CROSS RIVER BANK PRIVACY NOTICE

Legal Rights & Agreement Rules · Context

Cross River Bank privacy notice: effective 11/2018, last updated 12/2024

This is Cross River Bank's privacy notice, presented in a FACTS format under the question 'WHAT DOES CROSS RIVER BANK DO WITH YOUR PERSONAL INFORMATION?'. It gives an effective date of 11/2018 and a last update of 12/2024. The text does not say whether the 12/2024 update changed an operative term or only the notice.

Supporting quotations

Privacy Notice

Effective Date: 11/2018

Last Update: 12/2024

FACTS

WHAT DOES CROSS RIVER BANK DO WITH YOUR PERSONAL INFORMATION?

Qualifications & exceptions

• Effective Date: 11/2018; Last Update: 12/2024.
• The notice does not explain the relationship between the two dates.

Not stated here

• Whether the 12/2024 update altered the operative terms is not stated.

Legal Rights & Agreement Rules · Context

Why the notice exists: federal law requires disclosure and permits limited sharing

Under the 'Why?' row, the notice says federal law gives consumers the right to limit some but not all sharing of their personal information. It says federal law also requires financial companies to tell consumers how they collect, share and protect personal information, and it asks the reader to use the notice to understand Cross River Bank's practices.

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Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do.

Qualifications & exceptions

• The passage refers to federal law without naming a statute.

Not stated here

• The specific federal statute is not named in this passage.

Data Access & Collection · Company practice

Data collected and shared varies by product and includes identifiers and transaction records

Under the 'What?' row, Cross River Bank says the types of personal information it collects and shares depend on the product or service the customer has. Examples given are Social Security number, account balances, payment history, transaction history, account transactions and wire transfer instructions.

Supporting quotations

What?

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 balances

Payment history and Transaction history

Account transactions and Wire transfer instructions

Qualifications & exceptions

• The list is introduced by 'can include', so it is not exhaustive.
• The types depend on the product or service.

Not stated here

• The notice does not match each listed data type to a particular product or service.

Retention & Deletion · Company practice

Information sharing continues after the customer relationship ends

The notice states that when a person is no longer a Cross River Bank customer, the bank continues to share that person's information as described in the notice. No end date or retention period is given for that continued sharing.

Supporting quotations

When you are no longer our customer, we continue to share your information as described in this notice.

Qualifications & exceptions

• Continued sharing remains subject to the purposes and limits described in the notice.

Not stated here

• No retention period or deletion schedule is stated.

Sharing & Disclosure · Context

The table separates sharing reasons, actual sharing and customer limits

Under the 'How?' row, the notice says all financial companies need to share customers' personal information to run their everyday business. It explains that the table lists the reasons financial companies can share, the reasons Cross River Bank chooses to share, and whether the customer can limit each kind of sharing.

Supporting quotations

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Cross River Bank chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information

Does Cross River Bank share?

Can you limit this sharing?

Qualifications & exceptions

• Column headings are 'Reasons we can share your personal information', 'Does Cross River Bank share?' and 'Can you limit this sharing?'

Sharing & Disclosure · Company practice

Everyday business sharing: Cross River Bank shares and customers cannot limit it

For everyday business purposes, the table answers 'Yes' to whether Cross River Bank shares and 'No' to whether the customer can limit the sharing. The row gives examples: processing transactions, maintaining accounts, responding to court orders and legal investigations, and reporting to credit bureaus.

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Reasons we can share your personal information

Does Cross River Bank share?

Can you limit this sharing?

For our everyday business purposes- such as to process your transactions, maintain your accounts, respond to court orders and legal investigations, or report to credit bureaus

Yes

No

Qualifications & exceptions

• The row's examples follow 'such as' and are not exhaustive.
• The 'No' answer means this notice gives no limit for this sharing; other legal limits are not addressed here.

Sharing & Disclosure · Company practice

Cross River Bank shares for its own marketing and customers cannot limit it

The table answers 'Yes' to sharing personal information for Cross River Bank's marketing purposes, described as offering its products and services, and 'No' to whether the customer can limit that sharing.

Supporting quotations

Reasons we can share your personal information

Does Cross River Bank share?

Can you limit this sharing?

For our marketing purposes- to offer our products and services to you

Yes

No

Qualifications & exceptions

• The stated marketing purpose is limited to offering Cross River Bank's products and services to the customer.

Sharing & Disclosure · Company practice

Joint marketing sharing is marked not limitable in the general table

The table answers 'Yes' to sharing personal information for joint marketing with other financial companies and 'No' to whether the customer can limit that sharing.

Supporting quotations

Reasons we can share your personal information

Does Cross River Bank share?

Can you limit this sharing?

For joint marketing with other financial companies

Yes

No

Qualifications & exceptions

• The general table answer is followed by state-specific provisions for California and Vermont customers, recorded in separate cards.

Not stated here

• The table does not identify the joint marketing partners; the definitions mention loan finance companies.

Cross-references

• defined by (model-proposed): Joint marketing requires a formal agreement between nonaffiliated financial companies — The definition identifies joint marketing as a formal agreement between nonaffiliated financial companies that market together; the table row addresses sharing for that joint marketing.
• has exception (model-proposed): California customers: no joint marketing sharing without authorization — For California customers, the notice withholds joint marketing sharing without authorization, while the general table row answers Yes to that sharing and No to any customer limit. The California provision qualifies that general answer for California customers.

Sharing & Disclosure · Company commitment

No affiliate sharing of transaction and experience information

For affiliates' everyday business purposes involving information about a customer's transactions and experiences, the table answers 'No' to whether Cross River Bank shares and 'We don’t share' to whether the customer can limit the sharing.

Supporting quotations

Reasons we can share your personal information

Does Cross River Bank share?

Can you limit this sharing?

For our affiliates' everyday business purposes- information about your transactions and experiences

No

We don’t share

Qualifications & exceptions

• The row is limited to affiliates' everyday business purposes and transaction/experience information.

Sharing & Disclosure · Company commitment

No affiliate sharing of creditworthiness information

For affiliates' everyday business purposes involving information about a customer's creditworthiness, the table answers 'No' to whether Cross River Bank shares and 'We don’t share' to whether the customer can limit the sharing.

Supporting quotations

Reasons we can share your personal information

Does Cross River Bank share?

Can you limit this sharing?

For our affiliates’ everyday business purposes- information about your creditworthiness

No

We don’t share

Qualifications & exceptions

• The row is limited to affiliates' everyday business purposes and creditworthiness information.

Cross-references

• referred to by (model-proposed): Federal law limits the customer's right to limit sharing to three categories — The creditworthiness row uses the same category the notice lists among the three sharing types federal law lets customers limit, but the row says Cross River Bank does not share it.
• qualified by (model-proposed): Vermont customers: no creditworthiness disclosure to affiliates — The Vermont paragraph adds a state-specific restriction on disclosing creditworthiness information to affiliates, alongside the general row that already says Cross River Bank does not share that information.

Sharing & Disclosure · Company commitment

No sharing for nonaffiliates to market to the customer

The table answers 'No' to sharing personal information so nonaffiliates can market to the customer and 'We don’t share' to whether the customer can limit that sharing.

Supporting quotations

Reasons we can share your personal information

Does Cross River Bank share?

Can you limit this sharing?

For nonaffiliates to market to you

No

We don’t share

Nonaffiliates we share with can include loan finance companies.

Qualifications & exceptions

• The row covers nonaffiliate marketing only; the definitions say nonaffiliates Cross River Bank shares with can include loan finance companies.

Cross-references

• referred to by (model-proposed): Federal law limits the customer's right to limit sharing to three categories — The nonaffiliate-marketing row matches the third category the notice says federal law lets customers limit; the row says Cross River Bank does not share it.
• qualified by (model-proposed): Nonaffiliates are unrelated companies; sharing can include loan finance companies — The definition explains that nonaffiliates are unrelated companies and that sharing with them can include loan finance companies; the table row is limited to nonaffiliate marketing.
• qualified by (model-proposed): Vermont customers: limits on marketing disclosures to nonaffiliated third parties — The Vermont paragraph adds state-specific conditions to disclosures to nonaffiliated third parties for marketing, alongside the general row that says Cross River Bank does not share for nonaffiliate marketing.

Legal Rights & Agreement Rules · Procedure

Questions and more privacy information by phone or website

The notice gives the toll-free number 1-877-55CRB55 and the Cross River Bank website as contact routes for questions. It also says additional information about its privacy policies is available at the website or the same number.

Supporting quotations

Questions?

Call toll-free 1-877-55CRB55 or contact us at www.crossriver.com

Additional information concerning our privacy policies can be found at www.crossriver.com

or call 1-877-55CRB55.

Qualifications & exceptions

• Both routes are stated without hours, response times or a named privacy officer.

Not stated here

• The notice does not state what information the website adds beyond this notice.

Security & Safeguards · Company commitment

Security measures include computer, physical and procedural safeguards

Answering how it protects personal information, Cross River Bank says it uses security measures that comply with federal law against unauthorized access and use. It lists computer safeguards, secured files and buildings, other physical, electronic and procedural safeguards, and access limited to employees for whom access is appropriate.

Supporting quotations

How does Cross River Bank protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We also maintain other physical, electronic and procedural safeguards to protect this information and we limit access to information to those employees for whom access is appropriate.

Qualifications & exceptions

• The description is general; no technical standard, certification or breach-response procedure is specified.

Not stated here

• No specific security standard or audit is named.

Data Access & Collection · Company practice

Collection happens at account opening, loan applications, transactions and customer disclosures

The notice says Cross River Bank collects personal information, for example, when a customer opens an account or applies for a loan, makes deposits or withdrawals or provides employment information, or gives contact information.

Supporting quotations

How does Cross River Bank collect my personal information?

We collect your personal information, for example, when you:

Open an account or apply for a loan;

Make deposits or withdrawals from your account or provide employment information;

Give us your contact information.

Qualifications & exceptions

• The list is introduced as examples, not an exhaustive account of collection events.

Data Access & Collection · Company practice

Cross River Bank also collects information from credit bureaus, affiliates and other companies

Beyond information provided by the customer, the notice says Cross River Bank collects personal information from others, such as credit bureaus, affiliates or other companies.

Supporting quotations

We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Qualifications & exceptions

• The sources listed follow 'such as' and are examples.

Not stated here

• The notice does not describe what information each outside source provides.

Legal Rights & Agreement Rules · User right or choice

Federal law limits the customer's right to limit sharing to three categories

Answering 'Why can't I limit all sharing?', the notice says federal law gives the customer the right to limit only three things: sharing for affiliates' everyday business purposes about creditworthiness, affiliates using information to market to the customer, and sharing for nonaffiliates to market to the customer. It adds that state laws and individual companies may give additional rights.

Supporting quotations

Why can't I limit all sharing?

Federal law gives you the right to limit only:

sharing for affiliates’ everyday business purposes – information about your creditworthiness

affiliates from using your information to market to you

sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

Qualifications & exceptions

• The three categories are the federal limits described in this notice; the notice does not detail state-law rights here.
• The notice does not describe how a customer exercises these federal limits.

Not stated here

• The opt-out mechanism for the three federal categories is not stated.

Cross-references

• refers to (model-proposed): No affiliate sharing of creditworthiness information — The creditworthiness row uses the same category the notice lists among the three sharing types federal law lets customers limit, but the row says Cross River Bank does not share it.
• refers to (model-proposed): No sharing for nonaffiliates to market to the customer — The nonaffiliate-marketing row matches the third category the notice says federal law lets customers limit; the row says Cross River Bank does not share it.

Legal Rights & Agreement Rules · Context

Affiliates are companies under common ownership or control

The definitions section says affiliates are companies related by common ownership or control, and that they can be financial or nonfinancial companies.

Supporting quotations

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

Cross-references

• defines (model-proposed): Cross River Bank says it does not share with affiliates — The definitions section supplies what affiliates means for the statement that Cross River Bank does not share with its affiliates.

Sharing & Disclosure · Company commitment

Cross River Bank says it does not share with affiliates

Under the affiliates definition, the notice states that Cross River Bank does not share with its affiliates. This statement is broader than the table rows, which address only transaction/experience and creditworthiness information.

Details not recorded for this card

Supporting quotations

Cross River Bank does not share with our affiliates.

Qualifications & exceptions

• The statement appears in the definitions section and does not list exceptions.

Not stated here

• The notice does not explain whether the statement covers all information or only the categories in this notice.

Cross-references

• defined by (model-proposed): Affiliates are companies under common ownership or control — The definitions section supplies what affiliates means for the statement that Cross River Bank does not share with its affiliates.

Sharing & Disclosure · Company practice

Nonaffiliates are unrelated companies; sharing can include loan finance companies

The notice defines nonaffiliates as companies not related by common ownership or control, financial or nonfinancial. It also says the nonaffiliates Cross River Bank shares with can include loan finance companies.

Supporting quotations

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

Nonaffiliates we share with can include loan finance companies.

Qualifications & exceptions

• The definition does not state the purpose of sharing with loan finance companies.

Not stated here

• The purpose and scope of sharing with nonaffiliate loan finance companies are not specified in the definition.

Cross-references

• qualifies (model-proposed): No sharing for nonaffiliates to market to the customer — The definition explains that nonaffiliates are unrelated companies and that sharing with them can include loan finance companies; the table row is limited to nonaffiliate marketing.

Sharing & Disclosure · Context

Joint marketing requires a formal agreement between nonaffiliated financial companies

The notice defines joint marketing as a formal agreement between nonaffiliated financial companies that together market financial products or services to the customer, and says its joint marketing partners include loan finance companies.

Supporting quotations

Joint marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

Our joint marketing partner(s) include loan finance companies.

Cross-references

• defines (model-proposed): Joint marketing sharing is marked not limitable in the general table — The definition identifies joint marketing as a formal agreement between nonaffiliated financial companies that market together; the table row addresses sharing for that joint marketing.

Sharing & Disclosure · Company commitment

California customers: no joint marketing sharing without authorization

For California customers, the notice says Cross River Bank will not share personal information for joint marketing without the customer's authorization. This qualifies the general joint marketing row, which answers 'Yes' to sharing and 'No' to whether the customer can limit it.

Supporting quotations

For California Customers. We will not share personal information for joint marketing-without your authorization.

Qualifications & exceptions

• This provision applies to California customers and to joint marketing sharing.

Cross-references

• exception to (model-proposed): Joint marketing sharing is marked not limitable in the general table — For California customers, the notice withholds joint marketing sharing without authorization, while the general table row answers Yes to that sharing and No to any customer limit. The California provision qualifies that general answer for California customers.

Legal Rights & Agreement Rules · User right or choice

Nevada customers: notice under Nevada law and a marketing-call opt-out

For Nevada customers, the notice says it is provided pursuant to Nevada law. A customer who prefers not to receive marketing calls can say so by calling 1-877-55CRB55 or contacting Cross River Bank at its website.

Supporting quotations

For Nevada Customers. We are providing you this notice pursuant to Nevada law. If you prefer not to receive marketing calls from us, please let us know by calling us at 1-877-55CRB55 or contact us at www.crossriver.com

Qualifications & exceptions

• The described opt-out concerns marketing calls, not all sharing of personal information.

Not stated here

• The notice does not describe any other Nevada-specific right.

Sharing & Disclosure · Company commitment

Vermont customers: no creditworthiness disclosure to affiliates

For Vermont customers, the notice says Cross River Bank will not disclose information about the customer's creditworthiness to its affiliates. This state-specific statement sits alongside the general affiliate row, which already answers 'No' to sharing creditworthiness information.

Supporting quotations

For Vermont Customers. We will not disclose information about your creditworthiness to our affiliates

Qualifications & exceptions

• Applies to Vermont customers and to creditworthiness information.
• The notice does not list exceptions for this affiliate restriction.

Not stated here

• The notice does not define creditworthiness information further.

Cross-references

• qualifies (model-proposed): No affiliate sharing of creditworthiness information — The Vermont paragraph adds a state-specific restriction on disclosing creditworthiness information to affiliates, alongside the general row that already says Cross River Bank does not share that information.

Sharing & Disclosure · Company commitment

Vermont customers: limits on marketing disclosures to nonaffiliated third parties

For Vermont customers, the notice says Cross River Bank will not disclose personal information, financial information, credit reports or health information to nonaffiliated third parties to market to the customer, except as permitted by Vermont law or unless the customer authorizes the disclosures.

Supporting quotations

will not disclose your personal information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures.

Qualifications & exceptions

• The prohibition is subject to disclosures permitted by Vermont law and to the customer's authorization.
• It covers marketing by nonaffiliated third parties and four named data types.

Not stated here

• The notice does not identify which disclosures Vermont law permits or how authorization is given.

Cross-references

• qualifies (model-proposed): No sharing for nonaffiliates to market to the customer — The Vermont paragraph adds state-specific conditions to disclosures to nonaffiliated third parties for marketing, alongside the general row that says Cross River Bank does not share for nonaffiliate marketing.