California Consumer Privacy Act
California Consumer Privacy Act Disclosure
Last updated January 1, 2020
Your privacy is important to us. This California Consumer Privacy Act Disclosure explains how Preferred Bank (“Company,” “we,” or “us”) collects, uses, and discloses personal information relating to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”). This notice is provided pursuant to the CCPA.
Under the CCPA, ‘Personal Information’ is information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular California resident. The CCPA, however, does not apply to certain information, such as information subject to the Gramm-Leach-Bliley Act (“GLBA”).
The specific Personal Information that we collect, use, and disclose relating to a California resident covered by the CCPA will vary based on our relationship or interaction with that individual. For example, this Disclosure does not apply with respect to information that we collect about California residents who apply for or obtain our financial products and services for personal, family, or household purposes. For more information about how we collect, disclose, and secure information relating to these customers, please refer to our Privacy Notice.
Keeping Personal Information secure is one of our most important priorities. Consistent with our obligations under applicable laws and regulations, we maintain physical, technical, electronic, procedural and organizational safeguards and security measures that are designed to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, or access, whether it is processed by us or elsewhere.
Collection and Disclosure of Personal Information
In the past 12 months, we have collected, and disclosed to third parties for our business purposes, the following categories of Personal Information relating to California residents covered by this disclosure:
- Identifiers, such as name, government-issued identifier (e.g., Social Security number, driver’s license number, passport number), email address, account name, or other similar identifiers;
- Personal information, as defined in the California safeguards law, such as name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification number, insurance policy number, financial information such as a bank account, credit card, or debit card numbers.
- Characteristics of protected classifications under California or federal law, such as race, color, national origin, citizenship, religion or creed, martial status, disability, sex, or veteran or military status.
- Commercial information, such as records or personal property, transaction information and purchase or consuming histories or tendencies;
- Internet or network activity information, such as browsing history, search history, and information regarding interactions with our website or application;
- Geolocation data, such as device location and Internet Protocol (IP) location;
- Audio, electronic, visual and similar information, such as call and video recordings;
- Professional or employment-related information, such as work history and prior employer;
- Education information, such as student records and directory information;
- Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.
We may disclose your personal information to a third party for a business purpose. When we disclose information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except for performing the contract.
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- 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 (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
The categories of sources from whom we collected this Personal Information are:
- Directly from a California resident or the individual’s representatives
- Service Providers, Consumer Data Resellers and other third parties
- Public Record Sources (Federal, State or Local Government Sources)
- Website/Mobile App Activity/Social Media
- Information from Client Directed Third Parties or Institutions representing a Client/Prospect
- Information from Corporate Clients about individuals associated with the Clients (e.g., an employee or board member)
The categories of third parties to whom we disclosed Personal Information for our business purposes described in this privacy disclosure are:
- Vendors and Service Providers
- Third Parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
- Other Third Parties who enable customers to conduct transactions online and via mobile devices, support mortgage and fulfillment services
- Government Agencies as required by laws and regulations
Use of Personal Information
In the past 12 months, we have used Personal Information relating to California residents to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including the following:
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Short-term, transient use where the information is not disclosed to a third party and is not used to build a profile or otherwise alter an individual consumer’s experience outside the current interaction.
- Auditing related to a current interaction and concurrent transactions.
- Undertaking activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance the service controlled by the business.
- Debugging to identify and repair errors that impair existing intended functionality.
- Undertaking internal research for technological development and demonstration.
- Complying with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reflecting legal or regulatory guidance, codes or opinions)
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
Sale of Personal Information
In the past 12 months, we have not “sold” Personal Information subject to the CCPA, including Personal Information of minors under the age of 16. For purposes of this Disclosure, “sold” means the disclosure of Personal Information to a third-party for monetary or other valuable consideration.
Rights under the CCPA
If you are a California resident, you have the right to:
- Request we disclose to you free of charge the following information covering the 12 months preceding your request:
- the categories of Personal Information about you that we collected;
- the categories of sources from which the Personal Information was collected;
- the purpose for collecting Personal Information about you;
- the categories of third parties to whom we disclosed Personal Information about you and the categories of Personal Information that was disclosed (if applicable) and the purpose for disclosing the Personal Information about you; and
- the specific pieces of Personal Information we collected about you;
- Request we delete Personal Information we collected from you, unless the CCPA recognizes an exception; and
- Be free from unlawful discrimination for exercising your rights under the CCPA
We will acknowledge receipt of your request and advise you how long we expect it will take to respond if we are able to verify your identity. Requests for specific pieces of Personal Information will require additional information to verify your identity.
If you submit a request on behalf of another person, we may require proof of authorization and verification of identity directly from the person for whom you are submitting a request.
In some instances, we may not be able to honor your request. For example, we will not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual. Additionally, we will not honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer or where the Personal Information that we maintain about you is not subject to the CCPA’s access or deletion rights.
We will advise you in our response if we are not able to honor your request. We will not provide social security numbers, driver’s license numbers or government issued identification numbers, financial account numbers, account passwords or security questions and answers, or any specific pieces of information if the disclosure presents the possibility of unauthorized access that could result in identity theft or fraud or unreasonable risk to data or systems and network security.
We will work to process all verified requests within 45 days pursuant to the CCPA. If we need an extension for up to an additional 45 days in order to process your request, we will provide you with an explanation for the delay.
We use Google Analytics (GA) for aggregated, anonymized website traffic analysis. In order to track your session usage, Google drops a cookie (_ga) with a randomly-generated ClientID in your browser. This ID is anonymized and contains no identifiable information like email, phone number, name, etc. We also send Google your IP Address. We use GA to track aggregated website behavior, such as what pages you looked at, for how long, and so on. This information is important to us for improving the user experience and determining site effectiveness.
If you would like be removed from monitoring please delete your _ga cookies install the Google Analytics Opt-Out Browser Add-On."
How to Exercise Your Rights
If you are a California resident, you may submit a request by:
- Completing an online Personal Information Request Form
- Calling 888.673.1808
Questions or Concerns
You may contact us with questions or concerns about this Disclosure and our practices by:
- Writing us at:
Preferred Bank Headquarters
601 S. Figueroa St. 47th Floor
Los Angeles, CA 90017
- Emailing us at Service Inquiries
Changes to This California Consumer Privacy Act DisclosureWe may change or update this Disclosure from time to time. When we do, we will post the revised Disclosure on this page with a new “Last Updated” date.