The California Consumer Privacy Act and its implementing regulations (“CCPA”) provide data privacy rights to California residents (“consumers” or “you”) with respect to the collection, use, and deletion of their personal information. First Financial Bank, N.A. (“we” or “Bank”) is committed to protecting consumer privacy and intends for this Privacy Notice for California Residents (“Notice”) to supplement the Bank’s existing privacy policies and notices applicable to our services.
First Financial Bank, N.A.
Privacy Notice for California Residents
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include: publicly available information from government records; deidentified or aggregated consumer information; or information excluded from the CCPA’s scope such as, by way of example, personal information covered by certain specific privacy laws, including the Fair Credit Reporting Act and the Gramm-Leach-Bliley Act.
In particular, within the last 12 months we may have collected any of the following categories of personal information from consumers: (Note this list is based on the statute’s definition of “Personal Information”)
- Personal identifiers, including those listed in other California statutes such as full name, alias, postal address, Internet Protocol address, email address, telephone number, account title, Social Security number, driver’s license number, passport or other government issued numbers, or other similar identifiers;
- Protected classification characteristics under California or federal law such as age, citizenship, physical or mental disability, veteran or military status;
- Commercial information such as records of personal property; products or services purchased, obtained, or considered; or other purchasing or consuming histories or tendencies;
- Biometric information such as fingerprints and voice recordings;
- Internet or other electronic network activity or information such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement;
- Geolocation data used to identify physical location;
- Sensory data such as audio, electronic, or similar information;
- Professional or employment-related information such as title, salary, and details of education; and
- Inferences drawn from other personal information which may include a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We do not knowingly collect or maintain information about minors, unless that information is provided by a parent, legal guardian, or authorized adult.
The above-listed categories of personal information are collected from the following sources:
- Directly from you;
- Indirectly from you and your activity on our digital properties;
- Public record sources;
- Our affiliates and corporate clients; and
- From third parties such as credit reference agencies and law enforcement authorities.
- We will not collect additional categories of personal information without providing you notice.
Use of Personal Information
We may use or disclose the personal information we collect for business purposes, including security, compliance, risk management, and marketing. More specifically, in the past 12 months, we have used personal information relating to consumers: (Note this list is the statute’s definition of “Business Purpose” verbatim)
Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
Detecting security incidents; protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity.
Debugging to identify and repair errors that impair existing intended functionality.
Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
Undertaking internal research for technological development and demonstration.
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.
We will not use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
As further described in this Notice, we may disclose your personal information to our affiliates and third parties for business purposes. Categories of third parties to whom personal information may be disclosed include: you and your authorized representatives; professional advisors such as accountants, auditors, lawyers; governmental and regulatory authorities; and third-party service providers.
Your rights pursuant to the CCPA include:
Your Right to Know
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 receive and confirm your verifiable consumer request, we will disclose to you, free of charge:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business purpose for collecting or disclosing that personal information.
- The categories of third parties with whom we share that personal information and why we disclose this information about you.
- The specific pieces of personal information we collected about you.
Your Right to Request Deletion of Personal Information
You have the right to request that we delete any of your personal information that we collected, unless the CCPA recognizes an exception. Please keep in mind, we are not obligated to honor a request for deletion if the personal information is needed for a business purpose.
Your Right to Opt-Out of Personal Information Sales
We do not sell or otherwise disclose personal information for monetary or other valuable consideration as contemplated by the CCPA. Therefore, we do not offer a mechanism for opting out from the sale of personal information.
Your Non-Discrimination Rights
You have the right to be free from unlawful discrimination for exercising your rights granted by the CCPA.
Exercising Your Rights
To exercise the rights described above, please submit a verifiable consumer request to us by either:
Phone: 1-800-511-0045 or 812-238-6000
First Financial Bank, N.A.
One First Financial Plaza
Terre Haute, Indiana 47807
Attn: Chief Compliance Officer
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: (Defer to Compliance and Risk regarding how to verify a customer)
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, including:
- Full name;
- Email address;
- Last four digits of your Social Security number; and
- Other information that authenticates you as a customer or verifies you as an authorized party.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We will confirm receipt of your verifiable request within 10 business days of delivery and respond within forty-five (45) calendar days. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing. If you have an online account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
Changes to Our Privacy Notice
We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated version on our website. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.
This Notice was last updated on July 1, 2020.