This is the January 26, 2026 revision of Lead Bank's privacy policy. The policy describes the types of personal information Lead Bank collects through its websites and services, explains why it collects the information, and explains how it uses it.
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Rev. January 26, 2026
The following privacy policy outlines the types of personal information that Lead Bank (“Lead Bank”) collects through our websites and services. It also explains why we collect your information and how we use it.
Data Access & Collection · Company practice
Categories of information collected and shared
The types of personal information Lead Bank collects and shares depend on the product or service a customer has. The notice gives these examples: Social Security number and account transactions; checking account information and credit history; payment history and account balances.
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The types of personal information we collect and share depend on the product or service you have with us. This information can include:
Social Security number and account transactions
Checking account information and credit history
Payment history and account balances
Data Access & Collection · Company practice
How Lead Bank collects personal information
Lead Bank collects personal information, for example, when you apply for a loan or open an account, show a government-issued ID or use a credit or debit card, or provide employment information. It also collects personal information from others, such as credit bureaus, affiliates, or other companies.
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How does Lead Bank collect my personal information?
We collect your personal information, for example, when you
Apply for a loan or open an account
Show your government-issued ID or use your credit or debit card
Provide employment information
We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
Data Access & Collection · Company practice
California categories collected and disclosed: identifiers, customer records, protected classifications
For the last 12 months, Lead Bank says it collected the categories of personal information listed in its California table and disclosed them to the listed recipients. The table's first categories are: identifiers (name, address, email address, phone number, account identifiers, online identifiers, IP address, Social Security number, or similar identifiers); California customer records or similar information in states with applicable privacy laws (name, signature, Social Security number, address, telephone number, driver's license or state identification card number, employment, employment history, bank account number, and other financial information; this category may overlap with others); and characteristics of protected classifications under state or federal law (age, marital status, or gender). For each of these categories, the listed recipients are Lead Bank's affiliates, service providers, and third parties the consumer or their agents authorize Lead Bank to disclose the information to in connection with products or services Lead Bank provides.
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During the last twelve (12) months, we have collected personal information in the following categories from consumers and disclosed personal information with the following categories of recipients. Although the list contains examples of information collected, we do not collect every specific piece of personal information for every consumer:
Category of Personal Information Examples of Personal Information Collected Categories of Recipients
Identifiers Name, address, email address, phone number, account identifiers, online identifiers, IP address, Social Security number, or other similar identifiers. Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
California customer records or similar information in states with applicable privacy laws Name, signature, Social Security number, address, telephone number, driver’s license or state identification card number, employment, employment history, bank account number, and other financial information. This category may overlap with other categories. Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
Characteristics of protected classifications under state or federal law Age, marital status, or gender. Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
Qualifications & exceptions
The table states that it contains examples and that Lead Bank does not collect every specific piece of personal information for every consumer.
Data Access & Collection · Company practice
California categories collected and disclosed: commercial through sensitive information
Lead Bank's California table also lists these categories of personal information and the same categories of recipients: commercial information (purchasing or consuming histories or tendencies); internet or other similar network activity (information on a consumer's interaction with the website, applications, or advertisements); professional or employment-related information (current occupation); inferences (inferences drawn from the information listed above to create a profile about the consumer reflecting preferences, characteristics, behavior, and attitudes); and sensitive personal information (government-issued identifiers such as Social Security number and driver's license; financial account numbers in combination with login credentials; and facial images used for identification). For each of these categories, the listed recipients are Lead Bank's affiliates, service providers, and third parties the consumer or their agents authorize Lead Bank to disclose the information to in connection with products or services Lead Bank provides.
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Commercial information Purchasing or consuming histories or tendencies. Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
Internet or other similar network activity Information on a consumer’s interaction with our website, applications, or advertisements. Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
Professional or employment-related information Current occupation. Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
Inferences Inferences drawn from any of the information listed above to create a profile about you, such as a profile that reflects your preferences, characteristics, behavior, and attitudes. Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
Sensitive Personal Information Government-issued identifiers (such as Social Security number and driver’s license), financial account numbers in combination with login credentials, and facial images used for identification. Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
Qualifications & exceptions
This continues the table carded in the previous packet; the table states that it contains examples and does not list every specific piece collected for every consumer.
Data Access & Collection · Company practice
Sources of personal information
In addition to the sources described above, Lead Bank collects personal information directly from its clients or their agents; indirectly from its clients or their agents in the course of the services it provides; directly and indirectly from activity on its website; from other third-party sources, including government sources; and from third parties that interact with it in connection with the services it performs.
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In addition to the sources described above, we collect personal information from the following categories of sources:
Directly from our clients or their agents,
Indirectly from our clients or their agents, in the course of the services that we provide,
Directly and indirectly from activity on our website,
Other third-party sources, including government sources, and
From third parties that interact with us in connection with the services we perform.
Data Access & Collection · Context
Mobile app section scope and supplementation
This section provides additional information about how information is collected, used, and shared when a consumer uses the Lead Bank Mobile application (the "Mobile App"). It supplements, and should be read together with, Lead Bank's main Privacy Policy and any other privacy notices Lead Bank provides to the consumer as a customer.
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This section provides additional information about how information is collected, used, and shared when you use the Lead Bank Mobile application (the “Mobile App”). It supplements, and should be read together with, Lead Bank’s main Privacy Policy and any other privacy notices we provide to you as a Lead Bank customer.
Data Access & Collection · Company practice
Information the mobile app may collect
In addition to information described elsewhere in the Privacy Policy, the Mobile App, working with the mobile-banking service provider, may collect: personal information the consumer or Lead Bank provides through the app, such as name, address, email address, user IDs, telephone number, and where necessary Social Security number, when the consumer enrolls in mobile banking or uses mobile features; financial and transaction information needed to provide mobile banking services, such as account numbers, payment card details (including expiration date and identification/verification numbers), and transaction and payment history; device images and videos when the consumer chooses features requiring access to the camera or photo library, such as remote check deposit and using QR codes or similar functionality to initiate peer-to-peer or other payments where available; and device contacts when the consumer chooses features that allow selecting recipients from the device's contacts, for example to facilitate peer-to-peer payments where enabled.
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In addition to the information described elsewhere in this Privacy Policy (for example, information you provide to open and maintain accounts and to use Lead Bank products and services), the Mobile App, working with our mobile‑banking service provider, may collect information from or about you and your device, including:
Personal information you or Lead Bank provide through the Mobile App, such as your name, address, email address, user IDs, telephone number, and, where necessary, Social Security number, when you enroll in mobile banking or use mobile features.
Financial and transaction information needed to provide mobile banking services, such as account numbers, payment card details (including expiration date and identification/verification numbers), and transaction and payment history.
Device images and videos, when you choose to use features that require access to your camera or photo library, such as:
Remote check deposit (capturing images of checks); and
Using QR codes or similar functionality to initiate peer‑to‑peer or other payments where available.
Device contacts, when you choose to use features that allow you to select recipients from your device’s contacts (for example, to facilitate peer‑to‑peer payments where such functionality is enabled).
Qualifications & exceptions
The camera/photo-library and contacts collection is tied to the consumer choosing features that require that access.
Data Access & Collection · Company practice
Device and online activity data
The Mobile App may collect device and online activity data, such as device type, operating system, browser type, IP address, mobile carrier, language and display settings, and interactions with the app, such as pages or screens viewed, access times and duration, and navigation within the app. The notice says this information may be collected using cookies and similar tools, as described in the main Privacy Policy and in Fiserv's TouchBanking Privacy Notice.
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Device and online activity data, such as information about your mobile device (for example, device type, operating system, browser type, IP address, mobile carrier, language and display settings) and your interactions with the Mobile App (for example, pages or screens viewed, access times and duration, navigation within the app). This information may be collected using technologies such as cookies and similar tools, as described in our main Privacy Policy and in Fiserv’s TouchBanking Privacy Notice.
Qualifications & exceptions
The TouchBanking Privacy Notice is linked but not supplied; its contents are not summarized here.
Data Access & Collection · Company practice
Location information and its purposes
With the consumer's permission, the Mobile App and the mobile-banking service provider may collect, access, and use information about the location of the consumer's device ("Location Information"). Location Information may be derived from GPS, Wi-Fi, cell-tower data, and/or IP address, depending on device settings. The notice says Lead Bank and the service provider may use Location Information for purposes including fraud detection and prevention (for example, comparing the device's location to an ATM, merchant, or other transaction activity to help detect and prevent card transaction fraud and deposit fraud) and providing location-based services (for example, identifying and displaying nearby Lead Bank branch and ATM locations and related mapping features, and supporting other location-based features made available in the app from time to time).
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With your permission, the Mobile App and our mobile‑banking service provider may collect, access, and use information about the location of your device (“Location Information”). Location Information may be derived from technologies such as GPS, Wi‑Fi, cell‑tower data and/or IP address, depending on your device settings. We and our mobile‑banking service provider may use Location Information for purposes that include:
Fraud detection and prevention. For example, Location Information may be used to help detect and prevent card transaction fraud and deposit fraud by comparing the location of your device to the location of an ATM, merchant, or other transaction activity.
Providing location‑based services. For example, Location Information may be used to:
Identify and display nearby Lead Bank branch and ATM locations and related mapping features; and
Support other location‑based features that may be made available within the Mobile App from time to time.
Qualifications & exceptions
Collection, access, and use are conditioned on the consumer's permission.
Cross-references
qualified by (model-proposed): Location services are optional; declining may limit features — The ability to decline location access or turn off location services, and the possible loss of some features, qualifies the mobile app's collection and use of Location Information.
Data Access & Collection · User right or choice
Right to know, access, and data portability
Under certain State Privacy Laws, a consumer has the right to request disclosure of certain information about Lead Bank's collection and use of their personal information over the past 12 months. Once Lead Bank confirms the Data Subject Request, it will disclose, upon specific request: the categories of personal information collected; the categories of sources; its business or commercial purpose for collecting, disclosing, or sharing the information; the categories of third parties with whom it discloses the information; the categories of personal information it disclosed or sold to each category of third party; and the specific pieces of personal information collected.
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Under certain State Privacy Laws, you have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we confirm your Data Subject Request, we will disclose to you, upon specific request:
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting, disclosing, or sharing that personal information.
The categories of third parties with whom we disclose that personal information.
The categories of personal information we disclosed or sold to each category of third party.
The specific pieces of personal information we collected about you.
Qualifications & exceptions
The list uses "disclosed or sold" even though the notice separately states that Lead Bank has not sold or shared personal information as defined under State Privacy Laws.
Cross-references
contrast (model-proposed): No sale, advertising technology, or targeted advertising — The notice states that Lead Bank has not "sold" or "shared" personal information as defined under State Privacy Laws, while the right-to-know list refers to categories of personal information "disclosed or sold" to each category of third party. The list does not identify any category as sold; the two passages use different framing.