Privacy & Legal
Effective January 01, 2019
Personally Identifiable Information We Collect
When you use the Services, you may be prompted to submit information that uniquely identifies you or can be combined with other information that may uniquely identify you, such as, your name, postal or email address, or telephone number (“PERSONALLY IDENTIFIABLE INFORMATION”). To enroll for certain products or Services, you may also be prompted to submit additional Personally Identifiable Information, such as your username, password, date of birth, social security number, government issued ID number (such as your driver’s license number), and bank account information. In providing you Services, we may also collect Personally Identifiable Information related to your online banking activities and/or other financial transactions. Your decision to submit any Personally Identifiable Information to us through the Site or Apps is always voluntary, but may be required in order for you to use or access specific Services.
The Services also may allow you to submit Personally Identifiable Information about other individuals. For example, an App may allow you to make a payment to an individual on the contacts list on your mobile device, by selecting and transmitting that individual’s contact information to us through the App. If you choose to provide us with Personally Identifiable Information about another individual, you confirm that you are legally entitled to share that information with us.
How We Use Personally Identifiable Information
We may use Personally Identifiable Information for a variety of purposes allowed by law, such as:
- To communicate with you, including in response to your inquiries, to fulfill your requests, and to inform you of changes to terms and conditions relating to the products you receive from us or the Services in which you are enrolled;
- To provide you with information about our products and services;
- To allow you to apply for our products and services and to evaluate your eligibility for such products or services, including your credit worthiness;
- To maintain and upgrade the security of the Services and any data or information collected;
- To prevent fraud, including by confirming your identity and/or location;
- To improve our Services’ interface and functionality;
- To allow you to access features within the Site or Apps, when you request those features;
- To personalize your Services by presenting First Republic products and offers tailored to you;
- For legal, compliance and risk management purposes; and
- Other legally permissible or everyday business purposes, including data analysis, product development, and compliance with law enforcement and other legal processes.
How We Share Personally Identifiable Information
We may share Personally Identifiable Information collected through the Services with our affiliates and certain third-party service providers for the purposes described in this Policy.
- SERVICE PROVIDERS: We use service providers to deliver services to you on our behalf, such as bill payment, money transfers, check processing, wiring services and payment solutions. We share your Personally Identifiable Information with these service providers so they can deliver such services.
Other Information We Collect, Use & Share
While using or accessing the Services, our third-party service providers may also receive, or collect certain information about you, such as:
- YOUR IP ADDRESS: the numeric address assigned to the device (e.g., computer, smartphone) you are using when you access our servers.
- INFORMATION THROUGH YOUR BROWSER OR DEVICE: hardware and browser information of your computer or device, including Media Access Control (MAC) address, computer type and brand, screen resolution, operating system name and version, device manufacturer and model, browser type, and language used.
- INFORMATION THROUGH YOUR USE OF AN APP: App usage data, such as the date and time the App on your device accesses our servers, what information and files have been downloaded to the App.
- YOUR PHYSICAL LOCATION: if you use the App, the physical location of your device through the use of, for example, Bluetooth, satellite, cell phone tower, WiFi signals, or other technologies. We may use your device’s physical location to provide you with personalized location-based services, content, and offers, such as: informing you when you are approaching one of our ATMs, or banking locations, or offering you a coupon or reward that can be redeemed at a nearby location. We also may use your device’s physical location for fraud prevention purposes, if you are conducting a transaction. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you choose to deny such uses and/or sharing, we may not be able to provide you with the applicable personalized services and content.
- INFORMATION FROM YOU: information such as your state of residence as well as other information provided by you.
- AGGREGATED DATA: data we create or compile, or have created or compiled by our service providers, by aggregating data from various sources (including information collected by cookies, from accounts, transaction information, and any other information, including Personally Identifiable Information, collected through the Services), which does not personally identify you, or any other individual (“AGGREGATED DATA”). We may use and share Aggregated Data for business purposes, including data analytics, research, marketing products and services to you, and other legal or business purposes.
- INFORMATION FROM ONLINE ADVERTISING: In our efforts to deliver relevant digital advertising to you, we and other third party advertising service providers may collect information about your online activities over time and across different web sites when you use our Services. Some of the advertisements that click-through to our Services contain cookies that allow for the monitoring of your response to these advertisements, may be interest-based, and may use information about your online interests to customize the online ads you see. Interest-based advertising helps us to deliver content that is more likely to be of interest to you, and when you use our Services, we use information about your activities to help us determine which of our ads are more likely to appeal to you. If you do not wish to have us and/or our third party advertising service providers know which advertisements and subsequent websites you have viewed, you may opt-out at AboutAds. Additionally, the Digital Advertising Alliance website contains important information about interest-based advertising, cookies, behavioral advertising, and what opting out will and will not do.
We use information described in this section for purposes such as:
- calculating usage levels of the Services; helping diagnose technical issues;
- assessing the performance of our promotional campaigns;
- updating and improving our Services;
- performing maintenance and administrating our Services;
- ensuring that the Services we provide are working properly; and
- any other permissible purpose under applicable law.
Our Apps may allow you to use third-party authentication features, such as biometric technology (such as fingerprint scanning), to access the App on your device. We do not receive your fingerprint or other biometric data when you choose to use such features.
We seek to use reasonable organizational, technical, and administrative measures to protect Personally Identifiable Information that we maintain within our organization. Unfortunately, no data transmission or storage system is 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us at the telephone number listed below.
Control Over Your Personally Identifiable Information
If you would like to update Personally Identifiable Information that you have provided to us through the Services, you may contact us through one of the means listed in the “How to Contact Us” section below. Note that certain information is required to provide the Services; requests to delete required information may result in our inability to provide the Services.
We retain information, including Personally Identifiable Information, for as long as necessary to achieve the purpose for which it was collected, to fulfill legal or contractual obligations, or for as long as permitted by applicable law. We may retain Aggregated Data indefinitely.
Who May Use the Services
The Services are not directed to users under the age of 13. We do not knowingly collect personal information online from any person we know to be under the age of 13, and users under 13 must not send any information to or through the Services.
The Services are designed for users from, and are controlled and operated by us from, the United States. By using the Services, you consent to the transfer of your information to the United States, which may have different data protection rules than those of your country.
Do Not Track Signals
Your browser may allow you to send us a “do-not-track signal” to communicate your privacy preferences to us. Our Services do not respond to browser do-not-track signals.
Your California Privacy Rights
California Civil Code § 1798.83 permits users of our Services that are California residents to request certain information regarding our disclosure of Personally Identifiable Information to third-parties for their direct marketing purposes. To make such a request, please contact us through one of the means listed in the “How to Contact Us” section below.
Links to Other Websites
Our Services may feature links to third-party websites that offer goods, services, or information. When you click on one of these links, you will be leaving our Services and will no longer be subject to this Policy. We are not responsible for the information collection practices of the other websites that you visit, and urge you to review their privacy policies before you provide them with any personally identifiable information. Third-party sites or services may collect and use information about you in a way that is different from this Policy.
Changes to This Policy
Please note that we may transfer Personally Identifiable Information to a third-party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock.
How to Contact Us
If you have any questions regarding this Policy, you can call us at (888) 408-0288, or write us at:
First Republic Bank
ATTN: Customer Care Center
111 Pine Street
San Francisco, CA 94111
Phone: (888) 408-0288
Fax: (415) 392-1413