Mobile Privacy Policy Disclosure

Clay County State Bank Mobile Privacy Policy
General	We want you to understand the types of information we access, collect, use, store, and transfer (“Process”) through our mobile banking application (our “App”), including when you are using the App as well as when the App is running in the background. Be assured the App Processes your information only for the following limited purposes: to provide you with digital banking and related services (“Services”); to maintain & improve our Services; to ensure our Services are working as intended, such as tracking outages or troubleshooting issues that you report to us; to develop new Services and features; to provide you with personalized Services and content; to measure the performance of our App and Services; to communicate with you; to protect our Institution and customers from fraud, abuse, security risks, and technical issues; and any other specific purposes referenced or described in the Clay County State Bank Mobile Privacy Policy. We will always ask for your consent before using your information for a purpose that isn’t covered in the Clay County State Bank Mobile Privacy Policy.
Information you enter or provide to us	When you register, access, and use the App, you provide us with personal and sensitive information that includes your name, password, government identifiers like your social security number (SSN) or drivers’ license number, phone number, email address, physical or mailing address, financial information, payment information, payment card information, and credit information.

Clay County State Bank Mobile Privacy Policy

General

We want you to understand the types of information we access, collect, use, store, and transfer (“Process”) through our mobile banking application (our “App”), including when you are using the App as well as when the App is running in the background. Be assured the App Processes your information only for the following limited purposes:

to provide you with digital banking and related services (“Services”);
to maintain & improve our Services;
to ensure our Services are working as intended, such as tracking outages or troubleshooting issues that you report to us;
to develop new Services and features;
to provide you with personalized Services and content;
to measure the performance of our App and Services;
to communicate with you;
to protect our Institution and customers from fraud, abuse, security risks, and technical issues;
and any other specific purposes referenced or described in the Clay County State Bank Mobile Privacy Policy.

We will always ask for your consent before using your information for a purpose that isn’t covered in the Clay County State Bank Mobile Privacy Policy.

Information you enter or provide to us

When you register, access, and use the App, you provide us with personal and sensitive information that includes your name, password, government identifiers like your social security number (SSN) or drivers’ license number, phone number, email address, physical or mailing address, financial information, payment information, payment card information, and credit information.

Data Collection & Telemetry While Using the App
Other information we collect as you use our App	The information we collect includes unique identifiers, browser type and settings, device type and settings, operating system, mobile network information including carrier name and phone number, and application version number. We also collect information about the interaction of your other apps, browsers, and devices with our digital banking services. Additionally and as described in more detail below, your device may periodically contact our backend digital banking systems to provide information about your device and connection to the digital banking services. This information may include things like your device type and carrier name, crash reports, which apps you’ve installed, and, depending on your device settings, other information about how you’re using your mobile device.
Your activity	We collect information about your activity in connection with our App, in order to better understand: your interactions and behavior associated with App content and features; the ways in which you are moving through and navigating the App; the Services and features that are most valuable to you; areas or stages of the App where you may disengage or get stuck; and your typical patterns of behavior in connection with the App. The activity information we collect may include: logs, tags, reporting, and other analytics reflecting your specific use of screens, workflows, buttons, and features; logs, tags, reporting, and other analytics reflecting your navigation through, engagement with, and disengagement with the App; haptic information related to your use of your device (e.g. swipes, taps); your financial, payment, and transaction activity and history (including purchase history); and your navigation to or activity on third-party sites and apps linked to our App. This information enables us to improve, modify, or expand the services, features, and experience delivered through the App as well as to support in-App messaging, deliver user guides and polls, and optimize performance of the App. Additionally, and in particular, this information also enables us to detect and flag suspicious or potentially fraudulent activity.
Your device and other apps	We access and collect information related to your device and other Apps along with associated data. This information may be collected both while you use the App and while the App is running in the background or is otherwise not in use. Information we process concerning your device and other Apps includes: your device type; your device ID; other available device identifiers; your device operating system; network and IP address information; your cellular data carrier; and device and app diagnostic information. Additionally, if our App needs to access protected features of your device, then you will have an opportunity to provide consent. In the event that you decline to provide express consent, then the App will not be permitted to access data gated by your device’s permissions model. Without your express consent, the App will not allow use of the protected feature or related data. If and when our App accesses your: phone or contact book data; device location; or other background restricted permissions, then all related data is treated as personal or sensitive data subject to the Clay County State Bank Mobile Privacy Policy.

Data Collection & Telemetry While Using the App

Other information we collect as you use our App

The information we collect includes unique identifiers, browser type and settings, device type and settings, operating system, mobile network information including carrier name and phone number, and application version number. We also collect information about the interaction of your other apps, browsers, and devices with our digital banking services.

Additionally and as described in more detail below, your device may periodically contact our backend digital banking systems to provide information about your device and connection to the digital banking services. This information may include things like your device type and carrier name, crash reports, which apps you’ve installed, and, depending on your device settings, other information about how you’re using your mobile device.

Your activity

We collect information about your activity in connection with our App, in order to better understand:

your interactions and behavior associated with App content and features;
the ways in which you are moving through and navigating the App;
the Services and features that are most valuable to you;
areas or stages of the App where you may disengage or get stuck; and
your typical patterns of behavior in connection with the App.

The activity information we collect may include:

logs, tags, reporting, and other analytics reflecting your specific use of screens, workflows, buttons, and features;
logs, tags, reporting, and other analytics reflecting your navigation through, engagement with, and disengagement with the App;
haptic information related to your use of your device (e.g. swipes, taps);
your financial, payment, and transaction activity and history (including purchase history); and
your navigation to or activity on third-party sites and apps linked to our App.

This information enables us to improve, modify, or expand the services, features, and experience delivered through the App as well as to support in-App messaging, deliver user guides and polls, and optimize performance of the App. Additionally, and in particular, this information also enables us to detect and flag suspicious or potentially fraudulent activity.

Your device and other apps

We access and collect information related to your device and other Apps along with associated data. This information may be collected both while you use the App and while the App is running in the background or is otherwise not in use.

Information we process concerning your device and other Apps includes:

your device type;
your device ID;
other available device identifiers;
your device operating system;
network and IP address information;
your cellular data carrier; and
device and app diagnostic information.

Additionally, if our App needs to access protected features of your device, then you will have an opportunity to provide consent. In the event that you decline to provide express consent, then the App will not be permitted to access data gated by your device’s permissions model. Without your express consent, the App will not allow use of the protected feature or related data.

If and when our App accesses your:

phone or contact book data;
device location; or
other background restricted permissions, then all related data is treated as personal or sensitive data subject to the Clay County State Bank Mobile Privacy Policy.

Restricted Device Feature	Processing Purpose & Application Function
Use of Fingerprint	We collect information about your biometric identifiers when you use our App, which enables us to streamline your authentication and login experience and access our Services with less friction.
Precise or Fine Location	We collect information about your location when you use our App, which helps us offer features like search results for branch and ATM locations, credit card controls, and messages based on your general location.
Read or access Contacts, Contacts List, or phone log	We collect information about your contacts when you use our App, which enables us to facilitate requested P2P and other payment transactions.
Access Camera or Pictures/Photos	We collect information from your device’s camera and photos when you use our App, which enables use of mobile check deposit and other image scanning or capturing features of the App

Information Sharing, Cryptography & Governance
Sharing your information	Our App will only share information with third-parties with your consent, for the purpose of providing you with Services, or for the other ancillary purposes described in the Clay County State Bank Mobile Privacy Policy. Our App Processes your financial or payment information or government identification numbers and will never publicly disclose any personal and sensitive user data related to financial or payment activities or any government identification numbers. Our App may Process non-public phonebook or contact information, and we don’t allow unauthorized publishing or disclosure of your or others’ non-public contacts. Our app includes third-party code and SDKs that may collect personal and sensitive user data solely for the purposes described in the Clay County State Bank Mobile Privacy Policy. All third-party providers of code and SDKs will Process your data in accordance with the Clay County State Bank Mobile Privacy Policy and all applicable law and standards. Neither we nor our third-party providers will ever sell your personal and sensitive data Processed by the App. The App may also transfer data as necessary for legal reasons including compliance with a valid governmental request, applicable law, or as part of a merger or acquisition with legally adequate notice to users. The App handles all personal and sensitive user data securely, including transmitting it using modern cryptography.
Policy Governance	Approved August 10, 2023

Information Sharing, Cryptography & Governance

Sharing your information

Our App will only share information with third-parties with your consent, for the purpose of providing you with Services, or for the other ancillary purposes described in the Clay County State Bank Mobile Privacy Policy.

Our App Processes your financial or payment information or government identification numbers and will never publicly disclose any personal and sensitive user data related to financial or payment activities or any government identification numbers.

Our App may Process non-public phonebook or contact information, and we don’t allow unauthorized publishing or disclosure of your or others’ non-public contacts.

Our app includes third-party code and SDKs that may collect personal and sensitive user data solely for the purposes described in the Clay County State Bank Mobile Privacy Policy. All third-party providers of code and SDKs will Process your data in accordance with the Clay County State Bank Mobile Privacy Policy and all applicable law and standards.

Neither we nor our third-party providers will ever sell your personal and sensitive data Processed by the App.

The App may also transfer data as necessary for legal reasons including compliance with a valid governmental request, applicable law, or as part of a merger or acquisition with legally adequate notice to users.

The App handles all personal and sensitive user data securely, including transmitting it using modern cryptography.

Policy Governance

Approved August 10, 2023

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