Privacy Policy

Effective Date: January 26, 2023

Table of Contents:

1. Introduction
2. Scope
3. Definitions
4. How We Collect Information
5. Information We Collect
6. App Permissions
7. How We Use Information We Collect
8. With Whom Do We Disclose Information
9. Your Rights
10. Exercising Your Rights
11. How Long We Retain Personal Information
12. Security and Protection of Personal Information
13. Children and Minors
14. Cookies / Website Usage
15. Do Not Call Policy
16. California’s “Shine the Light” Law
17. Changes
18. Contact Us

 

1. Introduction

Cathay Bank and its affiliates (“Cathay Bank”, “we,” “our,” or “us”) are committed to protecting the privacy and security of our clients, employees, and others. Our affiliates include companies with a Cathay name, financial companies such as Cathay Holdings LLC, and nonfinancial companies such as Cathay New Asia Community Development Corporation. Please read this Privacy Policy (this “Policy”) to understand what we do with personal information and your applicable rights. By using our Services or applying for a job at Cathay Bank, you agree to the terms and conditions of this Policy. 

 

2. Scope

This Policy describes how Cathay Bank handles personal information that is collected online through our website (the “Site”), our mobile application (the “App”) and other online resources, and offline through interactions with you to provide Cathay Bank services (collectively, the “Services”).

For more information on how Cathay Bank handles U.S. consumer customer non-public information, our U.S. Privacy Notice for Consumers is available here.

This Policy does not apply to third-party websites to which Cathay Bank may link. If you are a customer of a financial product or service offered by one of our service providers, that service provider should also have delivered to you a Customer Privacy Notice (Customer Privacy Notice), and which is also available here, that explains how they collect, use and disclose information about you and offers you certain choices with respect to the use and sharing of your personal information.

 

3. Definitions

• “Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
• “Sale” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.
• “Sell,” “selling,” “sale,” or “sold” does not mean: (1) disclosure of personal information pursuant to a court order, as required by a regulator, or as necessary to enforce legal rights; (2) use or disclosure of personal information when necessary to perform a business purpose; (3) use or intentional disclosure of personal information to a third party when directed by the consumer; (4) use of personal information when a consumer uses a business to intentionally interact with a third party; or (5) transfer of personal information as part of a merger, acquisition, or change of control of the Cathay Bank.
• “Share,” “shared,” or “sharing” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by a business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of the business in which no money is exchanged.
• “Share,” “shared,” or “sharing” does not mean: (1) disclosure of personal information pursuant to a court order, as required by a regulator, or as necessary to enforce legal rights; (2) use or disclosure of personal information when necessary to perform a business purpose; (3) use or intentional disclosure of personal information to a third party when directed by the consumer; (4) use of personal information when a consumer uses a business to intentionally interact with a third party; or (5) transfer of personal information as part of a merger, acquisition, or change of control of the Cathay Bank.
• “Affiliates” means companies related by common ownership or control. They can be financial and nonfinancial companies.
• “Non-affiliates” means companies not related by common ownership or control. They can be financial and nonfinancial companies.
• “Joint marketing” means a formal agreement between non-affiliated financial companies that together market financial products or services to you.

 

4. How We Collect Information

We collect information from a variety of sources. The following are categories of sources from which information is collected:

• Directly from you and other consumers through your interactions with and use of our Services, such as opening an account, applying for a loan, or providing employment or income information;
• Through our websites and mobile apps;
• From public sources of data including government agencies or public records;
• Through automated technologies and online browser tools, including the use of cookies, pixel tags and other technologies;
• From service providers or business partners, including advertising networks and data analytics providers; and

From time to time, we may use or augment the personal information we have about you with information obtained from other sources, such as public databases, fraud detection services and other third parties. We may also combine information we get from a third-party with information we already have, and we may combine information that we have collected offline with information we collect online.

If you choose to submit any personal information relating to other people, you represent that you have the authority to do so and permit us to use the information in accordance with this Policy. 

 

5. Information We Collect

The specific pieces of personal information that Cathay Bank collects, uses, and discloses depends on the Services you have or use with us. We collect the following categories of personal information:

• Contact information (such as name, email address, residence address, mailing address (if different from residence address), phone number, and emergency contact information).
• Personal identifiers (such as your Social Security number, Driver’s License number, Tax Identification number, and signature).
• Financial information (such as credit/debit card number, account balances, credit history, investment activity, income or source of funds, and payment/transaction history).
• Employment information (such as occupation, title, and prior employment history).
• Demographic information (such as age, date of birth, gender, and ethnicity).
• Personal characteristics (such as veteran status, marital status, sexual orientation, and familial information).
• Geo-location information (such as city/state, zip code, physical location or movements).
• Internet or other Electronic Network Activity information (such as browsing history, IP address, device type, operating system, and duration of user session).
• Inferences drawn from the above categories of personal information reflecting your preferences, characteristics, behaviors, attitudes and abilities.

In addition to the above categories, you may choose to provide us with additional pieces of information when you fill in a form, update or add information to your Cathay Bank Account, use Cathay Bank Services or interact with us in other ways. Cathay Bank may also collect information that could be considered as sensitive personal information, as defined under the CCPA, and/or non-personal information; however, Cathay Bank does not use such information for any purpose that would fall under the scope of the CCPA. For more information about how Cathay Bank uses non-personal information, please refer to our U.S. Privacy Notice for Consumers that available here.

In addition to the personal information that you choose to provide to us, we or our vendors (including analytics providers) may use a variety of tracking technologies that automatically or passively collect certain information whenever you visit or interact with our website. We have implemented Google Analytics Advertising for features such as dynamic remarketing, interest-based advertising, audience targeting, behavioral reporting, demographics and interests reporting, user segment analysis, device reporting, display advertising, and video ads reporting. Please note that Cathay Bank has enabled restricted data processing for Google, which restricts the way Google can use certain unique identifiers and other data processed to undertake certain activities. For more information on how Google Analytics uses data collected through the website or to opt out, visit: google.com/policies/privacy/partners.

 

6. App Permissions

Depending on your device or App permission settings, the App may have access to the following information from your mobile device:

1. Contacts (may have access to your contact information)
2. Location (may include precise or approximate location)
3. Stored information and photos/media/files (the App may be able to read, modify, or delete the contents of your USB storage)
4. Camera (may allow the App to take pictures and videos)
5. Wi-Fi connection information (view your Wi-Fi connections to connect and disconnect from Wi-Fi)
6. Phone (may directly call phone numbers)
7. Other information (for example, the App may be able to receive data from the Internet, prevent your device from sleeping, your network connections, and obtain full network access)

These App permission settings allow you to access or use certain features within the App. For example, in order to locate the nearest branch to you, the App may need access to your precise location. You may change your App permission settings. By changing your App permission settings, you may affect your ability to access or use certain features on the App.

Additionally, you may be able to log into the App using your device’s log in features such as using a passcode or your fingerprint. These device log in features are facilitated through your device and not Cathay Bank and we have no control over such features, which you can change by accessing your device settings and preferences.

 

7. How We Use Information We Collect

• Fulfillment and Responding to Requests. We may use personal information to fulfill your requests and perform our responsibilities under our contract with you, such as opening your account.
• Protection and Security. We may use personal information to protect the security and integrity of our website and Services, and for the protection of Cathay Bank, our users, and others.
• Responding to your inquiries. We may use personal information to respond to your questions.
• Payment. We use financial information to complete requested transactions. 
• Administrative Communications. We may use personal information to send you important information regarding our Services, such as changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important to us providing our Services, you may not opt-out of receiving such communications.
• Marketing Communications. We may use personal information you or third parties provide to show you more relevant and meaningful content based on your interests, including notifying you about our promotions, offers, and programs, or inviting you to participate in surveys. You may opt-out of receiving such communications, as described in “Item 9. Your Rights” section.
• Research. We may use personal information from you, our service providers, publicly available sources, financial practitioners and other third parties to conduct research, surveys, compile databases, and identify individuals to recruit in research programs.
• Online Services. We collect and use information about how you and other users interact with our online services through websites, apps, online tools in order to compile statistics for analysis of our Services and business.
• Internal Business Purposes. We may use personal information collected from the categories listed above for our internal business purposes, such as data analysis, audits, developing new offerings, furnishing our website, improving our Services, identifying usage trends and determining the effectiveness of our promotional campaigns.
• Legal and Regulatory. We may use personal information to comply with our legal or regulatory obligations (such as compliance with anti-money laundering procedures or tax reporting, to prevent fraud, suspicious or other illegal activities, or to defend ourselves in litigation and investigations and to prosecute litigations).

We may use personal information collected from any of the sources listed in “Item 4. How We Collect Information” section of this Policy for our internal business purposes, such as data analysis, audits, developing new products, enhancing our websites and apps, improving our Services, identifying usage trends and determining the effectiveness of our promotional campaigns.

We do not “sell” personal information for money. Under some state laws, the manner in which we may use cookies may constitute a “sale.” You may have the right to opt out of the sale of personal information depending on how your state defines “sale.”

We do not collect and or use sensitive personal information for any purpose that may fall under the scope of the CCPA. Notwithstanding the foregoing, we do not use your sensitive personal information to infer characteristics about you.

We may aggregate and/or de-identify data about customers and site visitors and use it for any purpose, including product and service development and improvement activities.

 

8. With Whom Do We Disclose Information

We may disclose certain categories of personal information listed above with the following categories of recipients for the purposes outlined in this Policy:

• Affiliated Entities. We may disclose your personal information to our subsidiaries, corporate affiliates, and entities with common branding, such as the Cathay Bank Foundation. These companies may use your information consistent with this Policy.
• Service Providers. We may disclose personal information with service providers that we hire to assist with running our everyday business, such as account maintenance, data analysis, online advertising, payment/credit card processing, infrastructure provision, IT services, customer service, email delivery services, mobile application store providers, and other similar services. We work with auditors, administrators, legal and tax advisors, IT consultants, software companies and other third-party service providers. We grant these providers access to personal information only to the extent needed for them to perform their functions, and require them, by written agreement, to protect the confidentiality and security of personal information and prohibit the disclosing of personal information other than for the specific purposes for which we disclosed the information to them. However, even with the service providers agreeing to abide by these restrictions, we cannot control how these service providers process your personal information.
• Commercial Partners. We may disclose personal information with unaffiliated third parties and other financial companies who partner with us to deliver the Services or for other commercial activities. Depending on the choices you have made, such as intentionally directed Cathay Bank to disclose your information to other financial companies, and the nature of the joint marketing or joint activity, these third parties may contact you regarding Cathay Bank-related programs, services, and promotions that may be of interest to you. If you would like further information about how personal information is handled at Cathay Bank and to submit a request to opt-out of the sale/share of personal information, please review “Item 9. Your Rights” section below.
• Business Transfers or Assignments. In the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings), we may transfer any and all information that we collect from site users or offline to the entity with whom any of the aforementioned dispositions is occurring.
• Law Enforcement; Emergencies; Compliance. We may disclose personal information about you to others as we believe to be appropriate: (i) under applicable law including laws outside your country of residence; (ii) to comply with legal process (iii) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (iv) to enforce our terms and conditions; (v) to protect our operations and property interest; (vi) to protect the rights, privacy, safety or property of Cathay Bank, our employees, users of our Services, you, or others; and (vii) to permit us to pursue available remedies or limit the damages that we may sustain. We have no obligation to notify you of such disclosures, except as required by applicable law.
• At your direction. We may use and disclose your personal information as you otherwise consent. For example, if you enter a promotion, the official rules may include provisions related to the sharing of personal information.

Cathay Bank may also disclose aggregate or de-identified data that is not personally identifiable to third parties for any purpose.

If you have a retail banking account with Cathay Bank, in the twelve months preceding the Effective Date above, Cathay Bank has not sold your personal information. 

If you have a commercial banking account with Cathay Bank, we may disclose your personal information with co-branded commercial card partners to facilitate a commercial relationship with the partner and Cathay Bank, to the extent that you intentionally direct us to do so. Commercial cards are those products issued to a business solely for the purpose of a business or commercial purpose.

You may exercise your right to opt out of the sale/share of your personal information to a co-branded commercial card partner by clicking here to complete the Personal Information Request and Opt-Out Form. Please note that the co-branded commercial card partner may already have some personal information about you as a result of your relationship with the partner and your choice to opt out of the sale/share of personal information will govern only Cathay Bank’s sharing of your personal information with the partner if such a transmittal is not based on your intentional direction to disclose your personal information and if such a partner is not a “service provider” under the CCPA.

 

9. Your Rights

You may have certain rights and choices regarding our processing of your personal information. Depending on your jurisdiction, applicable law may entitle you to additional consumer rights, including the right:

• To know the categories and/or specific pieces of personal information collected about you, including the source of your personal information, whether your personal information is sold or disclosed and the purpose, and with whom your personal information was disclosed;
• To request deletion of personal information, if permissible by law;
• To correct inaccurate personal information we retain about you;
• To access a copy of the personal information we retain about you;
• To opt-out of the sale/share of personal information
• To limit the use of sensitive personal information; and
• To non-discrimination based on the exercise of a consumer’s privacy rights.

Please note that a large portion of the personal information collected and processed by Cathay Bank will be out of scope for certain individual rights as it falls under exemptions for information collected under applicable federal laws. For example, non-public personal information that is collected from an individual who obtains from us financial products or services to be used primarily for personal, family, or household purposes is not subject to aspects of various jurisdictional privacy laws. For more information on how Cathay Bank handles non-public information, our U.S. Privacy Notice for Consumers is available here.

 

10. Exercising Your Rights

You may exercise any of the applicable rights described in this Policy by clicking here to complete the Personal Information Request and Opt-Out Form. We will promptly respond to all applicable requests.

For questions about this Policy, please see "Item 18. Contact Us” below.

We reserve the right to verify your identity in connection with any requests regarding personal information to help ensure that we provide the information we maintain to the individuals to whom it pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information. If you are an authorized agent making a request on behalf of a consumer, we may require and request additional information to verify that you are authorized to make that request.

We reserve the right to deny your request if we cannot verify your identity. Where we deny your request in whole or in part, we will endeavor to inform you of the denial, provide an explanation of our actions, and the reason(s) for the denial.

We will not restrict or deny you access to our Services because of choices and requests you make in connection with your personal information. You may exercise any of the applicable rights described in this section by clicking here to complete the Personal Information Request and Opt-Out Form. We will promptly respond to all applicable requests.

 

11. How Long We Retain Personal Information

We will store your personal information for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the information was collected, or as may be permitted under applicable law. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the information; the potential risk of harm from unauthorized use or disclosure of the information; the purposes for which we process the information and whether we can achieve those purposes through other means; and the applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period we will remove personal information from our systems and records or take appropriate steps to properly anonymize it.

 

12. Security and Protection of Personal Information

We have put in place reasonable technical and information safety safeguards that comply with federal law in order to protect your personal information from unauthorized access and use. 

While it is our practice to take reasonable steps to secure each webpage that collects information, the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the Internet, especially personal information related to your financial information.

 

13. Children and Minors

Our Services are not directed to individuals under the age of sixteen (16) and we do not and will not sell the personal information of minors under 16 years of age absent affirmative authorization. If you are under age 16, please do not submit any personal information to us. In addition, we do not and will not knowingly collect personal information from children under the age of thirteen (13). We do not knowingly permit children to communicate with us or use our Services. If you are a parent and become aware that your child has provided us with information, please contact us using one of the methods specified below in "Item 18. Contact Us" and we will work with you to address this issue.

 

14. Cookies / Website Usage

As mentioned, when you access our website, your personal information may be collected by cookies and other similar technologies. A cookie is a bit of information that a website sends to your Web browser that helps the site remember information about you and your preferences. Pixel tags and web beacons are also used in connection with some of our pages and HTML-formatted email messages. You have the ability to exercise control over certain privacy settings by adjusting browser settings on devices (for example, Chrome, Edge, Firefox, Internet Explorer, or Safari). Note: If you do not enable cookies to visit our Sites, some parts of the Sites and services may not work.

Please be aware that limiting the ability of website technologies may limit your experience and in some cases the sites may not work.

 

15. Do Not Call Policy

This Policy constitutes Cathay Bank’s Do Not Call Policy under the Telephone Consumer Protection Act for all consumers. We do not solicit via telephone numbers listed on the state or federal Do Not Call lists, unless the law allows. Consumers who ask not to receive telephone solicitations from Cathay Bank will be placed on Cathay Bank’s internal Do Not Call preference list. Do Not Call requests will be honored within 30 days. No telemarketing calls will be made to residential or cellular phone numbers that appear on the Do Not Call list.

 

16. California’s “Shine the Light” Law

If you are a California resident, you are entitled, once a year, free of charge, to request information regarding our disclosure, if any, of certain categories of Personal Information to third parties for their direct marketing purposes in the preceding calendar year. Note: We do not share personal information with third parties for their own direct marketing purposes without your consent or providing the ability to opt-out.

 

17. Changes

We reserve the right to amend this Policy at any time. When we do revise this Policy, we will update the “Last Updated” date at the top of this page so that you can tell if it has changed since your last visit. The effective date of this Policy is the date in which this Policy was last updated. Your continued use of our Services constitutes your acceptance of the terms of the Privacy Policy as amended or revised by us from the date this Policy was last updated.

 

18. Contact Us

If you have questions about your personal information or your rights under this Policy, please call us, email us or send a letter using the following contact information:
777 North Broadway 1-0-A
Los Angeles, CA 90012
Attention: Compliance Department
Phone number: 800-922-8429
Email: [email protected]

You may exercise any of your rights in relation to your personal information by contacting us using the details provided above or clicking here to complete the Personal Information Request and Opt-Out Form.