TABLE OF CONTENTS
- Information You Submit
- Other Information Collected
- How We Use and Share Collected Information
- Additional Information for California, Residents
- Accuracy & Security
- Third Party Websites
- Contact Us
INFORMATION YOU SUBMIT
Requests for Information and Support. To contact us for more information or to request support via the Site, you will need to provide your contact information (including, without limitation, your email address, first and last name, your zip code, and your telephone number) as applicable, the company you work for, and the subject matter in which you are interested.
Marketing Communications. We will provide you with updates, promotions, or other communications to the email address you provide. We will use this information to send you Westfield Bank updates and promotional and other electronic communications. You may opt out of receiving updates and other emails from us at any time by following the unsubscribe instructions in the applicable email. We may use third-party email provides to deliver these communications to you.
Phone Numbers. To the extent permitted under applicable law, we may use telephone numbers you provide to us to contact you regarding the services and products we provide.
Live Chat. If you use any chat or messaging feature on the Site, we will collect all text and other information and content that you may provide or input using those features. If you use a chat or messaging feature while signed into your account, we may link that information to your account.
OTHER INFORMATION COLLECTED
As you navigate and use the Site, certain information can be passively collected—that is, gathered without the user actively providing the information or being concurrently made aware of the collection of information—using various technologies. We passively collect a variety of types of information in a variety of ways, including:
IP Addresses and Related Data. The servers used to operate and provide the Site may collect data pertaining to you and the equipment, software, and communication methods you use to access the Internet and the Site, including Internet protocol (“IP”) addresses assigned to the computers and other devices from where you access the Internet, your Internet service provider (ISP), device ID numbers and unique identifiers, your media access control (MAC) address, your operating system, your computer screen resolution, your web browser type, the pages you access on the Site, the websites you access before and after visiting the Site, the length of time you spend on the Site, date and time stamps, clickstream data, your approximate geographic location, performance statistics, and usage data. Westfield Bank may use this information to administer the Site and its servers, to generate statistical information, to monitor and analyze Site traffic and usage patterns, to monitor and help prevent fraud, to investigate complaints and violations of our policies, and to improve the Site.
We may combine this information with other Collected Information (including personal information) and information obtained from third parties for security reasons and to protect our rights or the rights of others. The suppliers that we use to provide the Site may collect information about your visits to the Site and other websites. Some of this information may be collected using cookies and similar tracking technologies as explained below under “Cookies and Tracking Technologies.”
Analytics. The Site uses third-party analytics tools (e.g., Google Analytics) to collect and process data about your use of the Site, including when you visit the Site(s), URLs of the websites that you visit prior to visiting the Site and when you visit those websites, and IP addresses assigned to the devices from where you access the Internet. Our analytics providers may set and read cookies to collect this data and your web browser will automatically send data collected by those cookies to our analytics providers. Our analytics providers use this data to provide us with reports that we will use to improve the Site’s structure and content.
Advertising Networks, Personalized Advertising, Remarketing, & Retargeting. From time to time the Site may use or participate in advertising networks and related advertising services that are managed and provided by third-party advertising servers, advertising agencies, technology vendors, and research firms, including Google Ads and advertising services provided by Facebook (sometimes referred to the Facebook “tracking pixel”). These services collect information about your visits to and interactions with the Site and other websites and will use that information to target advertisements for goods and services and to display those advertisements on other websites. The information collected may be associated with your personal information.
Advertising networks often gather data about consumers who view advertisements to make inferences about a consumer’s interests and preferences, which enables their computers to deliver advertisements directly targeted to the consumer’s specific interests. This practice is often referred to as “online behavioral advertising.” For example, a third-party advertising network might collect the type of web browser you use, the type of computer operating system you use, the domain name of a website you visit, whether or not you visit specific pages of the Site and other websites, the location of your Internet service provider, the date and time of a visit to a website, and other interactions between you and a website.
Through Google Ads, Google uses your Internet searches, cookies, and similar identifiers (e.g., pixel tags) to collect information about your visits to the Site and your interaction with our products and services to generate targeted advertisements to you on other websites that you visit across the Internet.
We may also enable and implement the following Google Analytics Advertising Features on the Site: Remarketing with Analytics, Demographics and Interest reporting, Campaign Manager integration, Display & Video 360 integration, Google Display Network (“GDN”) Impression Reporting, and Segments. Remarketing with Analytics uses Google Analytics cookies to serve advertisements to you across the Internet based on your visits to the Site. Demographics and Interest reporting uses a third-party cookie to collect information about our Site traffic by tracking users across websites and across time, which generates a report for us to better understand Site users. Campaign Manager integration allow us to view, analyze, and create remarketing lists using our Campaign Manager data in Google Analytics. Display & Video 360 integration allows us to create remarketing lists in Google Analytics and have those lists available in Display & Video 360. GDN Impression Reporting allows us to measure the impact of unclicked GDN Display ad impressions on website behavior and conversions. Segments allows us to isolate and analyze subsets of Site users by sorting our Google Analytics data.
To opt out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use this information, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Site.
To change your preferences with respect to certain online ads and to obtain more information about third-party ad networks and online behavioral advertising, please visit the National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Please remember that changing your settings with individual web browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads from time to time. Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” on Android) that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes.
Westfield Bank is active on social media. You may have the opportunity to comment on those social media platforms regarding Westfield Bank and the products we offer and/or to submit or upload related photographs and other materials. Westfield Bank reserves the right to post on the Site, other websites, and social media pages any comments, photographs, or content that you post on our social media pages or provide to us through social media.
The Site may use both cookies that we implement, and cookies implemented by our suppliers and other third parties. “First-party” cookies allow your browser to talk to the actual website that you are visiting, whereas “third-party” cookies allow your browser to talk to third-party websites, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider.
Most browsers automatically accept cookies. Browsers generally also allow users to manage cookies in the browser’s settings. For example, a browser may allow you to reject cookies from certain websites, reject certain types of cookies regardless of the website, reject or disable all cookies from all websites, and/or delete cookies stored previously. Some browsers also give you the option of being notified every time a cookie is sent to your browser by a website. You can disable or limit cookies but doing so may impact your use and enjoyment of the Site and other websites. For example, the Site may not be able to be personalized for you, may no longer capture or remember your preferences or other choices you have made on the Site in the past, and may not remember your name or contact information.
Changing your cookie preferences in one browser will not necessarily carry over to other browsers, so you may need to adjust your preferences each time you get a new computer, install a new browser, upgrade an existing browser, or alter or delete a browser’s cookie file.
The types of information collected by a cookie and the purposes for which that information is used depends on the type of cookie. By way of illustration, the types of cookies used, the types of information collected by those cookies, and the purposes for which that information are used are described below. We may combine information collected by cookies with other Collected Information.
- Operationally necessary cookies (also called essential cookies). These are cookies that are required for the operation of the Site. For example, these cookies are required to identify irregular website behavior, prevent fraudulent activity, and improve security. They also allow users of the Site to make use of its functions. Without these cookies, features and services you have requested will not be able to be provided.
- Functional cookies. These cookies allow us to offer you enhanced functionality when accessing or using the Site. This may include to remembering choices you make, for example, remembering your preferences or settings, remembering if you reacted to something on or through the Site so that you are not asked to react to it again, remembering if you have used any feature of the Site before, remembering your username or preferences, remembering if you have used any feature of the Site before, restricting the number of times you are shown a particular advertisement, and enabling social media components. If functional cookies are disabled, various functions of the Site may be unavailable to you or may not work the way you want them to.
- Performance cookies (also called analytical cookies). These cookies assess the performance of the Site, including as part of our analytic practices to help us understand how visitors use and interact with the Site, for example, which pages on our websites users visit most often. These cookies also enable us to personalize content and remember your preferences. These cookies help us improve the way our websites work and provide a better, personalized user experience.
- Advertising or targeted cookies. These cookies record your visits to the Site, the pages you visit on our websites, and the links you have clicked. They gather information about your browsing habits and remember that you have visited a particular website. Westfield Bank and its third-party advertising platforms or networks may use this information to make the Site and its content more relevant to your interests (this is sometimes called “behavioral” or “targeted” advertising and is further discussed above). These cookies are also used to limit the number of times you see an advertisement and to help measure the effectiveness of advertising campaigns. To find out more about interest-based ads and your choices, please visit the Digital Advertising Alliance, the Network Advertising Initiative, the Interactive Advertising Bureau (IAB) Europe, http://www.allaboutcookies.org, and http://www.youronlinechoices.com.
A cookie can either be a “session” cookie or a “persistent” cookie. Session cookies exist only for so long as you are visiting the applicable website. Session cookies are typically deleted or removed when you exit or quit your browser application. Persistent cookies exist for a set period of time, for example, six months or one year. Each time you visit a website that has implemented a persistent cookie, that cookie will remain active until its predetermined expiration date. You can also manually delete persistent cookies as discussed above.
The Site may also use the following types of tracking technologies: web beacons (also called clear GIFs), flash cookies, and pixels (also called pixel tags). Web beacons are tiny graphics with unique identifiers that functions similar to how cookies function but, in contrast to cookies, web beacons are embedded invisibly on websites. Flash cookies collect and store information about your use of a website and are commonly used for advertisements and videos. Pixel tags can be placed on websites or within emails to track your interactions with those websites and when emails are opened.
How We Respond to Do-Not-Track Signals. Due to the automatic collection of data using cookies as described above, we do not honor “do not track” requests. For this reason, your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of information using cookies and other tracking technologies.
Embedded Content. The Site incorporates content, including feeds, scripts embedded in the Site’s code, and visible content (e.g., videos), provided by third parties. In some cases, those third parties collect data about how you interact with their content.
Information from Other Sources. We may obtain data about Site users from various third-party companies and public sources, whether offline or online (such as publicly available social media profiles), and we may combine that data with Collected Information. This enhances our existing information about our users and customers and improves our ability to contact you and our marketing’s relevancy.
HOW WE USE AND SHARE COLLECTED INFORMATION
In addition to the uses and sharing described above, Westfield Bank and its suppliers may use and disclose Collected Information as described below:
Promotional Communications. We may use Collected Information to send you promotional communications about Westfield Bank and our Site to the extent permitted by applicable law and in accordance with your preferences. In order to provide you with a personalized experience these communications may be tailored to your preferences based on, for example, inferences we make using your visits to the Site or the links you click on in our emails. You may opt out of receiving promotional communications from us at any time by following the unsubscribe instructions contained in the email, where applicable, or by contacting us using the contact information provided below under “Contact Us.” Note that, even if you opt out of receiving promotional communications from Westfield Bank, you may still receive administrative communications from us with respect to your use of the Site.
Evaluation and Improvement of the Site. We may use and disclose Collected Information to analyze, develop, and improve the Site, content, materials, and products we provide; to inform marketing and communication plans and strategies; to understand use demographics and preferences; to analyze the effectiveness of the Site; and to evaluate user needs and customize Site content and the user experience.
Lawful Processes, Security & Protection of Rights. We may use and share Collected Information as required or permitted in accordance with subpoenas, court orders, valid law enforcement requests, governmental agency requests, and other legal processes. We may use Collected Information and share it with third parties if we believe doing so is necessary or appropriate to protect our rights or the rights of others, including disclosing information as necessary to protect our operations, to enforce or bring legal action in the event of a violation of our agreements or policies, or to pursue remedies or limit damages that we may sustain.
ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS:
Collection. Consistent with the “Information You Submit” and “Other Information Collected” sections above, we collect certain categories of personal information about you. We collect the following types of categories of personal information:
We collect the following subcategories of personal information:
We collect such personal information for the following purposes (consistent with and in addition to the purposes set forth in “How We Use and Share Collected Information” section above):
Consistent with and in addition to the information set forth in the “Information You Submit” section above:
First and last name, physical address, telephone number, cellphone number, email address.
Performing services or providing products to you, providing customer services, verifying user information, facilitating access to services or products.
To administer your account.
Communicating with you when you have requested support, information, services, etc.
To send promotional communications about us, to the extent permitted by applicable law.
Internet or other electronic network activity information
Consistent with and in addition to the “Other Information Collected” section above: IP addresses, log files, login information, and cookies and device information (e.g. online activity such as date and time of accessing our websites, website addresses accessed, the length of website visit).
Analytical purposes, including, without limitation, to help us improve your access to the Site (for example, by remembering your contact and other information when you access or use the Site), to identify repeat visitors to the Site, to track how you access and use the Site, to learn when and how users visit the Site, to learn how popular Site pages are and aren’t, to learn which search terms are used to find the Site, to learn which websites direct you to the Site, to help display certain information on the Site, and to improve your enjoyment of the Site.
Physical address; work / business address, state, region, zip code, IP address.
Performing the services or providing products, including, without limitation, providing customer services, verifying user information, facilitating access to the Site.
To communicate with you and send you information about our products or services, or to respond to your request for information or products and services.
To send you promotional communications about us and our products or services, to the extent permitted by law.
Personal information does not include the following:
- Publicly available information from government records;
- De-identified or aggregated consumer information;
- Information excluded from the CCPA’s scope, including, for example;
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Please note our collection and use of any information you provide to us that is regulated and protected under the GLBA is subject to the our Privacy Disclosure Statement.
Purposes. We collect personal information for the business and commercial purposes set forth under the “How We Use and Share Collected Information” section above as further expanded on in the above table.
- Our third party service providers;
- Online advertising networks;
- Third party websites and mobile applicable (e.g., websites that share information with us or our advertising partners);
- Social media companies;
- Our websites; and
- Your communications with us.
No Sensitive Personal Information. We do not knowingly collect any personal information that would be considered “sensitive” as defined under the CCPA.
- Identifiers: including but not limited to name, telephone number, address, age, email address, or date of birth;
- Internet or other electronic network activity information: including but not limited to computer and connection information, IP address, and cookies and other tracking technologies described further above; and
- Inferences: drawn from the above categories of personal information.
The categories of third parties to which we may share the above categories of information, include, without limitation:
- Westfield Bank affiliates and related entities;
- Third party service providers: including, but not limited to, data analytics and advertising providers, cloud storage providers, IT service providers, delivery partners, and marketing companies; and
- Law enforcement
Your Rights and Choices
The CCPA grants individuals that are California residents, certain rights (subject to all exemptions and exceptions as may be set forth in the CCPA or its applicable regulations) in regard to our collection of your personal information. These rights include, only to the extent applicable and to the extent granted to you under the CCPA:
- The right to request the disclosures of (1) what personal information has been collected; (2) the categories of sources from which your personal information was collected; (3) the business or commercial purpose for collection or selling your personal data; (4) the categories of third parties with whom we disclose personal information; and (5) the specific pieces of personal information we have collected about you (also called data portability);
- The right to request the deletion of your personal information that we have collected;
- The right to request the correction of your personal information that we have collected; and
- The right to not be discriminated against due to your exercise of your rights under the CCPA. We do not discriminate based on an individual’s exercise of the rights granted to them under the CCPA.
The above rights are only exercisable by you where the CCPA grants you the right being exerted and where no exception or exemption under the CCPA applies. You may also have a registered agent (if and only as permitted under applicable law) that you authorize to act on your behalf. If you have a registered agent act on your behalf, we have the right to authenticate such agent’s authority to act.
We do not sell your personal information to third parties, nor do we share your information for purposes of cross-contextual behavioral advertising as defined under the CCPA. In the event we begin selling your personal information or sharing your personal information for cross-contextual behavioral advertising purposes (1) this Notice will be updated to reflect that fact and you will be notified of such update and (2) if required under the CCPA, you will be provided the ability to opt out of the sale of your personal information or the sharing of your personal information for cross-contextual behavioral advertising purposes (as may be applicable).
To exercise the rights described herein (only to the extent applicable), you may submit a verifiable request to us by through the methods set forth under the “Exercise Your Rights” section below. We will respond to all requests that we receive from you about your personal information in accordance with applicable data protection laws and to the extent permissible under any other applicable laws.
Exercising Your Rights. To exercise the rights described above only to the extent applicable law grants you such rights, please submit a verifiable consumer request to us by either:
Visiting: [ California Privacy Form ]
Only you or a registered agent (if and only as permitted under applicable law) that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. If you have a registered agent act on your behalf, we have the right to authenticate such agent’s authority to act. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. Without limiting the foregoing, the verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format. We endeavor to respond to a verifiable consumer request within 45 days of its receipt, and in any event, we will respond to you within the timeframe required under applicable law. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
ACCURACY AND SECURITY
Personal data you provide to us should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up to date.
We have in place reasonable and appropriate technical, physical, and organizational procedures and security measures designed to safeguard and secure personal information from unauthorized loss, alteration, access, disclosure, and processing, taking into account the cost of implementing such measures commensurate with the risks posed by the particular type of processing, the nature of the personal information, and in accordance with applicable law. We value your trust in providing us your information; however, no method of transmission over the Internet, or method of electronic storage is 100% secure and reliable. We cannot guarantee the security of Collected Information.
The Site is not directed at children under 16 years of age. Westfield Bank does not knowingly collect or use information from children under 16 through the Site.
THIRD PARTY WEBSITES
Two Park Circle
Westfield Center, Ohio 44251