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CONSUMER PRIVACY POLICY
Emigrant's Commitment to Safeguarding Consumer Privacy
At Emigrant, we recognize that our relationship with you is based on trust, and the protection of your private financial information merits the highest priority. Thats why we have taken stringent measures and established corporate-wide procedures that ensure the confidentiality of all of your confidential information, whether we have received it directly from you or from a third party.
This policy outlines those procedures, and will be provided to you each year as long as you maintain an ongoing relationship with us.
Our Business Practices
- We collect only the information we need in order to serve you and conduct our business.
- We treat all personal and financial information about you in a confidential manner. This information may be obtained directly from you, or may be collected from other sources, or may result from applications you process with us.
- We maintain physical, electronic and procedural safeguards to protect customer information. We utilize state-of-the art technology for this purpose and upgrade, when appropriate, to improve our privacy protection performance.
- We limit access to your personal and financial information to those of our employees, agents and service providers that are required to have access to it in order to meet your financial needs or conduct our business.
- All of our employees, agents and service providers are responsible for compliance with the policies and procedures we have established to safeguard your personal and financial information.
- Our employees are governed by Emigrants Code of Conduct, which expressly requires the confidentiality of customer information, and our employees receive training in the importance of adhering to the procedures weve established to assure that confidentiality.
- Our data processing and electronic operations are performed in a secure technical environment that is accessed only by authorized personnel to transact legitimate business operations.
- We maintain electronic safeguards to protect customer privacy on our websites. This assures that when you conduct your business with us from your home or office, the privacy of your relationship and the information you furnish us online is protected.
- We carefully monitor our compliance with applicable laws and regulations and our internal security policies and procedures.
Information We Collect and Use
We collect and use various forms of information to open and service your banking, insurance, credit, securities brokerage or other accounts with us. We may also use this information to determine if other products or services might be of interest to you.
We collect and use nonpublic personal and financial information about you from the following sources:
- information we receive from you on applications or other forms;
- information about your transactions with us, our affiliates, or others; and
- information we receive from a consumer reporting agency.
Information we receive about you from third parties may include credit bureau reports from consumer reporting agencies, or verifications received from other companies, in connection with loan applications or other transactions you have requested.
Sharing Information Within The Emigrant Family
We may share all of the personal and financial information we collect, as described above, about our current and former customers with Emigrant's affiliate family of companies, each of which provides unique and valuable products and services. They include, but are not limited to, mortgage banking services (residential, small business, and mixed-use property lending), insurance agency services, loan administration, and private banking services.
Together, the Emigrant Family of companies offers a wide range of banking, loan and other products. By sharing information about your transactions and accounts among our Emigrant Family members, we give you an opportunity to enjoy the integrated financial services available. This process improves your access to information about all of the account relationships you maintain, and makes it easier for you to conduct business with us.
We are permitted to share the above information with our Emigrant Family members and you do not have a right to opt out of the disclosure of this information.
In addition, we may share with our Emigrant Family members other information that we collect about you, including information we obtain from:
- your loan application, such as your income or marital status;
- a consumer report, such as your credit score or credit history;
- a third party to verify representations made by you, such as your open lines of credit or property insurance; and
- a third party regarding their employment, credit or other relationship with you, such as a verification of your employment or credit history.
Sharing Information With Other Companies That Do Work For Us
We may share all of the personal and financial information we collect, as described above, about our customers or former customers, with companies that do work for us, including our Emigrant Family of companies, as necessary to or in connection with:
- effecting, administering or enforcing a transaction that you have requested or authorized;
- servicing or processing a financial product or service that you have requested or authorized;
- maintaining or servicing your account with us;
- maintaining or servicing your account with another company as part of a private label credit card program or other extension of credit on behalf of that company; or
- a transaction that necessitates the sharing of such information when such sharing is permitted by law.
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These companies may include check printing and processing companies, data processing companies, and other service providers. We may also disclose all of the personal and financial information we collect, as described above, concerning our current and former customers to financial service providers, such as insurance agents, and to companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements. Sharing information with these companies is permitted by law.
We may also disclose nonpublic personal information about you to nonaffiliated third parties as permitted by law and you do not have a right to opt out of the disclosure of this information.
All of these companies act on our behalf, and are contractually obligated to use the information that we provide to them only to provide the services that we have contracted with them to perform. Each company is required to keep all such information strictly confidential, and is prohibited from making any of this information available to any other entity.
Disclosure In Other Circumstances
Furthermore, we may disclose nonpublic personal information about you to our affiliates outside the Emigrant Family of companies, and/or to other third parties, including, but not limited to, financial service providers, such as mortgage bankers, securities broker-dealers, credit card companies, and insurance agents.
All of these companies are contractually obligated to use the information that we provide to them only to provide the services that we have contracted with them to perform. Each company is required to keep all such information strictly confidential.
We may disclose personal and financial information in other circumstances, but we do not disclose any personal and financial information about our customers or former customers to anyone, except as permitted by law. This may include information provided:
- with your consent or direction;
- to comply with federal, state or local laws or other legal requirements, or a subpoena, summons, or judicial process, or to federal, state or local authorities, to the extent authorized by applicable law and regulation, including the Right to Financial Privacy Act;
- to protect the confidentiality or security of records pertaining to you, or a service, product or transaction pertaining to you;
- to protect against fraud, unauthorized transactions, claims or other liability;
- to a fiduciary on your behalf, or to your attorney, accountant or auditor; or
- under other circumstances authorized by law or regulation.
The Emigrant Family
This Consumer Privacy Policy is provided on behalf of the Emigrant Family of companies that offer consumer-related financial services: Emigrant Bank (providing a full range of banking products); its retail banking affiliates: Emigrant Savings Bank - Bronx/Westchester, Emigrant Savings Bank - Brooklyn/Queens, Emigrant Savings Bank - Long Island, and Emigrant Savings Bank - Manhattan; Emigrant Mortgage Company, Inc. (offering residential mortgage loans), Emigrant Agency, Inc. doing business as Emigrant Financial Services (featuring insurance, annuity, and mutual fund products), EmigrantDirect (a division of Emigrant Bank offering certain banking products and services via the Internet), and New York Private Bank & Trust (a division of Emigrant Bank, offering private banking services).
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