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  1. Privacy Notice
  2. First Business Bank California Consumer Privacy Act Notice
  3. First Business Bank California Consumer Privacy Act Notice at Collection

 

REV. 10/2022

FACTS WHAT DOES FIRST BUSINESS BANK DO WITH YOUR PERSONAL INFORMATION?
Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

  • Social Security number and income
  • account balances and transaction history
  • credit history and investment experience
How? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customer’s personal information; the reasons First Business Bank chooses to share; and whether you can limit this sharing.

 

Reasons we can share your personal information Does First Business Bank share? Can you limit this sharing?
For our everyday business purposes–such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus YES NO
For our marketing purposes–to offer our products and services to you YES NO
For joint marketing with other financial companies YES NO
For our affiliates’ everyday business purposes–information about your transactions and experiences YES NO
For our affiliates’ everyday business purposes–information about your creditworthiness YES YES
For our affiliates to market to you YES YES
For our nonaffiliates to market to you NO We don't share

 

To limit our sharing Call 608-238-8008 – our menu will prompt you through your choice(s)

Please note:
If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice.
However, you can contact us at any time to limit our sharing.
Questions? Call 608-238-8008 or go to firstbusiness.bank/contact-us/ 

 

Who we are
Who is providing this notice? First Business Bank
What we do
How does First Business Bank protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

We restrict access to your personal information to only those employees who need to know. We require all companies with whom we share your information with to keep it confidential.
How does First Business Bank collect my personal information? We collect your personal information, for example, when you
  • give us your contact information or apply for a loan
  • open an account or make deposits or withdrawals from your account
  • tell us about your investment or retirement portfolio

We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
Why can’t I limit all sharing? Federal law gives you the right to limit only
  • sharing for affiliates’ everyday business purposes – information about your creditworthiness
  • affiliates from using your information to market to you
  • sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for your rights under state law.
What happens when I limit sharing for an account I hold jointly with someone else? Your choices will apply to everyone on your account.
Definitions
Affiliates Companies related by common ownership or control. They can be financial and nonfinancial companies.
  • Our affiliates include others, such as First Business Financial Services, Inc.
Nonaffiliates Companies not related by common ownership or control. They can be financial and nonfinancial companies.
  • First Business Bank does not share with nonaffiliates so they can market to you.
Joint marketing A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
  • Our joint marketing partners include credit card companies.
Other important information

Trust or fiduciary accounts for which First Business Bank is the trustee or services provider, including employer-sponsored retirement accounts are protected under special rules of confidentiality. Information on these accounts is not shared for marketing purposes without specific consent.

California Residents: We will not share information we collect about you with non-affiliated third parties, except as permitted by law, such as to process your transactions or to maintain your account. Please see our Privacy Notice for California Residents for further details concerning your privacy rights. https://firstbusiness.bank/privacy-notice/


Download Privacy Notice PDF

First Business Bank California Consumer Privacy Act Notice

Updated: June 30, 2023

This California Consumer Privacy Act Notice supplements the information contained in our Privacy Notice for First Business Bank and its subsidiaries (collectively, “we”, “us”, or “our”).

This notice explains how we collect, use, retain, and disclose personal information about California residents. The notice also explains certain rights California residents have under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”).

Your Rights


You may have certain rights under the California Consumer Privacy Act [Cal. Civ. Code §1798.100, et seq.] (CCPA) regarding your personal information, including:

  • The right to request the specific pieces of personal information we collected about you; the categories of personal information we collected; the categories of sources used to collect the Personal Information; the business or commercial purposes for collecting your personal information; the categories of your personal information disclosed for a business purpose; and the categories of third parties with whom we share your personal information each as it pertains to our activities in the preceding twelve (12) months.
  • The right to correct inaccurate personal information that we maintain about you;
  • The right to request, subject to certain exceptions, deletion of your personal information that we collected; and
  • The right not to be discriminated against for exercising any of these rights.

Information We May Collect


We may collect “personal information.” Personal information means information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device.

Please note that personal information does not include:

  • Publicly available information from government records;
  • De-identified or aggregated consumer information; or,
  • Information excluded from CCPA’s scope including information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), and the Gramm-Leach-Bliley Act (GLBA)

The table below describes which categories of personal information we may have collected and disclosed in the preceding 12 months:

Categories of Personal Information We Collect The Categories of Sources from Which the Personal Information is Collected The Business Purpose(s) for Which the Information is Collected, Used, and/or Shared The Categories of Third Parties with Whom We Share Personal Information
Identifiers-This may include 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. You, your agents, government entities from which public records are obtained, or through our service providers. To provide you with information, products, or services that you request from us, and to provide advertising or marketing services to you. Government Entities, as required by federal or state data reporting requirements.
Personal Information categories listed in the California Customer Records Statute (Cal. Civ. Code §1798.80(e))-This may include a name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. You, your agents, government entities from which public records are obtained, or through our service providers. To provide you with information, products, or services that you request from us, and to provide advertising or marketing services to you. Government Entities, as required by federal or state data reporting requirements.
Protected classification characteristics under California or federal law-This may include age, race, national origin, citizenship, marital status, sex, veteran or military status. You, your agents, government entities from which public records are obtained, or through our service providers. To provide you with information, products, or services that you request from us, and to provide advertising or marketing services to you. Government Entities, as required by federal or state data reporting requirements.
Internet or other similar network activity-This may include information on a consumer’s interaction with a website, application, or advertisement. You, your agents, or through our service providers. To provide you with information, products, or services that you request from us. We don’t share with third parties.
Geolocation data-This may include physical location or movements. You, your agents, or through our service providers. To provide you with information, products, or services, that you request from us. We don’t share with third parties.
Sensory data-This may include audio or visual data typically collected via phone and in-person for security and training purposes You, your agents, or through our service providers. To provide you with information, products, or services, that you request from us. We don’t share with third parties.
Sensitive Personal Information-This may include Social Security number, driver’s license or state identification card number, passport number, precise geolocation, racial or ethnic origin, or account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. You, your agents, government entities from which public records are obtained, or through our service providers. To provide you with information, products, or services that you request from us. Government Entities, as required by federal or state data reporting requirements.


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

Sources of Personal Information

We obtain the categories of personal information listed above from the following sources:

  • Directly from you – for example, from documents that you provide us related to the product(s) or service(s) for which you engage, use, or purchase from us.
  • Indirectly from you – For example, through information we collect from you in the course of providing you services. 
  • Directly and indirectly from activity on our website (https://firstbusiness.bank) – For example, from submissions through our website portal or website usage details collected automatically.
  • From third parties that interact with us in connection with the services we perform. For example, from credit agencies when we review qualifications for applications for some of our products.

Information Sharing

We may disclose your personal information to our service providers to perform a business or commercial purpose, such as to: maintain or service accounts, provide customer service, process payments, provide financing, provide advertising or marketing services, provide analytic services, or provide similar services on our behalf. If we disclose your personal information to a service provider, we do so pursuant to a written contract that prohibits the service provider from retaining, using, or disclosing the personal information for any purpose other than for the specific purpose of performing the services specified in the contract, or as otherwise permitted by the CCPA.

In the preceding 12 months, we have disclosed the following categories of personal information to our service providers for a business or commercial purpose:

  • Identifiers
  • Personal information categories listed in the California Customer Records Statute (Cal. Civ. Code §1798.80(e))
  • Sensitive personal information

First Business Bank and its subsidiaries have not, and do not engage in the sale of personal information, including that of minors under 16 years of age.

Exercising Your Rights

To exercise access and deletion rights, please submit a verifiable consumer request to us by either:

Once a request has been submitted, we will attempt to verify that you are the consumer the request applies to. We do that by taking the identifying information you provide (e.g., name, email address, account-related information) and using a combination of the information we have on file and our identity verification engine. We attempt to match a minimum of three data points you submitted. If we are unable to verify your request with the materials you provided, we may reach out to you for additional information.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a valid consumer request related to your personal information. An authorized agent can submit a request by clicking here. You may also make a verifiable consumer request on behalf of your minor child.

You may only submit a verifiable consumer request twice within a 12-month period. The verifiable 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; and
  • Describe your request with enough detail that allows us to properly understand, evaluate, and respond to it.

If we are unable to complete your request, including the inability to delete information, a copy of it will be logged for future reference within our system.

Request Responses

Privacy and data protection laws, other than the CCPA, apply to much of the personal information that we collect, use, and disclose. When these laws apply, personal information may be exempt from, or outside the scope of, the CCPA, including with respect to access and deletion requests. As a result, in some instances, we may decline all or part of an access request or deletion request related to this personal information.

Responses to a verifiable consumer request will be completed within 45 days of receipt. If more time is required (up to 90 days), the reason and extension period will be sent in writing. The email address you provide in your request will be what we use to communicate to you about your request.

Fees will not be charged to process or respond to consumer requests unless they are excessive, repetitive, or manifestly unfounded. Notification will be provided if a fee is required.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage. If no ad-hoc changes are warranted, this privacy notice will be reviewed annually.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or to exercise your rights, please do not hesitate to contact us at:

Download First Business Bank California Consumer Privacy Act Notice PDF

First Business Bank California Consumer Privacy Act Notice at Collection

Last updated: June 30, 2023

This California Consumer Privacy Act Notice at Collection (“Notice”) is provided by First Business Bank and its subsidiaries. These companies are referred to in this notice as “we” or “us.”

Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), “personal information” is information that identifies, relates to, describes, or could reasonably be linked with a particular California resident or household. This information is referred to in the Notice as “Personal Data.”

This Notice explains:

    1. Categories of Personal Data that we collect about residents of California; and
    2. The business or commercial purposes for which we use that Personal Data.

Categories of Personal Data that We Collect

We collect Personal Data in a variety of contexts. For example, we collect Personal Data to provide individual and commercial financial products and services, and vendor management purposes.

The Personal Data that we collect about a specific California resident will depend on, for example, our relationship or interaction with that individual.

We may have collected the following categories of Personal Data in the previous twelve (12) months. We do not sell or share Personal Data, including Sensitive Personal Data.

    1. Personal Identifiers – Personal unique identifiers, such as full name and federal or state issued identification numbers including Social Security number, driver's license number, and passport number.
    2. Personal Information – Personal information, including contact details such as telephone number and address, financial information such as account number and balance, payment card details including credit and debit card numbers.
    3. Characteristics of Protected Classes - Characteristics of protected classes or groups under state or federal law, such as sex, disability, citizenship, primary language, immigrations status, and marital status.
    4. Internet or Online Information – Internet or online information such as browsing history, and information regarding interaction with our websites, applications, or advertisements.
    5. Geolocation Data – Geolocation data, such as device location.
    6. Audio and Visual Information – Audio, electronic, visual, or similar information, such as call and video recordings.
    7. Sensitive Personal Information – 
      • Social Security number, driver’s license, state identification card, or passport number.
      • Precise geolocation.
      • Racial or ethnic origin, religious or philosophical beliefs, citizenship, or immigration status.

Why We Collect Personal Data and How We Use It

The business and commercial purposes for which we collect and use Personal Data depend on, among other things, our relationship or interaction with a specific California resident. The table below lists the purposes for which we collect and use Personal Data in different contexts.

Purposes for Collection and Use Examples
Provide and manage products and services
  • Establish and process transactions for our products and services including checking accounts, loans, investment accounts, as well as additional products for businesses such as commercial financing and payment services.
  • Support the ongoing management and maintenance of our products and services including to provide account statements, online banking access, customer service, payments and collections, and account notifications.
Support our everyday operations, including to meet risk, legal, and compliance requirements
  • Perform accounting, monitoring, and reporting. 
  • Enable information security and anti-fraud operations, as well as credit, underwriting, and due diligence.
  • Support audit and investigations, legal requests and demands, as well as exercise and defend legal claims.
  • Enable the use of service providers for business purposes. 
  • Comply with policies, procedures, and contractual obligations.
  • Obtain support for fulfilling the above purposes from third-party service providers, professional services and business partners.
Manage, improve, and develop our business
  • Market, personalize, develop, as well as improve our products and services. 
  • Support customer relationship management.
  • Evaluate and engage in mergers, acquisitions, and other transactions involving transfers of all or part of a business, or a set of assets.
  • Obtain support for fulfilling the above purposes from third-party service providers, professional services and business partners.
Use of Sensitive Personal Information as permitted by law
  • Perform services for our business, provide goods or services as requested by individuals, and ensure security and integrity.
  • Maintain and service accounts, provide customer service, verify customer information, process payments, and provide financing.


Data Retention

We will keep Personal Data no longer than necessary to fulfill the purposes described in this notice. Under our record retention policy, we are required to destroy Personal Data after we no longer need it according to specific retention periods. However, we may need to hold Personal Data beyond these retention periods due to regulatory requirements or in response to a regulatory audit, investigation, or other legal matter. These requirements also apply to our third-party service providers.

First Business Bank’s California Consumer Privacy Act Notice

First Business Bank’s California Consumer Privacy Act Notice is available for review at https://firstbusiness.bank/privacy-notice/.

Changes to this Notice 

We may change or update this Notice periodically. When we do, we will post the revised Notice on this webpage indicating when the Notice was “Last Updated.”

Download First Business Bank California Consumer Privacy Act Notice at Collection PDF