deny a verified request if the business can demonstrate that the information is necessary to:
• Complete transaction or services for which the personal information was collected or reasonably anticipated, or provide a service requested by the consumer;
• Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activity;
• Debug to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise their right to free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act;
• Engage in scientific, historical, or statistical public-interest research in limited circumstance;
• Enable solely internal uses that are reasonably aligned with the expectation of the consumer based on the consumer’s relationship with the business;
• Comply with a legal obligation; and
• Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

The Bank may not include Personal Data when the Bank responds to or processes Access Requests or Deletions Requests when the CCPA recognizes other exceptions. For example, the Bank will not provide the Personal Data about an individual where doing so could adversely affect the data privacy rights of another individual or if it is necessary to maintain that Personal Data to comply with legal and regulatory obligations. If Farm Bureau Bank denies a consumer’s request under CCPA, it will inform the customer of the reasons for not taking action and any right to appeal the decision to the Bank.

HOW TO MAKE REQUESTS

• If you are a California resident and would like to exercise your rights under CCPA by requesting a disclosure of your personal information collected by Farm Bureau Bank or requesting that the Bank delete your personal information, you may do so by:
  • Calling toll-free 1.800.492.3276; or
  • Submitting your request at [email protected].

CHANGES TO THIS CCPA NOTICE

We may change or update this CCPA Notice from time to time. When this occurs, the Bank will post the revised CCPA Notice with a “Last Updated” date.