Digital Privacy Policy

Revised February 26, 2024

Paradise Bank is pleased to share its privacy policy with you. We encourage you to read carefully the following important information.

In just a few short years, the Internet has revolutionized the way we do business. It allows us to interact with you personally across time and space to offer information and additional value, to listen to your opinions and to provide a host of banking and financial services that you can access from the convenience of your home or office. At the same time, it also brings legitimate concerns about privacy and security.

At Paradise Bank safeguarding your confidentiality and protecting your personal and financial information is fundamental to the way we do business. In fact, it is one of our highest priorities and remains the cornerstone of our commitment to you. At Paradise Bank the basis of each customer relationship, many of which span generations, is trust. We are dedicated to meeting or exceeding the privacy standards established by federal and state regulations and industry bodies. All our information handling practices comply with federal and state laws including the Gramm-Leach-Bliley and Fair Credit Reporting Acts, which are designed to protect the privacy of consumers.

However you choose to provide information to us, we use rigorous security safeguards to ensure your personal and financial information is protected. We are also committed to informing our customers about our privacy policies and information handling practices. On an annual basis, these policies will be outlined in a disclosure notice that describes what information is collected, how it is used and shared, how it is protected, and what choices you have with respect to sharing your personal information.

You are invited to use this privacy site to learn about the types of information we collect and how it is used, and about the steps we have taken to ensure the appropriate handling of your personal and financial information.

At Paradise Bank, we gather and use personal information to provide you with the financial services you have requested, or to offer you additional products and services. Most of the information we collect is voluntarily provided directly from you. For example, we may collect personal information from applications or other forms completed by you, and from your transactions with us. We may also collect information from consumer reporting agencies.

When you request products or services, we will ask you to provide only the information that enables us to complete your request, to provide better service or to offer you products and services we believe you might be interested in. These same principles also apply to our business clients. The types of information we may ask for depend on the nature of our request. Information that is essential for fulfilling most financial requests and applications typically includes your name, mailing address, e-mail address, phone number(s), account number(s), and Social Security Number.

When you visit our website, we do not collect any information that could identify you personally unless you choose to provide it to us. You are welcome to browse our website at any time anonymously and privately without revealing any personal or financial information about yourself.

All the information you provide to us is securely maintained and is kept strictly confidential.

At Paradise Bank, we collect personal information and anonymous/non-personal information.

 

Personal information is information that refers to you specifically. The type of personal information we usually collect and maintain in your customer file may include your:

• Name • Mailing Address • E-mail Address • Telephone Number • Social Security Number • Date of Birth • Place of Employment • Annual Income • Credit History • Transaction History

For business customers, information may include:

• Business Name • Business Address • Business Telephone Number • Name(s) of Owner(s), Officer(s) and Director(s) • Industry Type • Financial Status

The choice to provide us with personal information is always yours. In financial dealings, however, your decision to withhold details may limit or prevent us from providing the services you have asked for or that we are able to provide and may make it more difficult
for us to advise you or suggest appropriate alternatives. Different activities will call for various levels of information. If we are unable to accommodate your request based on the information that has been provided, we may ask for additional details to identify other ways to be of assistance. Occasionally we may also maintain a file containing contact history that is used for customer inquiry purposes.

At Paradise Bank, we routinely collect anonymous/non-personal information. Anonymous/non-personal information is information that cannot be associated with or traced back to a specific individual or business entity. For example, our web servers collect some anonymous/non-personal information automatically when you visit our Web site. Gathered electronically, this information might include the pages you visited, the type of Web browser you are using, the level of encryption your browser supports, information about your device’s operating system, and additional information associated with your device. We may also collect information through cookies, tags, and other technologies. The anonymous/nonpersonal information we collect may be used for research and analytical purposes. For example, we are able to determine how many times our online privacy policy has been visited but we do not know any specific information about those visitors.

To help us better understand our markets, we may also gather information for analytical purposes by conducting anonymous customer surveys.

At Paradise Bank, the type of information you will be asked to provide will vary according to your activity or request:

• Everyday Financial Services • Browsing Our Web Sites • Online Banking • Extended Financial Services Needs

For deposit-related financial services like opening a deposit or business account, applying for a credit card, or purchasing a certificate of deposit, you’ll be asked to provide information such as your name, address and telephone number (business name and address in the case of business customers).

If you are applying for credit in the form of a loan or a credit card, you will also be asked for specific information about your current financial situation and/or your business or other credit related information. This may involve exchanging information with credit agencies or verifying references you have provided us.

Browsing Our Web Sites

You may browse our website anonymously and privately, even if you do not wish to interact with us or use our online services. No personal or financial information will be collected from you unless you voluntarily provide it.

If you are currently a Paradise Bank customer and you have a Paradise Bank checking account, then you may enroll in our Online Banking service. During the enrollment process, you will be asked to provide your name, your account number and address information.

At Paradise Bank we use three primary types of information:

• We use personal/financial information to communicate with you, process applications or to provide you with the products and services you have requested. • We use transactional information to keep track of and report back to you on your dealings with us. • We use anonymous/non-personal information to improve our products and services to you.

We use your personal and financial information to communicate with you, process applications and effectively provide the services you have requested. The better we know you, the better we can help you achieve your financial goals. By sharing information about yourself, we can begin identifying your financial service requirements - for now and for the future. When you become a Paradise Bank customer, we will make every effort to establish and maintain an ongoing positive relationship with you. To help us do this, we use the personal information you have provided to us to communicate with you and to safeguard your interests. We will keep you informed about your account activities, authenticate your identity, send you important notices, and respond to any special needs or inquiries you may have. We may also send you information about other products and services in which we believe you would be interested.

The majority of information we retain about you is in the form of transaction records that reflect your business dealings with us. We update and maintain this information on an ongoing basis. If applicable, we will communicate this information back to you in the form of regular statements or through financial transactions.

The anonymous/non-personal information gathered from the Web is used primarily for technical, research and analytical purposes like evaluating the various sections of our website, this information is not personally identifiable.

At Paradise Bank we may share information about you or your accounts with the following:

• With other Paradise Bank Corporate family member companies that provide products and services we believe you may be interested in. We currently have only Paradise Bank with no subsidiaries or affiliates. • With authorized Paradise Bank Employees who have a legitimate business purpose and reason for accessing customer information. • With outside service suppliers who perform specialized services on our behalf. • With other parties as required or permitted by law.

Client information is kept strictly confidential, and we adhere to standards and policies that have been designed to ensure your information is secure and treated with the utmost care and respect.

As we grow and to ensure you benefit from our full range of products and services, your information may be shared with other Paradise Bank businesses, affiliates and subsidiaries. This will be done only when the proposed services are available through another member, and only in the manner we have disclosed to you.

In the course of daily operations, access to private, sensitive and confidential information is restricted to authorized employees who have a legitimate business purpose and reason for accessing it. For example, when you call us, visit a branch, or e-mail us, our employees will access your information to verify that you are the accountholder and to assist you in fulfilling your financial requests.

As a condition of their employment, all employees of Paradise Bank are required to abide by the privacy standards established by Paradise Bank. They are also required to work within the principles of ethical behavior as set out in our internal Employee Code of Ethics and must follow all applicable laws and regulations. Employees are well informed about the importance of privacy and they are required to sign either a code of conduct or confidentiality agreement that prohibits the disclosure of any client information to unauthorized individuals or parties. Employees periodically receive up-to-date literature about our privacy policy, principles and standards, and are required to confirm their understanding and commitment to upholding client privacy and confidentiality.

Unauthorized access to and/or disclosure of client information by an employee of Paradise Bank is strictly prohibited. All employees are expected to maintain the confidentiality of customer information at all times and failing to do so will result in appropriate disciplinary measures, which may include dismissal.

At Paradise Bank we sometimes contract outside organizations to perform specialized services such as check printing, market research or data processing. Our trusted service suppliers may at times be responsible for processing and handling some of the information we receive from you. For example, we give our check-printing agent the information that you have requested to display on the face of your checks. And our service processor may access records held by Paradise Bank for such information as your phone number, home address or email address. Our Processor will use this contact information to alert you about Service-related events or actions that require your attention. If you grant permission to use phone information, our processor will use the phone number to pre-populate forms that expect a personal phone number for contacting you. If you grant permission to use your device's location, our processor will use the data when checking for nearby branch and ATM locations. If you grant permission to use access photos, media or other files stored on your device, our processor will use that information to add an image to a transaction, to attach a document to chat, and add a photo to your profile. If you grant permission to use a camera, our processor will use it when taking a picture to add an image to a transaction or to capture images of a check that is being deposited or to add a photo to your profile.

When we contract our suppliers to provide specialized services, they are given only the information necessary to perform such services. Additionally, they are prohibited from storing, analyzing or using information for purposes other than to carry out the service they have been contracted to provide. In fact, our suppliers are bound by strict contractual obligations that have been designed to protect the privacy and security of your information. Furthermore, as part of our contract agreements, our suppliers and their employees are required to protect your information in a manner that is consistent with the privacy policies and practices that we have established.

The type of information we are legally required to disclose most often relates to governmental tax reporting requirements. In some instances, such as a legal proceeding or court order, we may be required to disclose certain information to the authorities. Only the information specifically requested is disclosed and it is our practice to validate the legitimacy of a request.

There are some situations where we are legally permitted to disclose your personal information to members and non-members of Paradise Bank such as to protect the confidentiality of your security and your bank records, to service or process your financial products or to respond to or carry out transactions you request or initiate. Other examples include returning a check due to insufficient funds, employing reasonable and legal methods to collect a delinquent account, a medical emergency or suspicion of illegal activities, to companies that provide services to us, to a consumer reporting agency regarding our experience with you, or in connection with our joint marketing arrangements to persons acting on your behalf.

At Paradise Bank decisions are often made based on the information we have. Therefore, it is important that your personal and financial information is accurate and complete. As a customer, you may access, verify and amend the information held in your personal and financial files.

You may access and verify any of your regular account or transactional information whenever you wish. Most of this information is available in the form of transaction records and account statements are generally the best source for this type of information.

Should you have questions concerning a decision we have made, we may inform you of the reasons for those decisions if we are permitted to do so by law. We will, upon request, provide you with the name(s) and address(es) of any consumer agencies that provided information to us on your behalf if it was relevant to our final decision.

To help us keep your information up to date, we encourage you to amend inaccuracies and make corrections as often as necessary. Should you identify any information in your file(s) that needs to be adjusted, we will make the proper changes in our files. Where appropriate, we will use every reasonable effort to communicate these changes to other parties who may have unintentionally received incorrect information from us.

Account deletion options cannot be added to the online or mobile applications as this option falls under Federal Regulations. Deleting a bank account would be in direct violation of several federal regulations and acts. The Federal Deposit Insurance Corporation and Bank Secrecy Act requires banks and other financial institutions to implement Customer Identification Programs to prevent money laundering. These programs mandate that banks obtain and retain checking and savings account customer data, including contact, identification, and tax information. FDIC and BSA regulations stipulate that banks must keep this information for at least five years after the account is closed. Regulations Federal Deposit Insurance Corporation (FDIC) 8000 1020.220 Bank Secrecy Act (BSA), 31 USC 5311, 12 CFR 21.11 and 12 CFR 21.21. The above regulations are only a subset of regulations that financial institutions are required to comply with.

To request a change to the personal contact information contained in your file, please contact us at 561-392-5444.

How We Safeguard Your Information

At Paradise Bank we maintain security standards to ensure that your personal and financial information is protected against unauthorized access, disclosure, inappropriate alteration, or misuse. All safety and security measures are also appropriate to the sensitivity level of your information.

Electronic client files are kept in a highly secure environment with restricted access. Paper-based files are stored in secured filing cabinets. Access is also highly restricted.

We manage our server environment appropriately and our firewall infrastructure is strictly adhered to. Our security practices are reviewed on a regular basis, and we routinely employ current technologies to ensure that the confidentiality and privacy of your information is not compromised.

We use Secure Socket Layer (SSL) and 128 bit encryption technologies to enhance security when you visit the secured areas of our Web site. SSL is the industry standard tool for protecting and maintaining the security of message transmissions over the Internet. When you access your accounts or send information, encryption will scramble your data into an unreadable format to inhibit unauthorized access by others.

To safeguard against unauthorized access to your accounts, you are required to “sign-on” using an encrypted password to certain secure areas of our website. If you are unable to provide the correct password, you will not be able to access these sections.

Your password information is encrypted which is presently the most effective way to secure data. To protect your Online Banking activity, our systems are designed to automatically terminate your session if extended inactivity is detected. If your session is terminated, you will be required to sign-on again to continue banking.

When you call one of our branch locations, you will be required to verify your identity by providing your account number and/or some personally identifying information.

On Occasion Paradise Bank may provide links on its website to other websites operated by third parties. If you use these links, you will leave Paradise Bank’s website, and your browser will be redirected to websites over which Paradise Bank has no control. You should acquaint yourself with these other websites, as they may have privacy policies that differ significantly from Paradise Bank.

We do not knowingly solicit data from children, and we do not knowingly market to children. We recognize that protecting children’s identities and privacy online is important and that the responsibility to do so rests with both the online industry and with parents.

We believe there are measures you should take to protect and safeguard your personal and financial information. The following is a list of things you can do to protect yourself against fraud and uninvited intrusion.

Verifying your identity when you call us on the phone is a requirement before we can give out any information. Employees are required to ask you a series of questions concerning your personal information and relationship with Paradise Bank in order to verify your identity prior to releasing any information over the phone.

Passwords are necessary to identify you and authenticate your permission to access your accounts. When you enroll in online services such as Online Banking, the password you use is encrypted. Encryption is presently the most effective way to achieve data security. Just as it is important for us to employ strict procedures to safeguard your information, you also should take precautions in handling your passwords. When selecting a password, we suggest that you use a combination of letters and numbers and do not use words that can be easily associated with you such as the name of a child, a pet or the street on which you live. We also suggest that you change your password regularly.

You should not share personal or financial information such as your Personal Identification Number, Social Security Number, or credit card number with others unless you clearly understand the purpose of their request and you know with whom you are dealing.

To make sure your connection to the protected areas of our Web site is secured, look for either a ‘closed lock’ or an ‘unbroken key’ icon located at the top or bottom right-hand side of your browser’s task bar. You may also check the Address bar to determine if SSL (Secure Socket Layer) is active by looking at the beginning of the address. If it starts with “https” rather than the standard ‘http”, then SSL is operating.

Our Web site may contain links to other third-party sites that are not governed by this privacy statement. Although we endeavor to only link to sites with high privacy standards, our privacy policy will no longer apply once you leave our Web site. Additionally, we are not responsible for the privacy practices employed by other third-party Web sites. Therefore, we suggest that you examine the privacy statements of those sites to learn how your information may be collected, used, and disclosed.

What are cookies?

Cookies are small text files that your browser stores on your computer or mobile device when you visit a site. When you return to a site you have visited before, your browser gives this data back to the site to help it remember your preferences and personalize your experience; enhance site performance and security; and enable interest-based advertising. When you visit our Site, we, or our service providers, may use cookies or other similar technologies to collect information on our Site.

We use cookies and information collected through their use to make your experience with Paradise Bank richer and more personalized based on the products, services, or other interactions you have with us.

If we make updates to this Policy, we will update the Policy with the changes and revise the "date of most recent update" posted at the top of this Policy. Any updates to the Policy become effective when we post the updates on the Site. To the extent permitted by applicable law, your use of the Site following the update to the Policy means that you accept the updated Policy.