EVOLVE BANK & TRUST PRIVACY POLICY

Legal Rights & Agreement Rules · Context

Evolve Bank & Trust privacy policy, last revised March 29, 2023

The document is the Evolve Bank & Trust Privacy Policy. Its stated last revision date is March 29, 2023; the saved text does not state a separate effective date.

Supporting quotations

Evolve Bank & Trust Privacy Policy

Last Revised on March 29, 2023

Qualifications & exceptions

• The date is the 'Last Revised' date shown in the saved text; no separate effective date is stated.

Not stated here

• Whether a later version exists is not established by this saved copy.

Legal Rights & Agreement Rules · Restriction or exception

Consumer financial-product applicants are outside this policy and referred to a GLBA policy

The policy expressly does not apply to information collected about individuals who apply for or obtain financial products or services for personal, family or household purposes. For those customers, Evolve points to a separate Gramm-Leach-Bliley Act Privacy Policy, linked but not included in the saved text.

Supporting quotations

This Privacy Policy does not apply to information we collect about individuals who apply for or obtain financial products and services for personal, family or household purposes.

please refer to our separate Gramm-Leach-Bliley Act Privacy Policy

Qualifications & exceptions

• The exclusion is limited to personal, family or household financial products or services.
• The referenced GLBA policy's terms are not supplied and are not described in this document.

Not stated here

• Contents of the linked GLBA policy.

Cross-references

• qualifies (model-proposed): California section applies only to California residents and includes sensitive personal information — The general policy excludes consumer financial-product applicants and points to a separate GLBA policy. The California section likewise says FCRA- and GLBA-regulated data is exempt from CCPA requirements and rights and points to the same separate policy. Both statements describe the same boundary for those customers; the linked GLBA policy is not in the saved source.

Legal Rights & Agreement Rules · Restriction or exception

Using the Services is stated as agreement to the policy

The policy states that by using the Services, a user agrees to the policy and its terms, and that a user who does not agree should not use or access the Services. The saved text does not describe a separate acceptance step.

Supporting quotations

By using the Services, you agree to this Privacy Policy and its terms.

If you do not agree to this Privacy Policy, please do not use or access any of the Services.

Qualifications & exceptions

• The statement is conditioned on using the Services.
• No signature, checkbox or other acceptance method is described here.

Not stated here

• How agreement is presented in the product interface is not shown in the saved text.

Legal Rights & Agreement Rules · Company practice

Policy may change by updating the Last Revised date, with notice efforts for material-use changes

Evolve may modify the policy and will update the 'Last Revised' date. If it makes material changes to the way it uses collected information, it says it will use commercially reasonable efforts to notify users and take additional steps required by applicable law. Users who do not agree to updates are told not to use or access the Services.

Supporting quotations

We may modify this Privacy Policy, in which case we will update the “Last Revised” date.

If we make material changes to the way we use information we collect, we will use commercially reasonable efforts to notify you and will take additional steps as required by applicable law.

Qualifications & exceptions

• The notice commitment is limited to material changes in how collected information is used and to commercially reasonable efforts.
• Additional steps depend on applicable law.

Not stated here

• The notice channel and timing are not specified.

Legal Rights & Agreement Rules · Restriction or exception

Evolve disclaims responsibility for third-party data accuracy and third-party policies

For information received from outside sources, Evolve says it is not responsible or liable for the accuracy of information provided by third parties and is not responsible for any third party's policies or practices. The policy points to 'Section 5 below' for more information.

Supporting quotations

We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices.

See Section 5 below for more information.

Qualifications & exceptions

• The disclaimer concerns information supplied by third parties and third-party policies, not Evolve's own practices.
• The reference is not numbered in the saved text; a reference record gives the exact citation and target.

Not stated here

• The content of any third-party policy is not supplied.

Legal Rights & Agreement Rules · Restriction or exception

Third-party links are not endorsed and their privacy practices are outside Evolve's responsibility

Evolve may provide links to third-party websites or platforms. It tells users who follow links to unaffiliated sites to review those sites' policies and terms, says it is not responsible for the privacy, security or information found on those sites, and says inclusion of a link does not by itself imply endorsement. Information provided on public or semi-public venues may be viewable by others without limitation as to its use.

Supporting quotations

If you follow links to sites not affiliated with us, you should review their policies and other terms.

We are not responsible for the privacy, security, or information found on these sites.

Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators.

Qualifications & exceptions

• The disclaimer covers sites not affiliated with Evolve.
• The policy does not describe any review of third-party practices.

Not stated here

• The linked sites' policies are not supplied.

Legal Rights & Agreement Rules · Restriction or exception

California section applies only to California residents and includes sensitive personal information

The California residents section applies only to California residents. For that section, 'personal information' includes 'sensitive personal information' as defined under the CCPA. Evolve notes that some data described is exempt from CCPA requirements and rights, such as data regulated by the Fair Credit Reporting Act and the Gramm-Leach-Bliley Act, and points to its separate GLBA privacy policy.

Supporting quotations

This section applies to you only if you are a California resident

references to “personal information” shall include “sensitive personal information,” as these terms are defined under the California Consumer Privacy Act (“CCPA”).

certain of the data we describe below is exempt from the requirements of the CCPA and the rights that you have under the CCPA, such as data regulated by the Fair Credit Reporting Act and the Gramm Leach Bliley Act.

This Privacy Policy does not apply to information we collect about individuals who apply for or obtain financial products and services for personal, family or household purposes.

Qualifications & exceptions

• The section is geographically limited to California residents.
• The exemptions are examples ('such as') and include FCRA- and GLBA-regulated data.
• The separate GLBA policy is linked but not supplied.

Not stated here

• The full set of exempt data is not enumerated.

Cross-references

• qualified by (model-proposed): Consumer financial-product applicants are outside this policy and referred to a GLBA policy — The general policy excludes consumer financial-product applicants and points to a separate GLBA policy. The California section likewise says FCRA- and GLBA-regulated data is exempt from CCPA requirements and rights and points to the same separate policy. Both statements describe the same boundary for those customers; the linked GLBA policy is not in the saved source.

Legal Rights & Agreement Rules · User right or choice

California residents may have the listed privacy rights, subject to legal limits

The 'Your California Privacy Rights' section says a California resident may have the rights listed below in relation to personal information collected about them. It states that the rights are not absolute and that in some cases Evolve may decline a request as permitted by law.

Supporting quotations

Your California Privacy Rights

As a California resident, you may have the rights listed below in relation to personal information that we have collected about you.

However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

This section applies to you only if you are a California resident

references to “personal information” shall include “sensitive personal information,” as these terms are defined under the California Consumer Privacy Act (“CCPA”).

Qualifications & exceptions

• The section applies to California residents.
• 'Personal information' for the section includes sensitive personal information as defined under the CCPA.
• The rights are expressly not absolute; refusal is permitted as allowed by law.

Not stated here

• The policy does not enumerate every refusal ground.

Legal Rights & Agreement Rules · User right or choice

Right to Know covers categories, sources, purposes, recipient categories and specific pieces

The policy states a right to request information about the collection, use and disclosure of personal information: the categories collected and disclosed for a business purpose; the categories of sources; the business or commercial purposes for collection; the categories of third parties to whom information was disclosed for a business purpose; and specific pieces of personal information collected.

Supporting quotations

Right to Know. You have a right to request the following information about our collection, use and disclosure of your personal information:

categories of personal information we have collected, disclosed for a business purpose;

categories of sources from which we collected personal information;

the business or commercial purposes for collecting personal information;

categories of third parties to whom the personal information was disclosed for a business purpose; and

specific pieces of personal information we have collected.

Qualifications & exceptions

• This is a right to request the listed information; the policy does not say the information is provided automatically.
• The rights intro states that requests may be declined as permitted by law.

Not stated here

• The response format and timing are not stated.

Legal Rights & Agreement Rules · User right or choice

Right to Delete covers personal information the company maintains

The policy states a right to request deletion of personal information Evolve maintains about the resident. The rights intro states that the rights are not absolute and requests may be declined as permitted by law.

Supporting quotations

Right to Delete.You have a right to request that we delete personal information we maintain about you.

However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

Qualifications & exceptions

• The right is framed as a request, not an automatic deletion.
• The section states that the rights are not absolute.

Not stated here

• The policy does not list exceptions to deletion in this item.

Legal Rights & Agreement Rules · User right or choice

Right to Correct covers inaccurate personal information the company maintains

The policy states a right to request correction of inaccurate personal information Evolve maintains about the resident, subject to the section's statement that the rights are not absolute.

Supporting quotations

Right to Correct.You have a right to request that we correct inaccurate personal information we maintain about you.

However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

Qualifications & exceptions

• The right is framed as a request.
• The section states that the rights are not absolute.

Not stated here

• The policy does not describe the correction process or evidence required.

Legal Rights & Agreement Rules · Procedure

No discrimination for exercising rights; identity and authorized-agent verification required

Evolve says it will not discriminate against a resident for exercising the listed rights. It may need information such as email address, government-issued ID or date of birth to verify identity before a substantive response. A resident may designate an authorized agent in writing or by power of attorney; Evolve requires proof of authorization and may also require the resident to verify identity directly.

Supporting quotations

We will not discriminate against you for exercising any of these rights.

We may need to collect information from you to verify your identity, such as your email address, government issued ID or date of birth, before providing a substantive response to the request.

You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights.

Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

Qualifications & exceptions

• Verification is described as something Evolve 'may need' before a substantive response.
• Agent requests require proof of authorization and may require direct verification by the resident.

Not stated here

• The policy does not state how much information is required in each case or the response timeline.

Legal Rights & Agreement Rules · User right or choice

California residents may request Shine the Light details about direct-marketing sharing, once a year

The policy says California law permits residents to request certain details about how their personal information, as defined in California Civil Code Section 1798.83, is shared with third parties for the third parties' direct marketing. Evolve may from time to time elect to share personal information for those purposes. Residents may, under certain circumstances, obtain the categories shared and the names and addresses of all third parties that received information for direct marketing in the prior calendar year. Evolve says it is only required to respond to one request per resident each year.

Supporting quotations

California law permits residents to request certain details about how their “personal information” (as defined in California Civil Code Section 1798.83) is shared with third parties for their direct marketing purposes.

We may from time to time elect to share certain personal information about you with third parties for those third parties’ direct marketing purposes.

Residents may, under certain circumstances, obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year.

Please note that we are only required to respond to one request per resident each year.

Qualifications & exceptions

• The request right is described as available 'under certain circumstances'.
• The response covers the immediately prior calendar year.
• The policy limits responses to one request per resident each year.

Not stated here

• The policy does not state a separate request channel apart from the general contact information.

Legal Rights & Agreement Rules · Procedure

CCPA rights and privacy questions use the contact form or 866.395.2754

To exercise CCPA rights or ask questions about privacy practices or the policy, Evolve directs users to its contact form or the phone number 866.395.2754.

Supporting quotations

To exercise your CCPA rights or should you have any questions about our privacy practices or this Privacy Policy, please use the following contact formor contact us at 866.395.2754.

Qualifications & exceptions

• The item gives a contact form link and a phone number.
• It does not state response times or a mailing address.

Not stated here

• No separate privacy email or postal address is given.