REVISED February 26, 2024

This privacy notice for Bank of Tennessee (“we”, “us”, or “our”) describes how we might collect, store, use and/or share (“process”) your information when you use our services (the “Service” or “Services”), when you download and use our mobile applications (Bank of Tennessee Mobile Banking and Bank of Tennessee Business Deposit) or any other application of ours that links to this privacy notice.

Questions or concerns?  Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have questions or concerns, please contact our Customer Care team at [email protected] or 1-866-378-9500.

The Bank of Tennessee Mobile Banking App allows you to check balances, transfer funds, deposit checks, view transactions and check messages from anywhere, anytime. It’s fast, free and available to all of our Online Banking users. With this app you can do the following:

• Check balances 24/7
• View pending transactions
• Create, approve, cancel or view funds transfers
• Pay bills
• Deposit checks anytime, anywhere
• Send money with Zelle
• Budget, cashflow and financial tools
• View transaction history
• Send and receive secure messages
• Access branch hours and location information
• Log in with Fingerprint and Face ID Authentication or 4-Digit Passcode Login

The Bank of Tennessee Business Deposit App is designed specifically for businesses that deposit multiple checks at a time, our app allows you to quickly and easily make check deposits from anywhere, anytime. It’s fast, free and available to our business customers. Don’t have time to run by the branch? Making a deposit is as easy as snapping a picture of your check with your smart phone.

TYPES OF INFORMATION WE COLLECT

Through the Services, Bank of Tennessee may request access to information stored on your device such as location, contacts, camera and photos in ordert to provide the best user experience and security for your accounts.

Before granting acess to this information, you will be prompted to give permission to the Service.  If you do not wish to grant permission, you may decline access.  You can change or update those permissions any time in your device settings.

Through the Service we may collect personal information from you in the following ways:

(a) Personal Information

• When you register for the Service, we will collect personal information from you such as:
  • First and last name
  • Address
  •  e-mail
  • User IDs
  • Mobile or other telephone number
  • Social Security Number

• When you login to access the Service and have enabled biometric authentication using fingerprint or Face ID, we are required to access the device’s API (Biometric API on Androids, or the Secure Enclave on Apple iOS) to authenticate. However, this biometric information is never directly accessed or transferred from the devices’ secure storage area.
• When you deposit a check or use a QR code to make a P2P payment using Zelle or other payments functionality, we are required to access:
  • Camera
  • Images
  • Device contacts
• When you access branch and ATM/ITM locations or to prevent card transaction fraud we are required to access:
  • Device location

• To provide you with the Services, we will collect information necessary to deliver the Service to you, including:
  • Account numbers
  • Debit card expiration date
  • Debit card identification
  • Verification numbers
  • Transaction and payment history
• If you provide feedback or contact Bank of Tennessee via the in-app messaging feature, in order to send a reply, we will collect:
  • Your name
  • Your email address
  • Content included in the message, including any attached images and files from your device

 (b) Personal Information Collected from Third Parties

The Service may collect certain information from identity verification services and consumer reporting agencies, including credit bureaus, in order to provide some of our Services.

(c) Personal Information Collected Via Technology

We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our Services, our communications and other online services, such as:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
• Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns.
• Local storage technologies, like HTML5 that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that an email was accessed or opened, or that certain content was viewed or clicked.
• Location Information. If you have enabled location services on your phone and agree to the collection of your location when prompted by the Services, we will collect your location information when you use the Services; for example, to provide our fraud detection services. If you do not want us to collect this information, you may decline the collection of your location when prompted or adjust the location services settings on your device.

HOW WE USE YOUR INFORMATION 

(a) General Use.

In general, we use your personal information to respond to your requests as submitted through the Services, to provide you the Services you request, and to help serve you better. Bank of Tennessee uses your personal information in the following ways:

• facilitate the creation of, secure and maintain your account;
• identify you as a legitimate user in our online and mobile banking system;
• provide improved administration of the Services;
• provide the Services you request;
• improve the quality of experience when you interact with the Services;
• send you administrative e-mail and/or push notifications, such as security or support and maintenance advisories; and
• send surveys, offers, and other promotional materials related to the Services.

(b) Compliance and Protection.

We may use your personal information to:

• comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements and internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

(c) Creation of Non-Identifiable Data

Bank of Tennessee may create de-identified information records from personal information by excluding certain information (such as your name) that makes the information personally identifiable to you. We may use this information in a form that does not personally identify you to analyze request patterns and usage patterns to enhance our products and services. We reserve the right to use and disclose non-identifiable information to third parties in our discretion.

DISCLOSURE OF YOUR PERSONAL INFORMATION

Bank of Tennessee discloses your personal information as described below.

(a) We may share your information with third parties

Other than as described in this Privacy Notice in connection with the Services, this Privacy Notice does not apply to the processing of your information by Bank of Tennessee or third parties with whom we share information.

(b) Third Party Service Providers

We may share your personal information with third party or affiliated service providers that perform services for or on our behalf, for the purposes described in this Privacy Notice, including: to provide you with the Services; to conduct quality assurance testing; to facilitate the creation of accounts; to optimize the performance of the Services; to provide technical support; and/or to provide other services.

(c) Authorities and Others

Regardless of any choices you make regarding your personal information, we may disclose your personal information to law enforcement, government authorities, and private parties, for the compliance and protection services described above.

LINKS TO OTHER SITES

The Services may contain links to third party websites. When you click on a link to any other website or location, you will leave the Services and go to another site and another entity may collect personal and/or anonymous information from you. Bank of Tennessee’s provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. We have no control over, does not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Notice do not apply to these outside websites. We encourage you to read the privacy notice of every website you visit.

YOUR CHOICES REGARDING YOUR INFORMATION

You have several choices regarding use of information on the Services.

(a) How We Respond to Do Not Track Signals.

Some web browsers transmit “do not track” signals to the websites and other online services with which your web browser communicates. There is currently no standard that governs what, if anything, websites should do when they receive these signals. Bank of Tennessee currently does not take action in response to these signals. If and when a standard is established, we may revise our policy on responding to these signals.

(b) Access, Update, or Correct Your Information.

You can access, update or correct your information by changing preferences in your account. To do so, contact us.

(c) Opting Out of Email or SMS Communications.

If you have signed up to receive our email marketing communications, you can unsubscribe any time by clicking the “unsubscribe” link included at the bottom of the email or other electronic communication. Alternatively, you can opt out of receiving marketing communications by contacting us at 1-866-378-9500 or [email protected] .

If you provide your phone number through the Services, we may send you notifications by SMS, such as fraud alerts and activity alerts. You may opt out of SMS communications by unlinking your mobile phone number through the Services.

(d) Opting Out of Location Tracking

If you initially consented to the collection of geo-location information through the Services, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. Please note, however, that if you withdraw consent to Bank of Tennessee’s collection of location information, you may no longer be able to use some features of the Services.

SAFEGUARDS AND RETENTION

We implement reasonable administrative, technical and physical measures in an effort to safeguard the information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information.

Federal laws and regulations require that US financial institutions retain original, active and historical records. Your personal and financial data will be retained for a period of five to ten years, depending on applicable laws, regulations and legitimate business needs.

A NOTE ABOUT CHILDREN

The Services are not directed towards individuals under the age of 13, and Bank of Tennessee does not intentionally gather personal information about visitors who are under the age of 13. If a child under 13 submits personal information to us and we learn that the personal information is the information of a child under 13, we will attempt to delete the information as soon as possible. To learn more about the Children’s Online Privacy Protection Act (COPPA) please visit the Federal Trade Commission’s Website at https://www.ftc.gov/.

PRIVACY NOTICE UPDATES

This Privacy Notice is subject to occasional revision. Bank of Tennessee may notify you of any material changes in our collection, use, or disclosure of your personal information by posting a notice on the Services. Any material changes to this Privacy Notice will be effective thirty (30) calendar days following notice of the changes on the Services or immediately where no notice is given. These changes will be effective immediately for new users of the Services. If you object to any such changes, you must notify us prior to the effective date of such changes that you wish to deactivate your account. Continued use of the Services following notice of any such changes (or use of the Services after any such changes) shall indicate your acknowledgement of such changes.

CONTACT BANK OF TENNESSEE

If you have any questions or complaints about this Privacy Notice or Bank of Tennessee’s data collection or processing practices, or if you want to report any security violations to us please contact us by email at: [email protected] or call us at 1-866-378-9500