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Privacy Policy

Revised: 10/2020

1. Overview

This Privacy Policy explains how Neighborhood Trust Financial Partners, LLC and its subsidiaries, partners and affiliates (“we”, “us”, or “Neighborhood Trust”) collects, protects, uses and shares information about you when you use https://neighborhoodtrust.org/ (“Website”) and any of our services (collectively with the Website, the “Services”), and whether you access the Services directly or through a third party, which third parties may include your employer. This Privacy Policy is incorporated by reference in, and forms a part of, our Terms of Service, available at https://neighborhoodtrust.org/terms-of-service/ (the “Terms of Service”). In the event of any conflict between the provisions of this Privacy Policy and the Terms of Service, the applicable provisions of this Privacy Policy shall control.

Neighborhood Trust takes your privacy very seriously. Please read this notice carefully to understand what we do. If you do not want information about you to be used as described in this Privacy Policy, or if you disagree with any portion of this Privacy Policy or our information practices, you must stop, or refrain from, using the Services.

If you have any questions or concerns about our information practices, please contact us at [email protected] or as otherwise set forth in the “How to Contact Us” section below.

Scope

This Privacy Policy applies to information that we collect through the Website, and any of our other websites that provide a link to this Privacy Policy, as well as information collected through any of our products and services that are accessible via the Website, from you as an individual user (“you”) of the Website.

Please understand that, except as specifically described below, this Privacy Policy does not apply to information collected by third parties, such as other companies, or third-party websites or mobile applications, even if any are linked to or accessible through the Services. Further, any Services received in person may be subject to additional privacy terms and conditions, which will be provided to you in connection with such in-person Services. To the extent any provisions of this Privacy Policy conflict with any such privacy terms provided in connection with in-person Services, the provisions of such privacy terms shall control.

2. Information We Collect

Information You Provide

Throughout the course of using the Services, Neighborhood Trust may collect and store information you enter on our Website or information provided to us during a counseling session or in some other manner in connection with our provision of the Services. This includes Personally Identifiable Information (“PII”), including but not limited to:

  • Social security numbers
  • Address and contact information
  • Date of birth
  • Demographic information
  • Employer
  • Income and expenses
  • Bank account and balance information
  • Information from the credit reporting agencies

Passive Data Collection

As a general matter, we automatically collect certain information based on your use of and behavior on the Website and in connection with the Services. We use this information to analyze our customers’ demographics, interests, and behavior to better understand and serve you and our customer base. We also analyze this information for security purposes, to protect the Services and customer information that we hold.

If the information we collect automatically identifies you or could be reasonably used to identify you, then it is treated as PII. Also, if we directly combine any information gathered through passive means with PII, we treat the combined information as PII under this Privacy Policy. But in many cases, the information that we collect passively is only used in de-identified or aggregated forms, which do not identify any individual.

We collect passive data in the following ways:

Mobile Device Information. When you download or use our Website from a mobile device, we receive information about your mobile device. We register your device, and we may use the identifier to send you push notifications about your transactions via the Services.

  • Log Files. Like most websites, we automatically receive and record certain information about our customers’ behavior on our Website and when using our Services. Our servers automatically gather technical information about our Website traffic and store it in log files. This information includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and other clickstream data. We aggregate this information with other pieces of information to analyze trends, to administer and improve the Services, for example to understand customers’ use of the Website and to make inventory and purchasing decisions that will best serve our customer base. Information from log files may also be used to determine general location information such as city, state or geographic area.
  • Hotjar. In accordance with the terms of this Privacy Policy, we use a technology service called Hotjar in order to better understand our users’ needs and to optimize this service and experience. It helps us better understand our users’ experience (e.g., how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (including, but not limited to, the device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and preferred language used to display our website. Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match the information with other data with respect to an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link.
  • Cookies, Web Beacons and Similar Technologies. A cookie is a small text file that is stored on a computer for record-keeping or tracking purposes. Web beacons (also known as pixel tags or clear GIFs), are graphics that can record whether a person has accessed particular content. We use these and other similar technologies on the Website and in connection with our Services. Cookies we utilize may include session cookies, persistent cookies, or similar technologies. A session cookie expires when you close your browser. A persistent cookie is stored on your computer or device for an extended period of time. You can remove persistent cookies by following the directions provided in your Internet browser’s “help” menu. You may also configure your browser to prevent cookies from being set on your computer. (Instructions should be provided in documentation for your browser.) If you reject cookies, your ability to use the Website and Services may be limited, and you may not be able to use certain features of the Website or Services. We may use cookies for the following purposes:
  • Essential cookies. Essential cookies are required for providing you with features or services that you have requested. For example, certain cookies enable you to log into secure areas of our Services. Disabling these cookies may make certain features and services unavailable.
  • Functional cookies. Functional cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
  • Performance/analytical cookies. Performance/analytical cookies allow us to understand how visitors use our Services such as by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/analytical cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising.

To find out more information about cookies, including information about how to manage and delete cookies, please visit https://www.allaboutcookies.org/.

We may use web beacons or similar technologies, which help manage content on the Website and in the Services by tracking what content is effective. These technologies may be used to track the online movements of customers, but in contrast to cookies, which are stored on a computer hard drive, these technologies are embedded in the Website.

We may also use web beacons in our HTML-based emails to let us know which emails recipients have opened. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

Third Party Advertisers

Third-party advertising companies may also use cookies, web beacons or similar technologies on the Website to collect information (such as click stream information) during your visits to our Website and other websites, as well as during your use of our Services, in order to help us provide you with advertisements about our Services that we believe are likely to be of interest to you.

If you prefer not to have your information used for the purpose of serving you personalized advertising, you may also learn more about your choices or change your preferences at https://optout.aboutads.info, https://optout.networkadvertising.org, https://preferences-mgr.truste.com, from Google at https://www.google.com/settings/ads or https://policies.google.com/technologies/partner-sites, from Facebook at https://www.facebook.com/about/ads or https://www.facebook.com/policy.php, or if you are located in the European Union at https://www.youronlinechoices.eu/.

3. How We Use Your Information

We may use information that we collect about you to:

  • Deliver the Services that you have requested;
  • Manage your account and provide you with customer support;
  • Perform research and analysis about your use of, or interest in, our Services or content available thereby, or products, services, or content offered by others;
  • Aggregate data such as the anonymous personal financial data you may provide via the Website. This aggregate information does not identify particular Users or otherwise allow anyone to recover sensitive information about individual Users.
  • Communicate with you by e-mail, postal mail, telephone, and/or mobile devices about products or services that may be of interest to you;
  • Enforce our terms and conditions;
  • Manage our business; and
  • Perform functions as otherwise described to you at the time of collection.

In addition, we may use aggregate, statistical, and de-identified data, which does not specifically identify any individuals, for any purpose.

4. How We Disclose Your Information

Disclosure to Third Parties: Other than the exceptions stated below, Neighborhood Trust pledges to not transfer your PII to any third party. We share PII and other information collected via our Services with other companies or individuals as follows:

  • When they help us operate our business, such as vendors and cloud providers who assist us with data storage, customer communication, outcome tracking, and analytics;
  • With third parties if we have a good faith belief that access, use, or disclosure of such PII is reasonably necessary to (a) satisfy applicable law, regulation, legal process or an enforceable governmental request, (b) enforce the applicable Terms of Service or this Privacy Policy, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of Neighborhood Trust, its Users or the public, including as required or permitted by applicable laws or valid legal orders of a governmental authority of competent jurisdiction.
  • With any of our subsidiaries, joint ventures, or other companies under common control with us, in which case we will require them to honor this Privacy Policy or terms which provide terms and conditions which are no less than stringent than those contained in this Privacy Policy. Additionally, in the event we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your PII may be among the assets transferred.
  • If requested, we may share your name with the organization that has connected you with the Services, but will not share your individual financial information.
  • Your financial information may be aggregated with others’ financial information and shared with the organization that has connected you with this service for reporting and evaluation purposes only.
  • PII that has been anonymized and aggregated may be shared with third parties for research, evaluation, and other internal business purposes.
  • We do not sell your PII to third parties.

When you are no longer our customer, we may continue to share your information as described in this Privacy Policy, including as necessary to comply with applicable laws or valid legal orders of a government authority of competent jurisdiction.

5. Third Party Websites

In the event that that we provide links to other websites that we do not control, whether or not those other websites refer to our branding, this Privacy Policy does not apply to those other websites. Visitors to those websites are advised to carefully read the policies on those individual websites.

6. Children’s Privacy

Our Services are not intended for or directed toward children under 13 years of age, and children should not use the Services for any purpose. If we learn that we have collected or received PII from a child under 13 years of age, we will delete that information

If you are the parent or legal guardian of a child under 13 years of age who has registered on the Website or you believe has otherwise provided PII to Neighborhood Trust, please contact us at [email protected] to have the account terminated and information deleted.

If you believe that we may have inadvertently collected any PII about a child aged 13 years or younger, please contact us at [email protected] or as provided in the “How to contact us” section below.

7. Your Choices

Accessing and requesting changes to your PII:

If you are a customer of Neighborhood Trust, you may review and change your PII through your customer account.

If you do not have a customer account with Neighborhood Trust, or if you cannot access or change any of your PII through your account, but you still wish to inquire about, access, correct, update or delete PII that we may hold about you, please email us at [email protected]. Please understand that, before responding to your request, we may ask you for additional information in order to verify your identity, or take other actions that we believe are appropriate in order to verify your identity.

Please also understand that we may not be able to alter or delete your PII and may retain information to provide you with requested services or fulfill obligations to you, for security reasons, if we are required under applicable law or regulations, for internal business use or for other valid reasons. We are also not obligated to comply with requests that are unreasonably burdensome or expensive, or with requests that would interfere with the rights of another individual. In some circumstances, we may charge a reasonable fee to fulfill your request.

Communications preferences:

If you would like to change the types of communications you receive from us or how you receive communications from us, or if you would like to opt out of promotional communications, you may do so at any time by updating the communication preferences provided in your customer account.

If you do not have a customer account, you may also use the unsubscribe links and instructions that will be present in any promotional emails or other communications that we send.

Please understand that, even if you opt out of marketing or promotional communications, we may continue to send non-promotional communications such as confirmations of transactions, changes to the Services or other information about your use of the Services.

“Do Not Track” Settings:

Our Website and Services are not at this time configured to read or respond to “do not track” settings or signals in your browser headings.

8. Notices to California Residents

We will not share your personal information with third parties for their independent business purposes or direct marketing purposes without first giving you the ability to provide affirmative consent to such sharing. If you have provided such consent, then California’s “Shine the Light” law permits you to request information regarding the disclosure of your Personal Information by us to a third party for the third party’s direct marketing purposes. To make such a request, please send an email to [email protected].

9. Notices to Vermont Residents

We will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures. Additional information concerning our privacy policies can be found at https://neighborhoodtrust.org/privacy-policy/ or call 800-927-8772.

You have the right to opt-out of the disclosure of any of the nonpublic personal information as stated above by notifying Neighborhood Trust in writing. In some instances, we may no longer be able to provide our services to you.

Please see the contact information at the bottom of this document to opt-out.

10. Security

Information security: We take reasonable technical and physical security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. These include encryption, internal reviews of our data collection, best physical and digital storage and processing practices and security measures, keeping up to date with patches on all relevant software, as well as working with reliable cloud providers to guard against unauthorized access to systems.

Our failure to enforce any provision of these Terms of Service shall not be construed as a waiver of that provision or any other provision. No waiver shall be effective against us unless made in writing, and no such waiver shall be construed as a waiver in any other or subsequent instance. Except as expressly agreed by us and you in writing, these Terms of Service and the Privacy Policy constitute the entire agreement between you and us with respect to the subject matter, and supersedes all previous or contemporaneous agreements, whether written or oral, between the parties with respect to the subject matter. These Terms of Service and the Privacy Policy will inure to the benefit of our successors, assigns, licensees, and sublicenses.

11. Changes to this Privacy Policy:

We may change this Privacy Policy from time to time. The most recent version of the Privacy Policy will always be posted on the Website, with the effective date posted at the top of the Privacy Policy. We may revise and update this Privacy Policy if our practices change, as technology changes, or as we add new services or change existing ones. If we make material changes to our Privacy Policy or how we handle your PII, or if we are going to use any PII in a manner that is materially different from that stated in our Privacy Policy at the time we collected such information, we will try to notify you of such changes reasonably in advance. By using our Website or Services after the effective date, you are deemed to consent to our then-current Privacy Policy.

12. How to Contact Us:

If you have questions, concerns or feedback regarding this Privacy Policy or our information practices, you can send an email to us at [email protected] or by postal mail at:

Neighborhood Trust Financial Partners
530 West 166th St, 4th floor
New York, NY 10032
Attn: Legal Department

The Neighborhood Trust Privacy Policy can also be found at https://neighborhoodtrust.org/privacy-policy/