Privacy Policy

1. Scope of this notice

This notice describes how River Gem Bank collects and uses personal information through this website, the online account application, online banking and the secure message center. It applies to applicants, members and visitors.

It does not describe the separate privacy notices that apply to specific financial products where federal or state law requires a separate notice. Those notices are provided at account opening or when required by law. In the event of a conflict, the product-specific notice controls for that product.

2. Information we collect

We collect information you provide, information created by your use of the service, and information from verification and service providers.

• Application and account information. Name, address, email, phone, date of birth, product selection, pension-day information, reserve preference and initial deposit amount. We do not collect your Social Security number through the public application.
• Identity verification information. Where required, a government-issued ID, a selfie or other information provided through our verification process after a banker initiates it.
• Account activity. Transactions, balances, statements, secure messages, card details and requests submitted through online banking.
• Enquiry information. The name, email, phone, business or private banking interest and message you submit through our enquiry form.
• Technical information. IP address, browser type, device type, pages visited, timestamps and error logs, collected by our hosting and security providers.
• Information from third parties. Identity verification results, fraud-prevention signals and information from a joint applicant or authorized representative.

3. How we use information

We use personal information to:

• Review and process account applications and verify identity.
• Open, administer, service and secure accounts, cards and payments.
• Respond to enquiries and provide the banking relationship you requested.
• Detect, prevent and investigate fraud, money laundering and other financial crime.
• Comply with legal, regulatory, tax and reporting obligations.
• Operate, maintain and improve the website, online banking and the banker console.
• Send service messages, security alerts and, where permitted, information about products.

We do not sell personal information. We do not use application information for advertising, and we do not use automated decision-making to make a final credit or account decision without human review.

4. How we share information

We share information only as needed to provide the service, protect the bank and comply with law:

• Service providers. Hosting, authentication, database, object storage, email delivery, identity verification, payment and card-processing providers, under contracts that limit their use of the information.
• Regulators and law enforcement. The California DFPI, the FDIC and other authorities where required by law or a valid legal request.
• Professional advisers. Auditors, counsel and consultants subject to confidentiality obligations.
• Business transfers. A successor entity in a merger, acquisition or transfer of assets, subject to applicable notice requirements.
• With your direction. A joint account holder, authorized representative or other party you instruct us to share with.

5. Cookies and analytics

Online banking uses a session cookie to keep you signed in and a theme preference stored in your browser. We do not use advertising cookies. Our hosting and security providers may set strictly necessary cookies to protect the service and measure reliability. You can block cookies in your browser, but online banking may not work without the session cookie.

We also record aggregate clicks on service links and calls to action. That record contains the link label, destination, the page the link appeared on and the time of the click. It does not contain your name, email address, account number or session identifier, and it is used to improve navigation rather than for advertising.

6. How long we keep information

We keep application and account records for as long as the relationship lasts and for the period required by banking, tax and recordkeeping law afterwards. Enquiry records are kept for up to 24 months after the last contact. Technical logs are kept for a shorter operational period unless they are needed for a security investigation. Records subject to a legal hold are kept until the hold is released.

7. How we protect information

We use encryption in transit and at rest, multi-factor authentication, least- privilege access, audit logging, vendor due diligence and continuous fraud monitoring. Bankers access customer information only as needed to serve the relationship. No system is perfectly secure, but we design the controls around the money movement and the customer record rather than around a marketing claim.

If you believe your account or information has been compromised, call (949) 555-0199 immediately. We will never ask for your password or a one-time code by email or text.

8. Your rights and choices

Depending on your state and the product, you may have the right to access, correct or delete certain personal information, to opt out of certain sharing, or to receive a copy of your records. To make a request, email privacy@rivergem.bank or write to us at P.O. Box 1180, Newport Beach, CA 92659. We may need to verify your identity before acting on a request, and some records must be retained by law.

You can opt out of marketing email at any time using the unsubscribe link. You cannot opt out of service, security and legal notices while you have an account.

9. Children

The website and account application are intended for people 18 and older. We do not knowingly collect personal information from children. If you believe a child has submitted information, contact us and we will remove it.

10. Changes to this notice

We may update this notice to reflect changes in the law, our services or our practices. We will post the revised notice with a new effective date and, where required, provide additional notice. The version in effect when you use the service applies.

11. How to contact us

Privacy questions and requests: privacy@rivergem.bank. General service: support@rivergem.bank or (949) 555-0142.

River Gem Bank, P.O. Box 1180, Newport Beach, CA 92659. California state-chartered bank. License [LICENSE_ID]; FDIC certificate [FDIC_CERTIFICATE]. See the Terms of Use for the regulatory and product terms.