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.
Sharing & Disclosure · Company commitment
No rental or sale of information
Lead Bank states that it will never rent or sell your information to anyone.
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We will never rent or sell your information to anyone.
Federal notice duty and right to limit some sharing
Federal law requires financial companies to tell consumers how they collect, share, and protect personal information, and gives consumers the right to limit some but not all sharing. Lead Bank's notice explains what it does with personal information.
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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.
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
Retention & Deletion · Company practice
Retention continues after the customer relationship
When you are no longer a Lead Bank customer, Lead Bank continues to retain and share your information as described in the notice.
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When you are no longer our customer, we continue to retain and share your information as described in this notice.
Cross-references
qualifies (model-proposed): Right to delete, subject to retention and other exceptions — The notice's statement that it continues to retain and share information after the customer relationship ends qualifies the deletion right, which is subject to federal financial-services retention and other exceptions.
Sharing & Disclosure · Company practice
Sharing reasons and whether consumers can limit them
Lead Bank's table lists the reasons it may share personal information, whether it shares for that reason, and whether a consumer can limit the sharing. Lead Bank shares for its everyday business purposes (for example, processing transactions, maintaining accounts, responding to court orders and legal investigations, and reporting to credit bureaus), for its own marketing, and for joint marketing with other financial companies; the table says consumers cannot limit those three categories. It does not share for affiliates' everyday business purposes based on transactions and experiences or creditworthiness, for affiliates to market to you, or for nonaffiliates to market to you; the table says "We don't share" for those four rows.
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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 Lead Bank chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information
For our everyday business purposes– such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus Yes No
For our marketing purposes– to offer our products and services to you Yes No
For joint marketing with other financial companies Yes No
For our affiliates' everyday business purposes– information about your transactions and experiences No We don't share
For our affiliates' everyday business purposes– information about your creditworthiness No We don't share
For our affiliates to market to you No We don't share
For nonaffiliates to market to you No We don't share
Qualifications & exceptions
The answers are read from the table's "Does Lead Bank share?" and "Can you limit this sharing?" columns; the column answers are not repeated in each row quote.
Cross-references
qualified by (model-proposed): Vermont accounts automatically treated as limiting sharing — Vermont accounts are automatically treated as having limited sharing as described above; for joint marketing, only name, contact information, and transaction information are disclosed. This regional rule qualifies the general sharing table.
Account & Service Control · Procedure
Questions and contact channels
For questions, call 866-845-9545 and use the menu prompts, visit www.lead.bank, or email clientsupport@lead.bank.
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Call 866-845-9545—our menu will prompt you through your choices
Lead Bank identifies itself as the provider of this notice.
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Who is providing this notice? Lead Bank
Security & Safeguards · Company commitment
Security measures and access limits
Lead Bank says it uses security measures that comply with federal law to protect personal information from unauthorized access and use, including computer safeguards and secured files and buildings. Employees may access information only when they need it for their work, and companies working for Lead Bank must protect the information.
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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 authorize our employees to get your information only when they need it to do their work, and we require companies that work for us to protect your information.
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.
Sharing & Disclosure · User right or choice
Federal right to limit three sharing categories
Federal law gives consumers the right to limit only three categories of sharing: sharing for affiliates' everyday business purposes about the consumer's creditworthiness, affiliates' use of the consumer's information to market to them, and sharing for nonaffiliates to market to the consumer.
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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
No collection or sharing for the limitable purposes; state law may add rights
Lead Bank states that it does not collect or share information for the three purposes for which federal law gives a right to limit. State laws and individual companies may give additional rights to limit sharing.
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You should be aware that Lead Bank does not collect or share information for these purposes.
State laws and individual companies may give you additional rights to limit sharing. See below for more information on your rights under state law.
Qualifications & exceptions
The additional state-law rights are described later in the notice; this card does not summarize them.
Cross-references
qualifies (model-proposed): Federal right to limit three sharing categories — Lead Bank's statement that it does not collect or share information for the three federally limitable purposes qualifies the practical effect of the federal right to limit those categories.
Linking & Identification · Context
Definitions: affiliates, nonaffiliates, and joint marketing
Affiliates are companies related by common ownership or control, financial or nonfinancial; Lead Bank's affiliates include others such as Luna Parent, Inc. Nonaffiliates are companies not related by common ownership or control, financial or nonfinancial; Lead Bank says it does not share with nonaffiliates so they can market to you. Joint marketing is a formal agreement between nonaffiliated financial companies that together market financial products or services to you; Lead Bank's joint marketing partners include third party financial service platforms for credit cards, loans, and other banking services.
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Companies related by common ownership or control. They can be financial and nonfinancial companies.
Our affiliates include others, such as Luna Parent, Inc.
Companies not related by common ownership or control. They can be financial and nonfinancial companies.
Lead Bank does not share with nonaffiliates so they can market to you.
A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
Our joint marketing partners include third party financial service platforms for credit cards, loans, and other banking services
Legal Rights & Agreement Rules · Procedure
Charter, regulator, and complaint route
Lead Bank is chartered under Missouri law and subject to FDIC regulatory oversight. A consumer wishing to file a complaint against Lead Bank may contact the FDIC in person or by U.S. mail at 1100 Walnut Street, Suite 2100, Kansas City, MO 64106; by telephone at (800) 209-7459; or online through the FDIC Customer Assistance Form.
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Lead Bank is chartered under the laws of the State of Missouri and is subject to regulatory oversight by the FDIC. Any consumer wishing to file a complaint against Lead Bank should contact the FDIC through one of the following means: In person or by U.S. Mail at 1100 Walnut Street; Suite 2100; Kansas City, MO 64106, by telephone at (800) 209-7459, or online at:
Legal Rights & Agreement Rules · Context
State privacy law rights may apply
Several U.S. states, including California, have enacted or will soon enact consumer privacy laws that grant residents certain rights and require additional disclosures. Residents of California or another such state may have rights under the applicable state law.
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Several U.S. states, including California, have enacted or will soon enact consumer privacy laws that grant their residents certain rights and require additional disclosures. If you are a resident of California or one of these states, you may have rights granted under the applicable state law.
Sharing & Disclosure · Restriction or exception
Vermont accounts automatically treated as limiting sharing
Accounts with a Vermont mailing address are automatically treated as if the account holder had limited sharing as described earlier in the notice. For joint marketing, Lead Bank will disclose only the account holder's name, contact information, and information about transactions.
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Accounts with a Vermont mailing address are automatically treated as if they have limited the sharing as described above. For joint marketing, we will only disclose your name, contact information and information about your transactions.
Qualifications & exceptions
This is a Vermont-specific automatic treatment; the notice does not require the account holder to make a request.
Not stated here
The notice does not enumerate the sharing categories covered by the automatic Vermont limitation; it refers to the limitation "as described above."
Cross-references
qualifies (model-proposed): Sharing reasons and whether consumers can limit them — Vermont accounts are automatically treated as having limited sharing as described above; for joint marketing, only name, contact information, and transaction information are disclosed. This regional rule qualifies the general sharing table.
Legal Rights & Agreement Rules · Procedure
Nevada notice and complaint contacts
Lead Bank provides this notice under Nevada law. For more information, contact Lead Bank at 866-845-9545 or clientsupport@lead.bank with "Nevada Annual Notice" in the subject line. A consumer may also contact the Bureau of Consumer Protection, Office of the Nevada Attorney General, at 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; telephone 702-486-3132; email BCPINFO@ag.state.nv.us.
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We are providing you this notice pursuant to Nevada law. For more information, contact us at 866-845-9545, or email clientsupport@lead.bank, with “Nevada Annual Notice” in the subject line. You may also contact the Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; telephone number: 702-486-3132; email BCPINFO@ag.state.nv.us.
Sharing & Disclosure · Restriction or exception
California accounts automatically treated as limiting nonaffiliate sharing
Accounts with a California mailing address are automatically treated as if the account holder had limited sharing with nonaffiliates as described earlier. California residents seeking additional choices over their data are directed to the California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020 in the next section.
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Accounts with a California mailing address are automatically treated as if they have limited the sharing with nonaffiliates as described above. If you are a California resident and would like to exercise additional choices over your data, please review the California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020 in the next section.
Qualifications & exceptions
This is a California-specific automatic treatment; the notice does not require the account holder to make a request.
Not stated here
The notice does not enumerate the nonaffiliate sharing covered by the automatic California limitation; it refers to the limitation "as described above."
Legal Rights & Agreement Rules · Procedure
Data Subject Request verification and detail requirements
Each Data Subject Request must provide sufficient information to allow Lead Bank to reasonably verify that the requester is the person about whom personal information was collected or an authorized representative. Lead Bank says it will make every effort to verify identity using the email address but may request additional information. If an authorized representative makes the request, Lead Bank requires documentation showing that the representative has authority. The request must describe the Data Subject Request with sufficient detail to allow Lead Bank to evaluate and respond. Lead Bank says it cannot respond or provide personal information if it cannot verify identity or the agent's authority, and that personal information provided in a verifiable request is used to verify identity or authority and not for any other purpose.
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Each Data Subject Request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. We will make every effort to verify your identity using your email address, but we may request additional information. If an authorized representative is making the request on your behalf, we require documentation showing that the representative has such authority.
Describe your Data Subject Request with sufficient detail that allows us to properly evaluate and respond to it.
We cannot respond to your Data Subject Request or provide you with personal information if we are unable to verify your identity, or unable to verify the authority for the person making the request as your agent. We will use personal information provided in a verifiable consumer Data Subject Request to verify your identity or authority to make the Data Subject Request, and not for any other purpose.
Qualifications & exceptions
Verification and sufficient detail are stated as conditions of processing a request.
Legal Rights & Agreement Rules · Restriction or exception
Access and portability requests limited to twice in 12 months
A consumer may make only two verifiable Data Subject Requests for access or data portability within a 12-month period.
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You may only make a verifiable Data Subject Request for access or data portability twice within a 12-month period.
Legal Rights & Agreement Rules · Procedure
Response timing, 12-month disclosure window, and no fee
Lead Bank will acknowledge a Data Subject Request within 10 days and attempts to respond within 45 days. If it needs more time, it will inform the requester of the reason and the additional time required, up to 90 days in total. Disclosures may cover only the 12-month period preceding receipt of the request. If Lead Bank cannot satisfy all or part of a request, it will explain why. Where required by applicable State Privacy Laws, a denial may be appealable, and Lead Bank will tell the requester how to submit an appeal in its response. Lead Bank does not charge a fee to process or respond to Data Subject Requests.
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We will acknowledge your Data Subject Request within 10 days. We attempt to respond to every Data Subject Request within 45 days. If we require more time, we will inform you of the reason and how much additional time we require (up to 90 days in total). Any disclosures we provide may only cover the 12-month period preceding the Data Subject Request’s receipt. If we are unable to satisfy your Data Subject Request, or a part of your Data Subject Request, we will explain why. Where required by applicable State Privacy Laws, if we deny your request, you may also have the right to appeal our decision, and we will tell you how to submit an appeal in our response.
We do not charge a fee to process or respond to Data Subject Requests.
Qualifications & exceptions
The 45-day response period is described as an attempt, not a guarantee; the total may extend to 90 days with notice.
Legal Rights & Agreement Rules · Procedure
Who may use an authorized agent and what proof is required
A verifiable Data Subject Request may be made only by the consumer, a person the consumer has designated in writing as an authorized agent, a person registered with the applicable Secretary of State to act on the consumer's behalf, or a person to whom the consumer has provided power of attorney under applicable law. A consumer may also make a verifiable request on behalf of a minor child. An authorized agent must provide sufficient written proof that the consumer designated them, and Lead Bank will still require sufficient information to reasonably verify that the consumer is the person about whom personal information was collected.
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Only you, or a person you have designated in writing as your authorized agent, or who is registered with the applicable Secretary of State to act on your behalf, or to whom you have provided power of attorney pursuant to applicable laws (“Authorized Agent”), may make a verifiable Data Subject Request. You may also make a verifiable Data Subject Request on behalf of your minor child.
If you wish to have an Authorized Agent make a request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your Authorized Agent, and we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information.
Legal Rights & Agreement Rules · Company commitment
No discrimination for exercising privacy rights
Lead Bank will not discriminate against a consumer for exercising any privacy rights. Unless permitted by the State Privacy Laws, Lead Bank will not deny services; charge different prices for its services, including through discounts or other benefits or penalties; or provide a different level or quality of service.
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We will not discriminate against you for exercising any of your rights. Unless permitted by the State Privacy Laws, we will not:
Deny you services.
Charge you different prices for our services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of service.
Qualifications & exceptions
The commitments are qualified by "Unless permitted by the State Privacy Laws."
Legal Rights & Agreement Rules · User right or choice
California direct-marketing list request (Section 1798.83)
If you are a California resident, California Civil Code Section 1798.83 permits you to request a list of all third parties to which Lead Bank, during the immediately preceding calendar year, disclosed certain personally identifiable information for direct marketing purposes. Lead Bank says it has not disclosed personally identifiable information for direct marketing purposes in the preceding calendar year. Lead Bank is only required to respond to a customer request for this list once during any calendar year; requests are made through the "Exercising Your Privacy Choices and Rights" section. Not all information sharing is covered by the California privacy rights requirements, and only covered sharing will be included in the response.
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If you are a California resident, California Civil Code Section 1798.83 permits you to request a list of all third parties to which we, during the immediately preceding calendar year, have disclosed certain personally identifiable information for direct marketing purposes. In the preceding calendar year, we have not disclosed personally identifiable information for direct marketing purposes.
We are only required to respond to a customer request for this list once during any calendar year. To make such a request, please see above under the section “Exercising Your Privacy Choices and Rights.” Please be aware that not all information sharing is covered by the California privacy rights requirements and only information sharing that is covered will be included in our response.
Qualifications & exceptions
The cited California Civil Code Section 1798.83 is an external legal citation; the notice's own description is the supplied evidence.
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.
Use & Processing · Context
Purposes of collection
Lead Bank collects personal information for the business and commercial purposes and uses described in the Privacy Policy section titled "What does Lead Bank do with your personal information?"
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We collect personal information for the business and commercial purposes and uses described in the Privacy Policy section titled “What does Lead Bank do with your personal information?”
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.
Retention & Deletion · Company practice
Retention periods set by six criteria
Retention periods for data elements in each category vary depending on the nature of the data element and the purposes for which it is collected and used. Lead Bank sets retention based on: (1) the length of time the data is needed for the purposes for which it was created or collected; (2) the length of time needed for other operational or record retention purposes; (3) the length of time needed for legal, compliance, and regulatory requirements, legal defense purposes, and legal holds; (4) how the data is stored; (5) whether the data is needed for security purposes and fraud prevention; and (6) whether the data is needed to ensure continuity of Lead Bank's products and services.
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The retention periods for data elements within each category listed above vary depending on the nature of the data element and the purposes for which it is collected and used. Our retention period for the data elements within each category is set based on the following criteria: (1) the length of time that the data is needed for the purposes for which it was created or collected, (2) the length of time the data is needed for other operational or record retention purposes, (3) the length of time the data is needed in connection with our legal, compliance and regulatory requirements, for legal defense purposes and to comply with legal holds, (4) how the data is stored, (5) whether the data is needed for security purposes and fraud prevention, and (6) whether the data is needed to ensure the continuity of our products and services.
Not stated here
The notice states criteria, not category-specific retention periods.
Legal Rights & Agreement Rules · Company practice
Changes to the State Mandated Privacy Notice
Lead Bank reserves the right to amend this privacy notice at its discretion and at any time. When it makes material changes to this notice, it will notify the recipient by email, by notice on this site, or by other acceptable means.
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We reserve the right to amend this privacy notice at our discretion and at any time. When we make material changes to this privacy notice, we will notify you by email, by notice on this site, or by other acceptable means.
Qualifications & exceptions
This change clause is stated for the U.S. State Mandated Privacy Notice at Collection; the introduction has a separate amendment sentence for the privacy policy.
Legal Rights & Agreement Rules · Procedure
Contact information for questions and rights requests
For questions or comments about the notice, the Privacy Policy, how Lead Bank collects and uses personal information, choices and rights, or to exercise rights under State Privacy Laws, contact Lead Bank by email at clientsupport@lead.bank or by phone at 866-845-9545.
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If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under State Privacy Laws, please do not hesitate to contact us.
By email: clientsupport@lead.bank
By phone: 866-845-9545
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.
Linking & Identification · Context
Fiserv provides mobile-banking technology; separate TouchBanking notice
The Mobile App is currently provided using mobile-banking technology and services from Fiserv, Inc., which the notice calls the mobile-banking service provider. Fiserv also publishes a separate TouchBanking Privacy Notice describing in more detail how its TouchBanking mobile platform collects and uses information; the notice is available at the link given in the source.
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Fiserv also publishes a separate TouchBanking Privacy Notice that describes in more detail how its TouchBanking mobile platform collects and uses information.
Qualifications & exceptions
The linked TouchBanking Privacy Notice is not supplied in this saved source; its contents are not summarized here.
Cross-references
referred to by (model-proposed): Fiserv's role and Lead Bank's responsibility — Lead Bank's responsibility statement refers to Fiserv's separate TouchBanking Privacy Notice for more detail and gives this mobile section and Lead Bank's main Privacy Policy precedence if the notices conflict.
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.
Use & Processing · User right or choice
Location services are optional; declining may limit features
A consumer is not required to enable location services to use the Mobile App. To avoid collection of Location Information, the consumer can decline location access when first prompted by the app or turn off location services for the app (or the device entirely) in the device's operating-system settings. If the app is not allowed to access Location Information, some features may not function properly or may be unavailable, including certain fraud-prevention tools and location-based services such as branch and ATM locator functions.
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You are not required to enable location services to use the Mobile App. If you do not want Location Information to be collected, you can:
Decline location access when first prompted by the Mobile App; or
Turn off location services for the Mobile App (or for your device entirely) in your device’s operating‑system settings.
Please note, however, that if you do not allow the Mobile App to access Location Information, some features may not function properly or may be unavailable, including certain fraud‑prevention tools and location‑based services (such as branch and ATM locator functions).
Qualifications & exceptions
The notice states that declining location access may affect features but does not say the app cannot be used without location services.
Cross-references
qualifies (model-proposed): Location information and its purposes — 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.
Linking & Identification · Company commitment
Fiserv's role and Lead Bank's responsibility
Fiserv provides mobile-banking services, including the TouchBanking platform, to Lead Bank as a service provider. Lead Bank remains responsible for the treatment of the consumer's personal information as described in the Privacy Policy and any other notices Lead Bank provides. Fiserv processes personal information on Lead Bank's behalf to deliver mobile-banking functionality, to support, secure, and improve the Mobile App, and for other purposes described in the TouchBanking Privacy Notice and permitted by law and by Lead Bank's agreements with Fiserv. For a more detailed description of how the TouchBanking platform collects, uses, and shares information, including device-level data and Location Information, the consumer may review Fiserv's TouchBanking Privacy Notice. If any aspect of that notice appears to conflict with the Privacy Policy, this mobile-app section and Lead Bank's main Privacy Policy govern the relationship with the consumer as a Lead Bank customer.
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Fiserv provides mobile‑banking services (including the TouchBanking platform) to Lead Bank as a service provider. When you use Lead Bank Mobile:
Lead Bank remains responsible for the treatment of your personal information as described in this Privacy Policy and in any other privacy notices we provide to you; and
Fiserv processes personal information on our behalf to deliver mobile‑banking functionality, to support, secure and improve the Mobile App, and for other purposes described in the TouchBanking Privacy Notice and permitted by law and by our agreements with Fiserv.
For a more detailed description of how the TouchBanking platform collects, uses, and shares information (including device‑level data and Location Information), you may review Fiserv’s TouchBanking Privacy Notice, referenced above. If any aspect of that notice appears to conflict with this Privacy Policy, this “Additional Information for Lead Bank Mobile Users” section and Lead Bank’s main Privacy Policy will govern our relationship with you as a Lead Bank customer.
Qualifications & exceptions
The linked TouchBanking Privacy Notice is not supplied in this saved source; its contents are not summarized here.
The precedence statement names this mobile-app section and Lead Bank's main Privacy Policy as governing if the TouchBanking notice conflicts.
Cross-references
refers to (model-proposed): Fiserv provides mobile-banking technology; separate TouchBanking notice — Lead Bank's responsibility statement refers to Fiserv's separate TouchBanking Privacy Notice for more detail and gives this mobile section and Lead Bank's main Privacy Policy precedence if the notices conflict.
Legal Rights & Agreement Rules · Context
State Mandated Privacy Notice scope
This section is a U.S. State Mandated Privacy Notice at Collection. It applies to residents of states that have enacted or will soon enact consumer privacy laws granting rights and requiring additional disclosures ("State Privacy Laws") and supplements Lead Bank's Privacy Policy. It is intended to provide information required under those laws, including the CCPA, and applies to Lead Bank's data collection and processing practices.
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If you are a resident of one of these states, this section applies to you and supplements the information contained in
This notice is intended to provide information required under State Privacy Laws, including the CCPA. This notice applies to the data collection and processing practices of Lead Bank (collectively, “Lead Bank” or “we”).
Legal Rights & Agreement Rules · Context
Federal law generally governs; some information falls under state law
Lead Bank says its data collection practices are generally governed by federal law, including the Gramm-Leach-Bliley Act ("GLBA"). Certain information may be out of scope of federal law and instead covered by State Privacy Laws. Under the California Consumer Privacy Act of 2018, as amended by the CPRA and other California laws (the "CCPA"), this may include information about employees and employee applicants as well as enterprise data (such as business-to-business).
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As explained in our Privacy Policy, both federal and state laws require us to tell you how we collect, use, share, and protect your personal information. As a result, our data collection practices are generally governed by federal law, including the Gramm-Leach-Bliley Act (“GLBA”). However, certain information collected may be out of scope of federal laws and instead covered by State Privacy Laws. Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (“CPRA”) of 2020 and other California laws (collectively, the “CCPA”), this may also include information about employees and employee applicants as well as enterprise data (such as business-to-business).
Sharing & Disclosure · Company practice
No sale, advertising technology, or targeted advertising
Lead Bank says it does not and will not sell consumer personal information in the traditional and colloquial sense of the word sale. It says it does not use advertising technology on its website, which under some State Privacy Laws may be considered a "sale" or "share" of information. In the preceding twelve months, Lead Bank says it has not "sold" or "shared" consumers' personal information as defined under State Privacy Laws, and it does not engage in targeted advertising.
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We do not and will not sell consumer personal information in the traditional and colloquial sense of the word sale. We do not use advertising technology on our website, which under some State Privacy Laws may be considered a “sale” or “share” of your information. In the preceding twelve (12) months, we have not “sold” or “shared” consumers’ personal information, as defined under State Privacy Laws. We do not engage in targeted advertising.
Qualifications & exceptions
The notice addresses both the traditional or colloquial sense of "sale" and the statutory definitions of "sold" and "shared" under State Privacy Laws.
Cross-references
contrast (model-proposed): Right to know, access, and data portability — 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.
Charges & Financial Obligations · Company practice
No financial incentives or service differences for data
Lead Bank says it does not offer financial incentives, preferential service agreements, or any other differences in its prices or services in exchange for consumer data.
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We also do not offer financial incentives, preferential service agreements, or any other differences in our prices or services in exchange for your data.
Legal Rights & Agreement Rules · User right or choice
Overview of state privacy rights
Under the State Privacy Laws, consumers may have rights to (1) request to know more about the categories and specific pieces of personal information Lead Bank collects, uses, and discloses and to access that information, including in a portable format; (2) request deletion of personal information; (3) request correction of inaccurate personal information; (4) request to limit the use and disclosure of sensitive personal information; and (5) not be discriminated against for exercising these rights. The notice calls these "Data Subject Requests" and says the section describes the rights and how to exercise them with Lead Bank.
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Under the State Privacy Laws, you may have the following rights, including the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose and access your personal information, including receive the information in a portable format, (2) request deletion of your personal information, (3) request correction of inaccurate personal information, (4) request to limit the use and disclosure of sensitive personal information, and (5) not be discriminated against for exercising these rights (“Data Subject Requests”).
This section describes consumers’ rights under the State Privacy Laws and explains how you can exercise those rights with Lead Bank.
Retention & Deletion · User right or choice
Right to delete, subject to retention and other exceptions
Under certain State Privacy Laws, a consumer has the right to request deletion of personal information Lead Bank collected and retained, subject to certain exceptions. After receiving and verifying the request, Lead Bank will delete the information from its records and direct its service providers to delete it from theirs, unless an exception applies. Certain personal information used to provide financial services that Lead Bank is obligated by federal law or regulations to retain cannot be deleted on request. Lead Bank may also deny a deletion request if retaining the information is necessary for Lead Bank or its service providers to detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; assist law enforcement in prosecuting those responsible; or comply with a legal obligation.
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Under certain State Privacy Laws, you have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your Data Subject Requests, we will delete your personal information from our records (and direct our service providers to delete your personal information from their records), unless an exception applies.
Certain personal information that we collect and use to provide you with financial services, and which Lead Bank is obligated by federal law and/or regulations to retain, cannot be deleted upon request.
We also may deny your Data Subject Requests to delete if retaining the information is necessary for us or our service providers to:
Detect security incidents;
Protect against malicious, deceptive, fraudulent, or illegal activity;
Assist law enforcement in prosecuting those responsible for such activities; or
Comply with a legal obligation.
Qualifications & exceptions
The federal financial-services retention exception and the four listed denial grounds are exceptions to the deletion right.
Cross-references
qualified by (model-proposed): Retention continues after the customer relationship — The notice's statement that it continues to retain and share information after the customer relationship ends qualifies the deletion right, which is subject to federal financial-services retention and other exceptions.
Legal Rights & Agreement Rules · User right or choice
Right to correction
Under certain State Privacy Laws, a consumer has the right to request correction of inaccuracies about their personal information. If Lead Bank provides the consumer with financial services, the consumer can make the request through Lead Bank's application.
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Under certain State Privacy Laws, you have the right to request that we correct any inaccuracies about your personal information. If we provide you with financial services, you can do so through our application.
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.
Use & Processing · User right or choice
Right to limit sensitive personal information; current practice
A consumer has the right to request that Lead Bank limit the use and disclosure of sensitive personal information to the services Lead Bank provides to the consumer. Lead Bank says its current practice is to use the sensitive personal information it collects only for the purpose of providing the financial services it offers.
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You have the right to request that we limit the use and disclosure of sensitive personal information to the services we provide to you. Lead Bank’s current practice is to use the sensitive personal information it collects only for the purpose of providing you with the financial services we offer.
Qualifications & exceptions
The notice states that current practice already limits sensitive personal information to providing financial services; it does not describe a separate request mechanism in this passage.
Legal Rights & Agreement Rules · Procedure
Exercising state privacy rights by email or phone
A resident of a state that provides the rights described above may exercise them by email at clientsupport@lead.bank or by phone at 866-845-9545.
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If you are a resident of a state that provides the above rights under State Privacy Laws, you may exercise the rights above by: