Privacy Policy

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Online Privacy Policy

This Online Privacy Policy applies to this Coosa Valley Mortgage online property that links to

this Policy. This Policy describes how our Sites may collect, use and share information from or about you, and explains how information may be collected and used for advertising purposes.

HOW WE COLLECT, USE AND SHARE INFORMATION

What Information Do We Collect?

We collect data which may be considered to be personally identifiable information. Please see the Personal Identifiable Information section below for more information. We also collect nonidentifiable data, which is information considered to not reveal specific details related to your identity. Please see the Non-Identifiable Information section below for more information. 

What is considered Personal Identifiable information and how is it collected?

Personal identifiable information is information that can be used on its own to identify, locate or contact a single person. This information includes that which you may submit through forms, surveys, applications, or other online fields. The types of information collected may include, but is not limited to: name, address (postal and email), and phone numbers.

How Do We Use Personal Information?

We may use any information collected through this Sites in order to do any of, but not limited to, the following: Respond directly to your questions and/or inquiries; Provide you updates regarding changes in policies, procedures and/or information regarding your account; Deliver marketing communications including, ads, surveys or offers tailored to you; Allow you to apply for products or services you may be interested in, as well as assessing eligibility for those enrollments;

How is Personal Information Shared?

For more detail on how Personal Information may be shared and how you may be able to limit certain types of Personal Information that may be shared, please reference the Coosa Valley Mortgage Privacy Policy.

ADDITIONAL INFORMATION

Advertising Coosa Valley Mortgage collects non-identifying information such as page visits, keywords used to find the Sites, pages viewed within our Sites and geography of those visiting our Sites. This information is used to create informed advertising and marketing strategies based on the general preferences, user behavior, and other user attributes. We may also use this information to determine the effectiveness of the above-mentioned strategies. Advertising types may include: 

1. Relationship-based Advertising

We may use general information about your relationship with Coosa Valley Mortgage to help determine which advertisements or offers to present to you.

2. Online Behavioral Advertising 

We may use certain information about your user behavior on our Sites, such as search key word sentered to help choose which of our advertisements may be of most interest to you. We may  also use this information for the purposes of offline marketing and advertising.

Online Privacy Policy

PURPOSE

Coosa Valley Mortgage has adopted this information security policy, which defines responsibilities and sets forth guidelines for appropriate administrative, technical, and physical safeguards over sensitive information. This program is designed to: • Ensure the security and confidentiality of customer and business information; • Protect against any anticipated threats or hazards to the security or integrity of such information; and • Protect against unauthorized access to or use of such information that could result in substantial harm or inconvenience to the bank, its bank affiliates, or any customer. In addition, the Board of Directors oversees the development, implementation, and maintenance of the information security program.

BACKGROUND 

Section 501(b) of the Gramm-Leach-Bliley Act (GLBA) of 1999 requires the financial institution regulatory agencies to establish standards for administrative, technical, and physical safeguards to protect customer information. This requirement complements the privacy and information sharing provisions of the GLBA (Title V) which directs financial institutions to implement standards for privacy and data disclosure, in addition to issuing privacy notices to customers that outline these standards. Effective July 1, 2001, The Interagency Guidelines Establishing Standards for Safeguarding Customer Information, were published jointly by the Federal financial institution regulators. These Guidelines set forth standards pursuant to Section 39 of the 20 Federal Deposit Insurance Act, and Sections 501 and 505 of the Gramm-Leach-Bliley Act (15 U.S.C. 6801 and 6805).

RESPONSIBILITY

Senior Management is responsible for: • Reviewing and approving the written information security program and supporting policies 

POLICY

Identity

Information Classification

Coosa Valley Mortgage policies, procedures, and controls for information security are based on the understanding that confidential information (including all non-public customer and consumer information in addition to sensitive corporate data) requires appropriate protection. To ensure that all employees recognize and distinguish confidential information, the company has established information classification categories. All information is categorized as Confidential or Public based on the following definitions. When determining the appropriate classification, consideration will be given to the nature of information (its source, use, and purpose) and the need for protective measures (confidentiality, integrity, and availability). • Confidential information – Confidential information consists of non-public customer and consumer information (as defined by the “Privacy Rule” associated with Title V of the GLBA.), critical bank/corporate information (e.g., proprietary, trade secrets, payroll, information subject to attorney/client privileges), or proprietary/critical data of bank affiliates or partners. Compromise of confidential information could result in serious harm to the bank in terms of financial, legal, and reputational consequences. • Non-confidential information – Non-confidential information is information that can freely be given to anyone without any possible damage to the bank, its affiliates, partners, or customers. Examples of public information include advertising material, product and service information and other data that might be posted in print or other media (e.g., public web site). In the event that there is any uncertainty about the appropriate classification for certain information, Coosa Valley Mortgage’s policy is to treat the information as confidential. When information systems or physical storage facilities contain a combination of data from both categories, the entire system or facility will be treated as confidential.

 No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.