Privacy Policy

Effective 2/27/2024

This Online Privacy Statement (“Statement”) describes the treatment of information that is provided or collected through any of Union Bank & Trust Company’s (“Union Bank”, “our”, “we”) online interfaces to which a copy of the Statement is posted. This Statement includes all “Services” which inclusively refers to www.BrightDirections.com (the “Website”), Applications we have placed on third party sites such as Facebook®, Twitter® and other social media sites, and our mobile applications (“Applications”). This Statement also explains how we collect, use, and share information based on users’ interactions with online advertisements, both on the Services and on online interfaces owned by third parties. This Statement does not govern our privacy practices offline or with respect to information that is not provided or collected through the Services.

For information on Union Bank’s offline privacy practices see our Financial Privacy Notice and your choice for opting-out of information sharing with our affiliates.

While this Statement describes how we treat information, please be aware additional terms and conditions may apply for certain parts of our Website and Applications.

Agreement to Statement

By using the Services you consent to this Statement. You do have the choice to opt-out of certain tracking, please see “Online Tracking and Advertising” section below.

Types of Information We Collect through online Services

We collect two basic types of information through the Services – personal information and anonymous information.

“Personal information” refers to information that identifies a particular individual, such as information you provide on our forms, surveys, applications or similar online fields. Examples include your name, address, telephone number, tax identification number, or account information.

“Anonymous information” means information that does not directly or indirectly identify a particular individual. Examples may include information about your Internet browser, information collected through tracking technologies, demographic information that you provide to us.

“Location information” means information that may be collected by certain mobile applications that identifies your physical location. This information may be collected from your mobile device’s location-aware features when you request certain services that are dependent on your physical location.

How We Collect Your Information

We collect personal information from you when you provide this information to us directly. For example, when you apply for accounts through our Services, or register for an Application.

In addition, we may collect information about your activity on the Services automatically using tracking technologies, such as cookies. For additional information, see the section entitles “Online Tracking and Advertising”.

How We Use Your Information

We may use information collected through the Services in order to, among other things:

• Provide you with, or evaluate your eligibility for, products and services that you request from us
• Communicate with you about your accounts or transactions with us
• Send you important information regarding the Services
• Allow you to participate in surveys, sweepstakes, contests and similar promotions, and to administer such promotions (note that these promotions may contain additional disclosures regarding our collection and/or use of your information)
• Consistent with local law, required disclosures, and choices and controls that may be available to you:
  • Send you offers and promotions for our products and services, or products and services that may be of interest to you;
  • Personalize content and experiences on the Services;
  • Verify your identity and/or location (or the identity or location of your authorized representative) for security, fraud prevention and other risk control purposes; and
  • Provide you with advertising based on your activity on the Services and on third-party websites and applications.
  • Optimize or improve our products and services
  • Detect, investigate and prevent activities that may violate our policies or be illegal
  • Comply with our legal and regulatory obligations

How We Share Your Information

Please refer to Union Bank’s Privacy Notice.

Online Tracking and Advertising

We, along with certain service providers operating on our behalf, may collect information about your activity on the Services using tracking technologies, including:

• Cookies. Cookies are pieces of data stored on your device. Browser cookies are assigned by a web server to the browser on your device. When you return to a site you have visited before, your browser gives this data back to the server. We use cookies that allow us to see information on user website activities including, but not limited to page views, source and time spent on website. The information is depersonalized and is displayed as numbers, meaning it cannot be tracked back to individuals. Using Google Analytics we can see what content is popular on our Website, and strive to give you more relevant information.

  We may use cookies to personalize your experience and provide social media features. We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services.

• Google AdWords. Our Website uses the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site. It could mean that we advertise to previous visitors who haven’t completed a task on our site. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to the Union Bank Website. Any data collected will be used in accordance with this Statement, our own privacy policy (www.ubt.com/privacy) and Google’s privacy policy. We restrict access and collection of information by advertising service providers for purposes other than assisting us with our advertising efforts.

  You can set preferences for how Google advertises to you using the Google Ad Preferences page (https://support.google.com/ads/answer/2662922?hl=en), and if you want to you can opt out of interest-based advertising entirely by adjusting your browser’s cookie settings or permanently using a browser plugin.

• Google Signals. This website uses Google Signals, a feature of Google Analytics that allows us to collect and use certain information from your browsing activity across other websites and apps that also use Google Signals. This information includes things like the pages you visit, the products you view, and the ads you click on. We use this information to improve our website and to provide you with more relevant advertising. You can opt out of Google Signals by visiting the Google Analytics opt-out page.

Linked Websites

The Services may contain links to third-party websites not controlled by Union Bank. We encourage you to be aware when you leave the Services and to read the privacy policies and terms of use of any such websites that may collect your personal information.

Information Security and Preventing Identity Theft

Your privacy is important to Union Bank. We have implemented physical, technical and administrative security measures that comply with federal law and industry standards, including network firewalls, Secure Sockets Layer (SSL) encryption for online sessions, dedicated security teams and secured files and buildings. You have the responsibility to help us protect your accounts by never revealing your username, password or PIN to other individuals.

Children’s Privacy

We do not knowingly collect or use personal information from children under the age of 13 through our website or online environment. We request that such individuals do not provide personal information through the Services. If a parent or guardian becomes aware that his or her child has provided us with information without parental or guardian consent, he or she should promptly contact us and we will delete such information from our files.

Social Media Platforms

Union Bank may utilize various social media platforms, including Facebook® and Twitter®. Please note any content you post to such social media platforms is subject to the applicable social medial platform’s terms of use and privacy policies, and is not in our control.

Changes to this Statement

From time to time, we may make changes to this Statement. If we do make changes, we will update the “Effective Date” posted at the top of the Statement. We encourage you to review the Statement periodically to ensure you understand how we collect, use and share information through the Services. By continuing to use the Services following any changes, you are agreeing to accept the terms of the revised Statement.

Learn more about who we are, how you can contact us and how we process personal data in our Privacy Policy.

Please state your consent ID and date when you contact us regarding your consent.

California Consumer Privacy Act Disclosure

The California Consumer Privacy Act (CCPA) addresses how personal information of California residents is collected, used and disclosed. Personal information is information that identifies, relates to, or could reasonably be linked with you or your household. California residents are provided with specific rights regarding such personal information. The CCPA does not apply to personal information already covered by certain other privacy laws, including the Fair Credit Reporting Act (FCRA) and Gramm-Leach-Bliley Act (GLBA).

Please see above for the types of information we collect, how we collect the information and how we use the information. We do not sell customer personal information. Please refer to Union Bank’s Privacy Notice for further detail on how we share your information. The CCPA gives California residents the following rights as to their personal information:

• Right to know what personal information was collected over the prior twelve (12) month period;
• Right to request we delete any of your personal information that we have collected and retained (unless the CCPA recognizes an exception); and
• Right to be free from discrimination for exercising your rights under the CCPA.

If you are a California resident and would like to exercise any of your above rights, please submit your request to:

Your consent applies to the following domains: www.BrightDirections.com