Mobile Banking Privacy Policy

Last Updated: 10/26/21

The Northwoods Bank App (the “App”)—powered by Fiserv—helps you control your credit and/or

debit cards through your mobile device, making it easy to manage your finances on the go.

The App allows you to:

• Get real-time balances for your accounts.

• Manage your money.

• View your transactions and statements.

• Make transfers.

• Pay your bills and manage billers.

• Deposit a check.

• Receive alerts.

• Manage cards.

This Privacy Policy, in combination with other relevant privacy notices that we provide—

Example: pursuant to financial privacy laws—is to inform you of the policies and practices

regarding the collection, use and disclosure of any personal information that we and our service

providers collect from or about users in connection with the App’s website, and mobile

application (the “Services”).

 

THE TYPES OF INFORMATION WE COLLECT IN THE APP

Through your use of the Services, we may collect personal information from you in the

following ways:

(a) Personal Information You Provide to Us

• We may collect personal information from you, such as your first and last name, address,

email, telephone number, and social security number when you create an account.

• We will collect the financial and transaction information necessary to provide you with the

Services, including account numbers, payment card expiration date, payment card

identification, verification numbers, and transaction and payment history.

• If you provide feedback or contact us via email, we will collect your name and email address,

as well as any other content included in the email, in order to send you a reply.

• We also collect other types of personal information that you provide voluntarily, such as any

information requested by us if you contact us via email regarding support for the Services.

(b) Personal Information Collected from Third Parties—We may collect certain information

from identity verification services and consumer reporting agencies, including credit bureaus, in

order to provide some of our Services.

(c) Personal Information Collected Via Technology—We and our service providers may

automatically log information about you, your computer or mobile device, and your interaction

over time with our Services, our communications, and other online services, such as:

• Device data, such as your computer or mobile device’s operating system type and version,

manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage,

device type (example: phone, tablet), IP address, unique identifiers, language settings,

mobile device carrier, radio/network information (example: Wi-Fi, LTE, 3G), and general

location information such as city, state, or geographic area.

• Online activity data, such as pages or screens you viewed, how long you spent on a page or

screen, the website you visited before browsing to the Service, navigation paths between

pages or screens, information about your activity on a page or screen, access times, and

duration of access.

• Cookies, which are text files that websites store on a visitor’s device to uniquely identify the

visitor’s browser or to store information or settings in the browser for the purpose of helping

you navigate between pages efficiently, remembering your preferences, enabling

functionality, and helping us understand user activity and patterns.

• Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent

functionality but can store larger amounts of data, including on your device outside of your

browser in connection with specific applications.

• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a

webpage or email was accessed or opened, or that certain content was viewed or clicked.

• Location Information. If you have enabled location services on your phone and agree to the

collection of your location when prompted by the Services, we will collect your location

information when you use the Services; for example, to provide our fraud detection services.

If you do not want us to collect this information, you may decline the collection of your

location when prompted or adjust the location services settings on your device.

 

HOW WE USE YOUR INFORMATION COLLECTED IN THE APP

(a) General Use—In general, we use your personal information collected through your use of the

Services to respond to your requests as submitted through the Services, to provide you the

Services you request, and to help serve you better. We use your personal information, in

connection with the App, in the following ways:

• Facilitate the creation of, and secure and maintain your account;

• Identify you as a legitimate user in our system;

• Provide improved administration of the Services;

• Provide the Services you request;

• Improve the quality of experience when you interact with the Services;

• Send you administrative email notifications, such as security or support and maintenance

advisories; and

• Send surveys, offers, and other promotional materials related to the Services.

(b) Compliance and protection—We may use your personal information to:

• Comply with applicable laws, lawful requests and legal process, such as to respond to

subpoenas or requests from government authorities;

• Protect our, your or others’ rights, privacy, safety or property (including by making and

defending legal claims);

• Audit our internal processes for compliance with legal and contractual requirements and

internal policies;

• Enforce the terms and conditions that govern the Service; and

• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical, or illegal

activity, including cyberattacks and identity theft.

(c) Creation of Non-Identifiable Data—The App may create de-identified information records

from personal information by excluding certain information (such as your name) that makes the

information personally identifiable to you. We may use this information in a form that does not

personally identify you to analyze request patterns and usage patterns to enhance our products

and services. We reserve the right to use and disclose non-identifiable information to third

parties in our discretion.

 

DISCLOSURE OF YOUR PERSONAL INFORMATION

We disclose your personal information collected through your use of the Services as

described below.

(a) In Accordance with Our Other Privacy Notices—Other than as described in this Privacy

Policy in connection with the App, this Privacy Policy does not apply to the processing of your

information by us or third parties with whom we share information.

(b) Third Party Service Providers—We may share your personal information with third party or

affiliated service providers that perform services for or on behalf of us in providing the App, for

the purposes described in this Privacy Policy, including: to provide you with the Services; to

conduct quality assurance testing; to facilitate the creation of accounts; to optimize the

performance of the Services; to provide technical support; and/or to provide other services to

the App.

(c) Authorities and Others—Regardless of any choices you make regarding your personal

information, The App may disclose your personal information to law enforcement, government

authorities, and private parties, for the compliance and protection services described above.

 

LINKS TO OTHER SITES

The App may contain links to third party websites. When you click on a link to any other website

or location, you will leave the App and go to another site, and another entity may collect personal

and/or anonymous information from you. The App’s provision of a link to any other website or

location is for your convenience and does not signify our endorsement of such other website or

location or its contents. We have no control over, do not review, and cannot be responsible for,

these outside websites or their content. Please be aware that the terms of this Privacy Policy do

not apply to these outside websites. We encourage you to read the privacy policy of every

website you visit.

 

YOUR CHOICES REGARDING YOUR INFORMATION

You have several choices regarding use of information on the Services.

(a) How We Respond to Do Not Track Signals—Some web browsers transmit “do not track”

signals to the websites and other online services with which your web browser communicates.

There is currently no standard that governs what, if anything, websites should do when they

receive these signals. We currently do not take action in response to these signals. If and when a

standard is established, we may revise its policy on responding to these signals.

(b) Access, Update, or Correct Your Information—You can access, update, or correct your

information by changing preferences in your account. For additional requests, please contact us.

(c) Opting Out of Email or SMS Communications—If you have signed-up to receive our email

marketing communications, you can unsubscribe any time by clicking the "unsubscribe" link

included at the bottom of the email or other electronic communication. Alternatively, you can opt

out of receiving marketing communications by contacting us at the contact information under

"Contact Us" below. If you provide your phone number through the Services, we may send you

notifications by SMS, such as provide a fraud alert. You may opt out of SMS communications by

unlinking your mobile phone number through the Services.

(d) Opting Out of Location Tracking—If you initially consented to the collection of geo-location

information through the Services, you can subsequently stop the collection of this information at

any time by changing the preferences on your mobile device. Please note, if you withdraw

consent to our collection of location information, you may no longer be able to use some features

of the App.

 

SAFEGUARDS AND RETENTION

We implement reasonable administrative, technical, and physical measures in an effort to

safeguard the information in our custody and control against theft, loss and unauthorized access,

use, modification, and disclosure. Nevertheless, transmission via the internet is not completely

secure and we cannot guarantee the security of your information.

 

A NOTE ABOUT CHILDREN

The Services are not directed towards individuals under the age of 18, and we do not, through

the App, intentionally gather personal information about visitors who are under the age of 18. If a

child under 18 submits personal information to us through the App and we learn that the

personal information is the information of a child under 18, we will attempt to delete the

information as soon as possible.

 

PRIVACY POLICY UPDATES

This Privacy Policy is subject to occasional revision. We will notify you of any material changes in

its collection, use, or disclosure of your personal information by posting a notice on the Services.

Any material changes to this Privacy Policy will be effective thirty (30) calendar days following

notice of the changes on the Services. These changes will be effective immediately for new

users of the Services. If you object to any such changes, you must notify us prior to the effective

date of such changes that you wish to deactivate your account. Continued use of the Services

following notice of any such changes shall indicate your acknowledgement of such changes.

 

CONTACT US

If you have any questions or complaints about this Privacy Policy or The App’s data collection or

processing practices, or if you want to report any security violations to The App, please contact

The App by email at: This email address is being protected from spambots. You need JavaScript enabled to view it.; or by mail at:

 

Northwoods Bank of Minnesota

P O Box 112

Park Rapids, MN 56470