Privacy Notice

Introduction

Protecting your privacy is important to Choice Bank ¹ (“Choice Bank,” “we,” “us,” or “our”) and our employees. We want you to understand what information we collect, how we use it, and the steps we take to protect it. In order to provide our customers with a broad range of financial products and services as effectively and conveniently as possible, we use technology and established internal procedures to manage and maintain customer information.

This Privacy Notice describes our practices and how we comply with applicable U.S. federal and state laws regarding the collection, use, disclosure, retention, and protection of personal information in connection with the financial products and services we provide to consumer and business customers in the United States, and in connection with our website, digital channels, and online services. Certain products, services, online platforms, or account relationships may be subject to additional terms, disclosures, or agreements.

¹Choice Bank is a division of Choice Financial Group.

1. What Information We Collect

We may collect personal information about you from the following sources:

• Information you provide directly — on applications, loan or account forms, web forms, or in communications with us
• Information from your transactions — account activity, payment history, transaction data generated in your relationship with us
• Information from third parties — consumer reporting agencies (such as credit bureaus), affiliates, service providers, and other companies as permitted by law
• Information collected automatically — through your use of our website, online banking, and mobile banking services, including through cookies and similar technologies

Depending on the products or services you use, the categories of personal information we collect include:

Categories of Information We Collect

Category	Examples
Identifiers	Name, postal address, email address, phone number, Social Security number, Tax ID number, driver’s license number, account number, IP address, device identifier, cookie ID
Financial Information	Account balances, payment history, overdraft history, transaction activity, credit history, credit scores, income
Commercial Information	Products and services obtained or considered, account relationship history
Internet/Network Activity	Pages visited on bankwithchoice.com, links clicked, browser type, device type, referring URL, time spent, session activity
Geolocation Data	General location inferred from IP address
Audio and visual	Call recordings (where permitted by law and disclosed); images captured by security systems at branch locations
Professional / employment	Information provided in job applications submitted through our careers portal
★ Sensitive Personal Information	Social Security number; financial account numbers and login credentials; driver’s license or government-issued ID number

2. How We Use Personal Information

Choice Bank collects and uses personal information in the ordinary course of operating a bank and providing financial services to consumer and business customers. We use the information we collect to:

• Provide, maintain, and service your accounts, loans, and other financial products and services
• Process transactions and payments
• Verify your identity and evaluate applications
• Communicate with you regarding your accounts, applications, transactions, and customer service requests
• Protect against fraud, unauthorized transactions, claims, and other liabilities
• Comply with legal, regulatory, reporting, examination, audit, and recordkeeping obligations
• Improve the administration, functionality, security, and performance of our operations, website, and online services
• Deliver targeted marketing and advertising for Choice Bank’s own products and services — including through third-party advertising platforms when you visit bankwithchoice.com
• Process job applications submitted through our careers portal

3. Information Sharing

(Federal Privacy Notice — GLBA)

Federal law gives consumers the right to limit some but not all sharing of nonpublic personal information (“NPI”). The table below lists the reasons financial companies can share NPI, whether Choice Bank chooses to share, and whether you can limit this sharing. The full disclosure can be found here, and is provided to satisfy the requirements of the Gramm-Leach-Bliley Act (GLBA) and Regulation P.

 

Reason for Sharing	Does Choice 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	Yes	No
For our affiliates’ everyday business purposes — information about your creditworthiness	No	We don’t share
For nonaffiliates to market to you	No	We don’t share

 

3.1 Definitions

Term	Definition
Affiliates	Companies related to Choice Bank by common ownership or control. Our affiliates include financial companies, such as Choice Financial Holdings, Inc.
Nonaffiliates	Companies not related by common ownership or control. Choice Bank does not share with nonaffiliates to market to you.
Joint Marketing	A formal agreement between nonaffiliated financial companies that together market financial products or services. Choice Bank does not engage in joint marketing.

 

3.2  What Sharing Is and Is Not Permitted 

We do not sell, rent, or share your nonpublic personal information with nonaffiliated third parties for their own marketing or promotional purposes. We may disclose NPI to third parties to assist us in servicing your accounts, to government entities in response to legal process, and to consumer reporting agencies. All such disclosures are made only as permitted or required by law.

If you close your account(s) or become an inactive customer, we will continue to adhere to the privacy practices described in this Privacy Notice, subject to applicable law and our record retention practices.

 

3.3 FAST Act Annual Notice Exception 

Because Choice Bank does not share NPI in ways that require an opt-out under GLBA §§ 1016.13, 1016.14, or 1016.15, and our privacy practices have not changed since our last notice, Choice Bank qualifies for the FAST Act annual notice exception. We are not required to deliver an annual privacy notice while these conditions are met. This qualification is assessed and documented annually.

4. Confidentiality and Security

We take steps to safeguard your personal information. We restrict access to your personal and account information to those employees, agents, and service providers who need to know that information in order to provide products or services to you or to perform legitimate business, compliance, security, or operational functions.

We maintain physical, electronic, and procedural safeguards designed to protect your personal information and to comply with applicable federal standards, including the FTC Safeguards Rule. Our safeguards include:

• Encryption of sensitive data in transit and at rest
• Multi-factor authentication for account and system access
• Access controls that limit employee access to personal information to a need-to-know basis
• Regular security testing, vulnerability assessments, and monitoring of our information security systems
• Physical security measures at branch locations and data facilities
• Employee training on privacy and information security obligations

Employees who violate our privacy or information security requirements may be subject to disciplinary action, subject to applicable policies and law.

Although we use safeguards designed to protect information, no method of transmission over the Internet or method of storage is completely secure. Accordingly, we cannot guarantee absolute security.

In the event of a data breach that affects your personal information, we will notify you as required by applicable law, including California’s data breach notification law and applicable federal banking regulatory requirements.

5. California Privacy Rights

This section applies to California residents

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), gives you specific rights regarding your personal information. This section describes those rights and how to exercise them. Note that personal information subject to the federal Gramm-Leach-Bliley Act (GLBA) — such as NPI collected in connection with your bank accounts and financial products — may have a more limited scope of CPRA rights. Information collected in other contexts, such as through our website and marketing cookies, is subject to full CPRA protections.

 

5.1 Your Rights

Right	What it means	How to exercise
Right to Know / Access	Request the categories and specific pieces of personal information we have collected about you, the categories of sources, the business or commercial purposes, and the categories of third parties to whom it was disclosed	Submit a verified DSR — see Section 6
Right to Delete	Request deletion of personal information we hold about you, subject to certain exceptions such as legal obligations, fraud prevention, and transaction completion	Submit a verified DSR — see Section 6
Right to Correct	Request correction of inaccurate personal information we maintain about you	Submit a verified DSR — see Section 6
Right to Opt Out of Sale / Sharing	Opt out of the sharing of your personal information with third-party advertising partners for cross-context behavioral advertising (our marketing cookies constitute ‘sharing’ under CPRA)	Submit a verified DSR — see Section 6
Right to Limit Sensitive PI	NoLimit our use and disclosure of sensitive personal information (e.g., account login credentials) to purposes necessary to provide the requested service	Submit a verified DSR — see Section 6
Right to Non-Discrimination	We will not deny goods or services, charge different prices, or provide a different quality of service because you exercised any of these rights	This right is automatic — no request needed

6. How to Submit a Privacy Rights Request

6.1 Intake Channels

To exercise your privacy rights, you may submit a request through any of the following channels. We will confirm receipt within 10 business days and respond within 45 calendar days (or up to 90 days if an extension is needed).

Channel	How to reach us
Phone (toll-free)	Call (888) 894-1357 and ask for Privacy Rights (available during business hours)
Email	help@bankwithchoice.com (indicate Privacy Rights)

 

6.2 Identity Verification 

To protect your information, we will verify your identity before processing access, delete, or correct requests. We will not require notarized documentation as the sole method of verification.

• Customers: Identity is verified through our secure online banking portal, by correctly responding to questions asked as part of the verification process, or by matching information you provide against records we maintain.
• Non-customers: Identity is verified by matching information you provide against records we maintain
• Authorized agents: Must provide proof of your signed written authorization permitting them to act on your behalf — we will not require notarized documentation as the sole method

6.3 Response Timeline 

We will confirm receipt of your request within 10 business days. We will provide a complete response within 45 calendar days of receipt. If we need additional time (up to 45 more days, for a maximum of 90 days total), we will notify you of the extension and the reason before the initial 45-day period expires.

7. Internet and Online Privacy

When you visit our website, use online banking, submit information through online forms, interact with our digital tools, or otherwise use our online services, we may collect certain technical and usage information as part of operating, securing, and improving those services.

7.1 Browsing Our Website

When you visit bankwithchoice.com to view pages, review product information, or use online tools, you may do so without directly providing personal information. We may, however, use standard technologies to collect information about website usage for security, analytics, and operational improvement. This may include your Internet service provider, referring website, browser type, device information, access dates and times, pages visited, and general activity on the site.

 

7.2 Cookies and Tracking Technologies

We use cookies, pixels, tags, and similar technologies on bankwithchoice.com. The types of cookies we use include:

• Strictly necessary cookies — required for the website to function; cannot be disabled
• Analytics cookies — help us understand how visitors interact with our website (e.g., Google Analytics)
• Marketing/advertising cookies — used to deliver targeted advertisements about Choice Bank’s products and services on our website; these cookies share information with our advertising partners
• Preference cookies — remember your settings and preferences for future visits

 

7.3 Email and Online Communications 

If you send us an email, submit a form, or otherwise communicate with us electronically, we may use the information you provide to respond to your request, provide customer service, maintain records of the communication, and satisfy legal or regulatory obligations. We will not use your email address for unsolicited marketing communications.

 

7.4 Online and Mobile Banking Security 

When you use our online or mobile banking services, Choice Bank and the service providers that support those services may have access to information necessary to authenticate you, maintain your account, process transactions, provide requested services, and protect against fraud and unauthorized access. We use encryption and secure access controls to protect information transmitted through our online services.

You also play an important role in protecting your information. Please safeguard your login credentials, use strong passwords, avoid sharing access information, sign off after using online services, keep your devices and software current, and remain alert to phishing and suspicious activity.

 

7.5 Text Messages and SMS Communications

If you enroll in text message or SMS communications from us, we may use your mobile number to send account alerts, fraud notifications, authentication codes, customer care messages, or other messages related to your banking relationship, in accordance with applicable law and your consent choices.

Mobile information — including phone numbers, opt-in data, and consent records — will not be shared, sold, rented, or disclosed to third parties or affiliates for their own marketing or promotional purposes, except as required by law, necessary to deliver the messaging service, or otherwise permitted by applicable law. Message and data rates may apply. You may opt out of nonessential text messages by following the instructions provided in the message or by contacting us using the information in Section 13.

 

7.6 Third-Party Links

Our website or online services may contain links to third-party websites that are not controlled by us. This Privacy Notice does not apply to third-party websites. We are not responsible for the privacy, security, content, or practices of those third parties. You should review the privacy notices of any external sites you visit.

8. Sensitive Personal Information

Certain categories of personal information are classified as Sensitive Personal Information (SPI) under CPRA. We collect the following SPI:

• Social Security numbers and government-issued ID numbers — collected when you apply for accounts, loans, or other financial products
• Financial account numbers and account login credentials — collected in connection with your banking relationship and online banking access
• Driver’s license numbers — collected when required for identity verification

 

We use SPI only as necessary to:

• Provide the financial products and services you have requested
• Verify your identity and prevent fraud
• Comply with legal, regulatory, and reporting obligations

We do not use SPI for targeted advertising or for purposes other than those disclosed above. California residents have the right to request that we limit the use and disclosure of their SPI to these purposes. To exercise this right, submit a request through the channels in Section 6.1.

9. Do Not Sell or Share My Personal Information

Choice Bank does not sell your personal information for money to third parties.

10. Maintaining Accurate Information

We continually strive to maintain complete and accurate information about you and your accounts. If you believe that our records contain inaccurate or incomplete information about you, please notify us promptly using the contact information in Section 13. We will review your concern and, where appropriate, correct inaccuracies as reasonably practicable and in accordance with applicable law.

If you believe we have furnished inaccurate information about your account to a consumer reporting agency, please notify us in writing at the address in Section 12. To help us investigate, please include your complete name, current address, telephone number, account number, the type of account involved, the specific item in dispute, and the reason you believe the information is inaccurate. We will review the matter and take any corrective action required by applicable law.

11. Children’s Privacy

Our website and services are not directed to children under the age of 13, and we do not knowingly collect personally identifiable information online from children under 13 except as permitted by law. If we learn that we have collected such information inconsistently with applicable law, we will take steps to address the issue in accordance with our legal obligations.

12. Contact Information

If you have questions about this Privacy Notice, want to exercise your privacy rights, or have concerns about our data practices, please contact us:

Choice Financial Group – Privacy Office

 

Mailing Address	4501 23rd Avenue S, Fargo, ND 58104
Phone (Privacy Rights)	(888) 894-1357 — ask for Privacy Rights
Email	help@bankwithchoice.com

13. Changes to This Privacy Notice

We may amend or update this Privacy Notice from time to time to reflect changes in our practices, operations, technology, legal requirements, or other relevant factors. Any updated version will be posted at bankwithchoice.com with a revised effective date.

Where required by law, we will provide additional notice or obtain any required consent before making material changes. Material changes to our GLBA sharing practices may require re-delivery of a privacy notice in accordance with Regulation P.