Protecting your privacy is important to us. Accordingly, Western Alliance Bank is providing its Privacy Policy to explain what and how we collect, share, use, and protect your personal information. If you are a California resident, you may have additional rights under the California Consumer Privacy Act (“CCPA”) as described in the Privacy Notice for California Residents, which supplements the information contained in the Privacy Policy.
PRIVACY POLICY (rev 01/01/2016)
| FACTS | WHAT DOES Western Alliance Bank (divisions are Alliance Association Bank, Alliance Bank of Arizona, Bank of Nevada, Bridge Bank, First Independent Bank, and Torrey Pines Bank) DO WITH YOUR PERSONAL INFORMATION? |
|---|---|
| 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. |
| What? |
The types of personal information we collect and share depend on the product or service you have with us. This information can include:
|
| 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 Western Alliance Bank chooses to share; and whether you can limit this sharing. |
| Reasons we can share your personal information | Does Western Alliance Bank share? | Can you limit this sharing? |
|---|---|---|
| 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 | No | We don’t share |
| 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 non-affiliates to market to you | No | We don’t share |
| Questions | ||
|---|---|---|
| If you have questions, please call us or go to our division websites: | ||
| Western Alliance Bank Divisions: www.westernalliancebancorporation.com or at the following sites: | ||
| Alliance Association Bank | www.allianceassociationbank.com | 888-734-4567 |
| Alliance Bank of Arizona | www.alliancebankofarizona.com | 877-273-2265 |
| Bank of Nevada | www.bankofnevada.com | 877-299-2265 |
| Bridge Bank | www.bridgebank.com | 408-423-8500 |
| First Independent Bank | www.firstindependentnv.com | 775-828-2000 |
| Torrey Pines Bank | www.torreypinesbank.com | 877-476-2265 |
| Who we are | |
|---|---|
| Who is providing this notice? | Western Alliance Bank (divisions are Alliance Association Bank, Alliance Bank of Arizona, Bank of Nevada, Bridge Bank, First Independent Bank, and Torrey Pines Bank) |
| What we do | |
| How does Western Alliance 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 restrict access to only those employees who need to know information to provide products or services to you. |
| How does Western Alliance Bank collect my personal information? |
We collect your personal information, for example, when you
|
| Why can’t I limit all sharing? |
Federal law gives you the right to limit only
|
| Definitions | |
| Affiliates |
Companies related by common ownership or control. They can be financial and nonfinancial companies.
|
| Non-affiliates |
Companies not related by common ownership or control. They can be financial and nonfinancial companies.
|
| Joint marketing |
A formal agreement between non-affiliated financial companies that together market financial products or services to you.
|
| Other important information | |
| Western Alliance Bancorporation www.westernalliancebancorporation.com | |
WESTERN ALLIANCE BANK PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Effective Date: 07/01/2020
Last Reviewed on: 07/01/2020
This Privacy Notice for California Residents supplements the information contained in Western Alliance Bank’s Privacy Policy (https://www.westernalliancebancorporation.com/privacy-legal-home/privacy-policy) (divisions are Alliance Association Bank, Alliance Bank of Arizona, Bank of Nevada, Bridge Bank, First Independent Bank, and Torrey Pines Bank) (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.
Information We Collect
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.
- • Information excluded from the CCPA's scope, like:
- ○ Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- ○ Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (CalFIPA), and the Driver's Privacy Protection Act of 1994.
We have collected the following categories of personal information from consumers within the last twelve (12) months:
| Category | Examples | Collected |
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. | YES |
| B. Categories of personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. |
YES |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth (including related medical conditions), sexual orientation, veteran or military status. | YES |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data | YES |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. | YES |
| G. Geolocation data. | Physical location or movements. | NO |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | YES |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | YES |
| J. Non-public education information under the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99). | Education records directly related to a student maintained by an educational institution or party acting on their behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information. | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | YES |
We obtain the categories of personal information listed above from the following sources:
- • Directly from you or your agents. For example, from forms you complete or documents you provide us with related to the services for which we are engaged.
- • Indirectly from you or your agents. For example, through information we collect from our clients in the course of providing services to them.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
- • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery.
- • To provide you with information, products or services that you request from us.
- • To process your requests, transactions, and payments and prevent transactional fraud.
- • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
- • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
- • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
- • Our affiliates.
- • Service providers.
- • Third parties to whom you or your agents authorize us to disclose your personal information in connection with the products or services we provide to you.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category E: Biometric information.
Category F: Internet or other similar network activity.
Category H: Sensory data.
Category I: Professional or employment-related information.
Category K: Inferences drawn from other personal information.
We disclose your personal information for a business purpose to the following categories of third parties:
- • Our affiliates.
- • Service providers.
- • Third parties to whom you or your agents authorize us to disclose your personal information in connection with the products or services we provide to you.
In the preceding twelve (12) months, we have not sold any personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information.
This section describes your rights as a consumer under California law and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
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 twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- • 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 or selling that personal information.
- • The categories of third parties with whom we share that personal information.
- • The specific pieces of personal information we collected about you (also called a data portability request).
- • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- ○ Sales, identifying the personal information categories that each category of recipient purchased;
and - ○ Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
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 confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise fulfill our contractual obligations under any contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Identify, debug or repair errors that impair existing intended functionality of our systems.
- Exercise our right to free speech, or to safeguard the rights of other consumers to exercise any rights afforded to them by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- • Calling us toll-free at 1-888-995-2265; or
- • Mailing a written request addressed to: Western Alliance Bank, CCPA Privacy Inquiries – Client Service, 1 East Washington Street, Suite 1400, Phoenix, AZ 85004.
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:
- • Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or are acting as an authorized representative.
- • Describe your request in detail so that we can promptly perform an evaluation and provide you with a response.
Prior to honoring any request we are required confirming that the personal information we have collected relates to you, verifying your identity or confirming that you are authorized to submit the request on another’s behalf. Making a verifiable consumer request does not require you to create an account with us.
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 endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. In the event we are unable to respond within 45 days, we may request that this deadline be extended for an additional 45 days. If an extension is granted, we will inform you of the reason and extension period in writing.
The scope of personal information we are required to disclose is limited to the data collected over the 12-month period directly preceding the date we received a verifiable request. The response we provide will also explain the reasons we cannot comply with a request, where applicable. For data portability requests, we will select a format to provide your personal information to you that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the CCPA, we will not:
- • Deny you goods or services.
- • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- • Provide you a different level or quality of goods or services.
- • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
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 notice on our website and update the notice’s effective date.
Contact Information
If you have any questions or comments about this notice, 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 California law, please do not hesitate to contact us at:
Mail:
Western Alliance Bank
CCPA Privacy Inquiries – Client Service
1 E. Washington Street, Suite 1400
Phoenix, AZ 85004
Phone:
1-888-995-2265