Enterprise Privacy Notice

Enterprise Privacy Notice

Effective Date: October 1, 2024 
Last Revised: October 1, 2024 

The privacy and security of your information is very important to Pinnacle Bank (“Pinnacle Bank”, “we”, “us”, “our”). We are deeply committed to maintaining industry standard levels of security that comply with applicable federal and state laws to help protect the personal information that we collect. 

This Enterprise Privacy Notice applies to your interaction and communication with Pinnacle Bank, including, without limitation, in person, by phone, through mail or email or through any online or mobile site, application or social media account that Pinnacle Bank owns and controls (collectively, “Sites”), unless a separate privacy notice is posted or made available to you and supplements this Enterprise Privacy Notice. 

This Enterprise Privacy Notice applies only to the Sites and does not extend to other websites, including websites owned and controlled by our partners or third-party websites for which we have provided links, or to any social media platforms, which are governed by their own terms of use and privacy policies. 

By accessing or using our Sites or otherwise disclosing information to us, you agree that you are providing freely given, specific, informed and unambiguous consent to our collection, use, and sharing of your information in accordance with this Enterprise Privacy Notice. 

Information we collect and the sources from which we collect it: 

We collect the below categories of information directly and indirectly from individuals and the parties with which we do business in a variety of ways, including in person, by phone, through mail or email and through our Sites. These may include parties that interact with us directly (our customers or individuals that apply for our products, respond to our surveys, request information about our products or services or otherwise voluntarily provide us with their information), parties to which we provide goods or services, parties that provide goods or services to us and other parties with whom we offer or provide products and services. 

We may collect and store the following types of information: 

• Identifiers, such as name, address, email address, phone number, date of birth, Social Security number, taxpayer ID, driver’s license number, passport number, government ID or IP address. 
• Protected classification characteristics, such as race, color, national origin, marital status, sex, veteran or military status. 
• Geolocation data, such as physical location or movements. 
• Commercial information, such as organizational information, records of personal property or purchasing history. 
• Internet or other similar network activity, such as browser information, search history, device type or service provider information. 
• Professional or employment-related information, such as income or current or past job history. 
• Inferences drawn from other information, such as person’s preferences, trends or behaviors. 
• Personal records, such as family history or power of attorney. 
• Information that you provide by filling in forms or providing other contributions on our Sites, through email or over the phone. 
• Information received from a government entity or other third party. 
• Records and copies of your correspondence (including email addresses), if you contact us. 
• Responses to surveys. 
• Details of transactions you carry out through our Sites, such as, financial information, account information, credit information or transactional information. 
• Account information when you register for an account on our Sites. 
• Any other information that you provide to us. 

Further, we and our service providers may use various tracking technologies, including cookies, to collect information about you when you interact with our Sites, including information about your browsing and viewing behavior. Cookies are small data files stored on your hard drive or in device memory that help us improve the Sites and your experience, see which areas and features of the Sites are popular and count visits. In addition, when you access or use the Sites, our servers automatically record certain log file information, such as your Internet Protocol address, operating system, browser type and language, referring URLs, access times, pages viewed, links clicked and other information about your activities on the Sites. 

If you want to remove existing cookies from your device, you can do this using your browser options. Please bear in mind that deleting and blocking cookies may have an impact on your user experience. Visit the Federal Trade Commission to learn more about how to limit tracking and online advertising through controlling cookies and other tracking technology that is attached to your browser. 

Certain information set forth above may be categorized as “personal information” to the extent it identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. Such personal information may receive additional protections under applicable state or federal law (see below). 

Personal information specifically does not include information that is publicly available information from government records, or information that is de-identified or aggregated information. 

How we use information we collect: 

We may use information: 

• To detect, investigate or prevent activity that may be illegal, violate our policies, cause harm to our operations or compromise our security. 
• To optimize, improve or enhance our products, services and operations. 
• To respond to your inquiries or fulfill your requests, including to provide individuals with, or evaluate their eligibility for, products and services that they have requested from us. 
• To communicate with individuals about their accounts or transactions that they have made with us. 
• To provide important information regarding our products or services, including changes to our policies or other terms, conditions or agreements and our Sites. 
• To allow participation in surveys, sweepstakes, contests and other promotions. 
• To comply with legal and regulatory requirements, required disclosures and choices or controls that may be available. 
• To send offers and promotions for our products and services or for other products and services that may be of interest. 
• To personalize online or mobile content and user experiences. 
• To verify the identity or location of an individual for security, fraud prevention and other risk control purposes. 
• To provide advertising based on activity on our Sites. 
• To perform operational functions in connection with our business, including data analysis, audits, developing and improving products and services, enhancing the Sites, identifying usage trends, and determining the effectiveness of promotional campaigns. 
• In connection with your employment (to the extent applicable to you). 
• To maintain appropriate records for internal administrative purposes. For any other purpose disclosed by us to you at the time you provide us information. 
• For any other purpose with your consent. 

We may disclose each of the categories of information we collect for any of the business purposes set forth above. 

To the extent you have obtained a financial product or service from Pinnacle Bank that is used primarily for personal, family or household purposes, please refer to the supplemental privacy statement found here with respect to how Pinnacle Bank will use and share your personal information collected in connection with such financial product or service. 

How we share information we collect: 

Generally, our sharing of information is subject to additional rights available under applicable federal or state law. 

We may disclose each of the categories of information that we collect: 

• To our subsidiaries and affiliates. 
• To contractors, service providers and other third parties we use to support our business. 
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of any or all of Pinnacle Bank's assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which information held by Pinnacle Bank about our Site users is among the assets transferred. 
• To third parties to market their products or services to you. 
• To fulfill the purpose for which you provide it. 
• For any other purpose disclosed by us when you provide the information. 
• With your consent. 
• To comply with any court order, law, or legal process, such as, responding to any government or regulatory request. 
• To enforce or apply our terms of use with respect to our Site and other agreements, including for billing and collection purposes. 
• If we believe disclosure is necessary or appropriate to protect the rights, property or safety of Pinnacle Bank, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. We may disclose aggregated information about you, and information that does not identify any individual, without restriction. 

We may disclose each of the categories of information we collect for any of the business purposes set forth above. 

To the extent you have obtained a financial product or service from Pinnacle Bank that is used primarily for personal, family or household purposes, please refer to the supplemental privacy statement found here with respect to how Pinnacle Bank will use and share your personal information collected in connection with such financial product or service. 

Third Party Analytic Services: 

We may work with certain third parties to collect, analyze, and use some of the information described above. For example, we may allow third parties to set cookies or use web beacons on the Sites or in email communications from Pinnacle Bank. The information collected by third parties using these technologies may be used to engage in analysis and reporting. These third parties may set and access cookies on your computer or other device and may collect information about your online activities across different websites or services over time, including on websites and mobile applications that are not owned or operated by Pinnacle Bank. Any personal information that we provide to third parties is subject to restrictions on use contained in written contracts or agreements or industry practice. 

In addition, we use advertising service providers to place advertisements for our accounts and services on websites not affiliated with us, and to help us determine which of our advertisements are most likely to be of interest to you using non-personal information. Advertisements placed by these service providers may use tracking technologies that allow monitoring of your responsiveness to such advertisements. We restrict access and collection of information by advertising service providers for purposes other than assisting us with our advertising efforts. 

While most web browsers are automatically set to accept cookies, web browser preferences can be modified to disable cookies. Disabling or declining cookies, however, will likely impact or disable some of our Sites’ functionality and/or your user experience. While cookies are not required to browse our Site, they may be required for access to accounts. You may opt out of certain advertising and web analytic cookies by visiting the “Modify Privacy Options” link at the bottom of this page. 

Children’s Online Privacy Protection Act: 

Pinnacle Bank does not knowingly solicit individually identifiable personal information from or about children online and does not knowingly market our products to children online. We fully support protecting children's identities and privacy online and recognize the responsibility to do so rests with both the online industry and with the parents. 

USA PATRIOT Act: 

Important Information About Procedures for Opening a New Account 

To help the government fight the funding of terrorism and money laundering activities, federal law requires all banks to obtain, verify and record information that identifies each person who opens an account. 

What this means to you: When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver's license and other identifying documents. 

Notice to International Users: 

The Sites and bank products and services are offered and hosted in the United States and subject to U.S. law, and are intended for users located only in the U.S. If you are accessing the Sites or bank products and services from outside the United States, please be advised that U.S. law may not offer the same privacy protections as the laws of your jurisdiction. By accessing and using the Sites or bank products and services, you consent to the transfer to and processing of your personal information in the U.S. 

Linked Websites: 

The Sites may contain links to third-party websites not controlled by Pinnacle Bank. We encourage you to be aware when you leave a Site and to read the privacy policies and terms of use of any such websites that may collect your personal information, as they will likely differ from those of specific to our Sites. Pinnacle Bank does not guarantee and is not responsible for the privacy or security of these websites, including the accuracy, completeness or reliability of their information. 

In addition, Pinnacle Bank is not responsible for the information collection, use and disclosure practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, or any other app developer or provider, social media platform provider, operating system provider, wireless service provider or device manufacturer. 

Social Media Platforms: 

Pinnacle Bank may interact with registered users of various social media platforms, including Facebook®, LinkedIn®, and X®. Please note that any content you post to such social media platforms, as well as any personal information that you otherwise make available to users (such as information within your profile), is subject to the applicable social media platform’s terms of use and privacy policies. We recommend that you review this information carefully in order to better understand your rights and obligations with regard to such content. 

Security: 

Your privacy is very important to Pinnacle Bank and we are committed to protecting your personal information from unauthorized access or use. We will use reasonable organizational, physical, technical and administrative measures to protect personal information within our organization. Our policy is to restrict access to nonpublic personal information about you only to those employees who need to know that information to provide products or services to you, or to provide necessary technical support. 

Changes to this Enterprise Privacy Notice: 

We may change this Enterprise Privacy Notice at any time. The most current version of this Enterprise Privacy Notice will be posted and available on the Sites. Any changes to this Enterprise Privacy Notice will be effective at the time we post the revised Enterprise Privacy Notice to the Sites. If we make material changes to how we treat your information, we will notify you through a notice on our Sites home page. Please review it periodically. Your use of the Sites following any changes made means that you accept the revised Enterprise Privacy Notice. 

Contact Information: 

If you have any questions or comments about this Enterprise Privacy Notice, please do not hesitate to contact us at: 

Website: https://www.pinnbank.com/contact 
Email: customerservice@pinnbank.com 

Pinnacle Bank 
1401 N Street 
Lincoln NE 68508

California Consumer Privacy Act Notice 

Effective Date: October 1, 2024 
Last Revised: October 1, 2024 

If you are a California resident, in addition to the information provided above, California law may provide you with additional rights regarding our use of your personal information; subject to exclusions from the rights granted under California law ("California Consumer Privacy Act" or "CCPA") with respect to certain information governed by certain sector-specific privacy laws, including the Gramm-Leach-Bliley Act (“GLBA”), the Fair Credit Reporting Act (“FCRA”), or the California Financial Information Privacy Act (“FIPA”). 

Categories of Personal Information That Pinnacle Bank Has Collected in the Last 12 Months: 

We may collect personal information from California consumers in a variety of different situations, including, but not limited to on any of our websites, your mobile device, through email, in physical locations, through the mail, over the telephone, and/or in any other situation where we interact with you. More specifically, Pinnacle Bank collects the following categories of personal information from you as a California consumer, which will depend on the particular business purpose for which we collect it:

Sensitive Personal Information Collected in the Last 12 Months 

Privacy laws in California specify certain rights with respect to our collection of certain information those laws designate as “Sensitive Personal Information.” When we notify California residents that we collect Sensitive Personal Information that means that we collect Sensitive Personal Information within the meaning of California law. We collect the following Sensitive Personal Information in California: 

• Social Security, driver’s license, state identification card, passport number 
• Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account 

Pinnacle Bank does not share Sensitive Personal Information for purposes of cross-context behavioral advertising. 

Retention Period 

We store personal information for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations, or as required by the terms of a client contract. 

How Does Pinnacle Bank Safeguard Personal Information? 

Pinnacle Bank maintains physical, electronic and procedural safeguards to protect against unauthorized access to personal information. In addition, Pinnacle Bank limits access to personal information to those with a need to know. All employees with access to personal information complete annual privacy and security training. 

Sharing or Selling Your Personal Information 

We do not sell personal information to third parties for monetary consideration without your prior consent, but we may share your personal information with third parties for cross-context behavioral advertising . 

The categories of personal information that we may have shared are: 

• Identifiers, including IP addresses, cookie identifiers, and other pseudonymous identifiers 
• Account information 
• Internet or other electronic network activity information 
• Professional or employment information 
• Inferences drawn from personal information 

We do not purposefully sell or share the personal information of children under the age of 16. 

For more on your personal information share/sale rights, see below. 

We reserve the right to transfer any personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation). 

Use of Sensitive Personal Information 

Under the California Consumer Privacy Act, we collect the types of sensitive personal information described in the "Sensitive Personal Information Collected" section above. Pinnacle Bank only collects and uses sensitive personal information for certain limited purposes, such as providing services and products to consumers, detecting data security incidents, and protecting against fraud (“Limited Purposes”). Because Pinnacle Bank uses this sensitive personal information for Limited Purposes, there is no need for us to provide a Limit Use and Disclosure of Sensitive personal information right under the CCPA. 

Rights Under the CCPA: 

The CCPA provides California consumers with certain additional rights regarding their personal information. 

Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, disclose, and sell, and to access your information, (2) request deletion of your personal information, (3) request correction of your personal information and (4) not be discriminated against for exercising these rights, (5) limit processing of Sensitive Personal Information. 

Right to Know 

You have the right to know what personal information Pinnacle Bank has collected about the you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom Pinnacle Bank discloses personal information, and the specific pieces of personal information Pinnacle Bank has collected about you. 

We will disclose the applicable information upon receipt of your verifiable consumer request (see “Submitting a Verifiable Consumer Request” section below). 

Right to Deletion 

You have the right to request that we delete any of your personal information subject to the various exceptions provided in the CCPA (see “Submitting a Verifiable Consumer Request” section below). 

We may deny your deletion request under certain circumstances, and will inform you of the basis for the denial, which may include, but is not limited to, if retaining the information is necessary for us or our service provider(s) to: 

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. 
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. 
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. 
• Comply with a legal obligation. 

Right to Correction 

You have the right to request that we correct information that is inaccurate (see “Submitting a Verifiable Consumer Request” section below). 

Right to Portability 

A California resident may have the right to request that we transmit their personal information to another entity in a portable, easily understandable, and to the extent technically feasible, in a structured, commonly used, machine-readable, and readily usable format. 

Right to Opt-Out 

Our use of tracking technologies may be considered a “sale” under California law. If you are in California, you can opt-out of being tracked by these third parties by submitting a verifiable consumer request. 

Right to Non-Discrimination 

We will not discriminate against you because you elect to exercise any of your rights under the CCPA including, but not limited to: 

• Denying goods or services to you 
• Charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties on you 
• Providing a different level or quality of goods or services to you 
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services 

Submitting a Verifiable Consumer Request 

In order to protect your information, we can only honor requests to know, correct or delete upon receipt of a verifiable consumer request. 

You may submit a verifiable consumer request by using the web form or calling 1-800-227-7715 from Monday through Friday between 8 AM and 8 PM CT. 

Individuals who are authorized to submit a request on behalf of another individual may also do so through the web form . 

Upon receiving your request, we will respond via email with a request for certain information required to verify your identity. You are responsible to respond to the request from us for additional information to enable us to verify your identity within ten (10) business days or your request will be rejected. 

A California resident may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify the requestor is the person about whom we collected personal information or an authorized representative and describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to a request or provide personal information if we cannot verify the identity or authority to make the request. 

Response Timing and Format 

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing. 

We will deliver our written response by mail or electronically, at your option. 

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 

For any questions related to Pinnacle Bank’s privacy policies and information practices, you may contact us at [insert email or other contact info]. 

Changes to Our California Privacy Notice 

We may change the California Privacy Notice provisions from time to time. If we make changes to this privacy notice, we will notify you by revising the effective date at the top of this policy. We encourage you to review this policy regularly to stay informed about our information practices and the choices available to you.