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A current copy of our Online Privacy Policy (pdf).
Flagstar Savings, National Association and Flagstar Savings Insurance Agencies, Inc. (“Flagstar Savings”) is committed to the privacy of your information. This Online Privacy Policy (“Privacy Policy”) is meant to help you understand the information we collect, why we collect it, and how you can manage it. This Privacy Policy applies to our website at www.CapitalGuardiansBank.com (the “Site”) and all related Flagstar Savings-branded products, services, communications, mobile services, mobile applications, and other applications (the “Services”), and is intended for a U.S. audience only. By using our Site, or by using our Services, you are acknowledging that you have read, understood, and accept this Privacy Policy.
In this Privacy Policy, any use of the words "you," "yours," or similar expressions refers to users of this Site and our Services, as well as any other individuals whose information we collect and process. References to "we," "us,” "our" or similar expressions refer to Flagstar Savings.
This Privacy Policy does not extend to anyone whose personal information is not under our control or management, including data that is collected by other websites that you may visit before or after this Site, and which are not governed by this Privacy Policy. We are not responsible for the data protection or privacy policies of any other websites and accept no responsibility or liability for those policies. Please carefully check the policies of other websites and services you use before you visit or submit personal information.
1. Information we collect
1.1 INFORMATION WE COLLECT AND RECEIVE
In order for you to use our Site and Services, we need to collect and process certain types of information. Depending on your use of our Site and Services, Flagstar Savings may have collected the following categories of personal information in the last 12 months. We may have also collected personal information from the individuals at businesses with whom we interact in the business to business context. This may include:
Personal Identifiers you provide to us by contacting us or that others provide to us, including, without limitation: any personal information you may provide to us when you email, fax, mail, or call us, such as name, phone number, employer, and any other details you provide in your communications. Flagstar Savings may also request your contact information for the purposes of having someone contact you for additional information, or in response to your request for information from us;
Information you provide to us by completing forms on our Site or mobile application, for example, this may include your name, telephone number and address information, and any other information you may provide in the forms on our Site;
Information you grant access to on your mobile device through our mobile application, such as your contacts or camera;
Characteristics of protected classifications under state or Federal law, such as your race, ethnicity, sex, marital status, veteran or military status;
Purchase information, such as products and services you have obtained and transaction histories;
Audio, electronic, and visual information such as call recordings and video recordings;
Professional or employment related information, such as current and past job history;
Education information, such as degrees or certifications;
Geolocation information, such as the location of you or your device;
Sensitive information you provide us. For example, if you enroll in Online Banking, we may collect the information you provide to us throughout the process such as your Social Security number, driver’s license, state identification card, or passport number, or your financial account, debit card, or credit card number in combination with any required security codes or password;
Internet or other electronic network activity information, which includes information about the ways people visit and interact with our Site, such as traffic analytics, and other statistics;
Information about your activity through our Services, including your device information (such as your IP address, the type of device or browser you use, and your actions on the Site); and
Inferences we draw based on any of the information listed above to create a profile about you reflecting preferences, characteristics, attitudes or similar trends.
We will only use personal information to provide you with information, products, or services you have requested, or for other purposes set out in this Privacy Policy. We may use aggregate information from which individual identities have been removed for other purposes.
1.2 INFORMATION FROM CHILDREN
Flagstar Savings does not knowingly solicit or collect any personal information from anyone under 13 years of age, and children under 13 are not permitted to register for or use our Site or Services, including by subscribing to receive information from Flagstar Savings. Parents can contact customer support to access, change, or delete the personal information that has been submitted by a child. If we become aware that a child under the age of 13 has provided us with personal information, we will delete it. We have no actual knowledge of ever selling personal information of consumers under 16 years of age.
1.3 COOKIES AND TRACKERS
We use cookies and other tracking technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off, and across the Site and different Services and devices. You may be able to control certain cookies through your browser settings and other tools. Our Site does not respond to Do Not Track signals.
Third parties may also use cookies and other tracking technologies to assist us with our Site and Services. For example, Google may place cookies for analytics and marketing purposes. You can opt-out of Google tracking through Google Ads Settings, Ad Settings for mobile apps, or any other mechanisms Googles makes available, such as the Google Analytics opt-out plug-in for the web. For more information about how you may be able to opt-out of certain online behavioral advertising, please visit http://www.aboutads.info/choices/, https://www.networkadvertising.org/, or http://www.youronlinechoices.com.
2. How we use information
Flagstar Savings may use the personal information we collect for the following business purposes:
To provide and manage products and services, including maintaining or servicing accounts; providing customer service, processing, or fulfilling orders and transactions; verifying your information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services;
To alert you about product updates, special offers, updated information and other news and services from Flagstar Savings;
For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us;
To market, personalize, develop, and improve our products and services;
To ensure our Site and Services are relevant to you and your interests;
To help us create and publish content most relevant to you;
To contact you in response to sign up forms, requests, or surveys;
To audit related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
To help ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes;
For debugging to identify and repair errors that impair existing intended functionality of our Site and applications;
To undertake internal research for technological development and demonstration;
To undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us;
To manage any other business relationships we may have with you or your company;
To engage in any other activities reasonably anticipated within the context of our ongoing business relationship with you, or otherwise to perform any contract between Flagstar Savings and you; or
For any other purpose not otherwise prohibited by applicable law.
3. How information may be disclosed
Flagstar Savings does not sell, share, or rent any of your personal information, and we do not disclose your personal information publicly without your consent. However, we may disclose your information with certain trusted third-party service providers to help us provide, improve, promote, or protect our products and Services. For example, we may partner with other companies to store your data to support delivery of our Services. Whenever we disclose data with third-party service providers, we require that they use your information only for the purposes we’ve authorized, and that they protect your personal information at least to the same standards we do.
We also reserve the right to disclose personal information when it is reasonably necessary to conduct our business; protect Flagstar Savings’s legal rights and property or as part of a merger, acquisition, bankruptcy, or other transaction; to comply with the law or law enforcement; or carry out any of the uses described above in this Privacy Policy. Otherwise, your personal information is not disclosed to any individual or other organization.
4. Protection of your personal information
We follow industry-standard practices to protect the data we collect and process. Flagstar Savings has therefore put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the personal information that Flagstar Savings collects. Access to personal information will be restricted to our authorized personnel who require the information in order to perform their duties properly. In addition, access will be limited to only that information that is strictly necessary for the performance of those duties.
Remember, the safety and security of your information also depends on you. Where you have chosen, or where we have given you a username and password for access to certain parts of the Site or Services, you are responsible for keeping the username and password confidential. No method of transmission over the internet or electronic storage is completely secure, so Flagstar Savings cannot guarantee its absolute security.
5. Email notifications
We give you the ability to opt out of any marketing e-mail communications we send. For example, we may send you email relating to the Services we offer. You may also elect to receive certain marketing email communications, in accordance with your preferences, and from which you may opt out at any time. You can always opt out of receiving email information or mobile device notifications from Flagstar Savings (other than certain transactional or required communications), by sending us an email at info@capital-guardians.com or calling us at 800-908-2265 stating your request. If we have sent you a promotional email or mobile device notification, you may send us a return email or mobile device communication asking to be omitted from future email or mobile device distributions.
6. California residents only
The following sections apply to those California residents who are considered consumers under the California Consumer Privacy Act; CA CIVIL § 1798.100, et seq., as amended from time to time and its implementing regulations (the “CCPA”). Certain exemptions apply to your rights and Flagstar Savings’s obligations pursuant to the CCPA. These rights may not apply in certain situations depending on your relationship with Bremer and Flagstar Savings’s other legal obligations and as otherwise provided for in the CCPA.
This Privacy Policy does not address personal information collected for employment related inquiries or transactions. For additional details about the use of personal information for employment matters, please refer to the Flagstar Savings HR Notice at Collection and Privacy Policy.
Under the CCPA, personal information is defined as information that identifies, relates to, or could reasonably be linked with a particular California resident or household (“Personal Information”). Any other terms defined in the CCPA have the same meaning when used in this Privacy Policy. To understand our collection, use, and disclosure practices with respect to Personal Information, please refer to the chart below.
Category of Personal Information Collected
Collection Sources
Business Purpose for Collection
Categories of Third Parties with Whom Personal Information is Disclosed
Personal Identifiers
Directly from you
Individuals authorized to act on your behalf
Our affiliates
Service providers
Government agencies and other publicly available sources
Operating systems and platforms
Data analytics providers
To open, maintain and service accounts, provide customer service, process or fulfill orders and transactions, verify customer information, process payments, provide financing, provide analytic services, or similar services.
Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions and auditing compliance
Helping to ensure security and integrity of Personal Information
Debugging to identify and repair errors that impair intended functionality
Short-term transient use meeting the conditions of the CCPA
Providing advertising and marketing services not including cross-context behavioral advertising
Undertaking internal research for technological development and demonstration
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
Comply with legal and regulatory obligations
Detect, investigate and prevent activities that may violate our policies or be illegal
Enforce our terms and conditions and otherwise protect our rights and operations
Government agencies
Third parties to whom you authorize us, directly or indirectly, to disclose your Personal Information
Data analytics Providers
Contact details such as telephone number and address, financial information such as account number and balance, credit and debit card numbers
Helping to ensure security and integrity
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
Characteristics of protected classification under California or Federal law
Commercial information such as products or services purchased, obtained, or considered
Internet or other electronic network activity information
Geolocation
Audio, electronic, visual, or similar information
Professional or employment-related information
Education information
Short term transient use meeting the conditions of the CCPA
Inferences drawn to create a profile about a consumer
Service Providers
Data Analytics Providers
Our affiliate
Sensitive personal information
To perform services, including maintaining or servicing accounts, customer service, processing orders and transactions, verifying customer information, processing payments, providing financing, analytic service, storage or similar services;
To provide requested goods and services
Help to ensure security and integrity
Short term, transient use meeting the conditions of the CCPA
To verify or maintain quality or safety of service or device or improve upgrade or enhance service or device
Rights and requests under the CCPA
California residents may have certain rights regarding their Personal Information. Except where an exemption applies, these rights may include 1) the ability to request a copy of the information we have collected about you during the previous 12 months, as well as the right to review our data collection practices related to you; 2) the ability to request deletion of your Personal Information that we have collected from you; 3) the ability to correct your inaccurate Personal Information maintained by us; 4) the ability to opt out of our selling or sharing of your Personal Information; 5) the ability to limit the use and disclosure of sensitive Personal Information; and 6) the right not to be discriminated or retailiated against due to your exercise of any of the preceding rights. While these rights are not globally applicable, our customers and other individuals with whom we interact are entitled to submit requests.
How to submit requests
You may call us at 800-908-2265 or email us at info@capital-guardians.com to exercise any of these rights. To protect your privacy and security, Flagstar Savings may take reasonable steps to verify your identity before granting access to, correcting, or deleting data. As part of our verification procedures, we may request that you provide the following information to identify yourself: name, contact information, Social Security or individual taxpayer identification number, date of birth, cell phone number, email, user ID, business ID, password, account number, government issued ID, such as driver’s license, state ID, passport or matricula card, and/or answers to security questions that we have on file. We will attempt to match information that you provide in making your request with other sources of similar information to reasonably verify identity. In addition, for certain requests, we may require an extra layer of verification such as requiring you to sign a declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request.
Requests by authorized agents
A California resident who is considered a consumer under the CCPA may designate an authorized agent to make a request on behalf of the California resident by contacting us at the toll-free number or email address listed above. If you designate an authorized agent to make an access, correction, or deletion request on your behalf, we may require you to provide the authorized agent written permission to do so and require you to verify your own identity directly with us (as described above).
As part of our verification process, we may request that the authorized agent provide:
The authorized agent’s name; contact information; Social Security or individual taxpayer identification number; date of birth; and government issued ID, such as driver's license, State ID, passport, or Matricula Card.
The name; contact information; Social Security or individual taxpayer identification number; date of birth; and the government issued ID of the California resident on whose behalf the request is being made.
A document to confirm that the authorized agent is authorized to make the request such as a copy of a power of attorney, legal guardianship or conservatorship order, or a birth certificate of a minor if the requestor is the custodial parent.
For an authorized agent of a company or organization ("legal entity agent") making a request on behalf of a California resident:
The legal entity agents’ active registration with the California Secretary of State.
Proof that the California resident has authorized the legal entity agent to make the request.
The name; contact information; Social Security or individual taxpayer identification number; data of birth; and government issued ID of the California resident on whose behalf the request is being made.
From the individual who is acting on behalf of the legal entity requestor, proof that the individual is authorized by the legal entity requestor to make the request.
Our response to requests
We will generally respond to your request(s) within 45 days, unless, for reasons beyond our control, a longer response time is necessary, in which case, you will be advised accordingly. Please note that we may retain certain information about such requests as required by law or as necessary for our legitimate business purposes.
7. Questions, comments or complaints
If you have questions or comments about this Privacy Policy, or if you are not completely satisfied with this Privacy Policy, its application by us, or any of our determinations in response to your request(s), we invite you to convey your concerns or suggestions to us at info@capital-guardians.com or 800-908-2265. We will reply as quickly as possible and inform you of the steps, if any, that have been or will be taken in order to address your concern or implement the suggestion.
8. Updates and changes to this Privacy Policy
This Privacy Policy was last updated and is effective as of April 26, 2023. We may change this Privacy Policy from time to time, and the most current version will be available on our Site. You understand that by continuing to use our Site or Services after the effective date of any change, you have agreed to the most recent version of this Privacy Policy.