Collection of Visitor Information – Public Area
If you visit the public areas of the Websites without requesting any information from Promontory Network, we do not collect any information that personally identifies you. We may collect, store, and use non-personally identifying information, including information relating to the Internet connection and the date and time of the visit. We reserve the right to collect, store, and use such information for any lawful purpose.
If while visiting the public area of any of the Websites you request information from Promontory Network, or if you otherwise inquire about any of the Services, we may collect information you provide to us that allows us to respond to your request. You may choose to provide us with your contact information, including name, email address, mailing address, telephone number, or other information. We will use information you provide to respond to your request. We may also use the information to contact you regarding the Services. We do not and will not sell or distribute such personally identifying information to third parties. We will, however, comply with any subpoena or lawful information request from a court or government agency.
Confidentiality and Security of Data – Members-Only Areas
If you are an authorized representative of a Participating Institution in the CDARS service or the ICS service and are accessing the Transaction & Reporting Portal (the “Portal”) through the secure, members-only area of the promnetwork.com website, confidentiality and security are governed by the applicable Participating Institution Agreement between your institution and Promontory Network. In connection with the establishment of a user account, Promontory Network may collect certain information, including the name and email address of the user. Promontory Network is committed to protecting the confidentiality and security of information we collect through the Portal. We use a variety of security technologies and procedures to help protect personally identifying information collected through the Portal from unauthorized access, use, or disclosure.
Cookies and Google Analytics
When you visit the Websites or access the Portal, a cookie may be created, used, and stored on your device. A cookie is a piece of data stored by your web browser. Among other things, a cookie may help a website keep track of user visits and activity.
We may also use several features of Google Analytics:
- We may use Remarketing with Google Analytics to display content-specific advertisements to visitors to the Websites that have previously visited the Websites when those visitors go to other websites that have implemented the Google Display Network. In the future, we may use other remarketing vendors. Third-party vendors, including Google, may show our advertisements on websites across the internet. We and some third-party vendors, including Google, may use first-party cookies (such as the Google Analytics cookie) and third-party cookies together to inform, optimize, and serve advertisements based on a visitor’s past visit to the Website. By using Google’s Ads Settings, you may customize Google Display Network ads.
- We may use Google Analytics Demographics and Interest Reporting (“GADIR”) to learn more about visitors to the Website so that we may enhance the Websites or Services and provide a better user experience. We will never sell information collected through GADIR.
- We may use the Google Analytics User-ID feature. We may use this feature to analyze groups of sessions, across devices, using a unique, persistent, and non-personally identifiable ID string.
If you do not want any information from your browsing session to be sent to Google Analytics, you may install the Google Analytics Opt-Out Browser Add-on.
Notice for Consumers in the State of California
If you are a consumer residing in the State of California, you have a right to request that we disclose to you the categories and specific pieces of personal information that we have collected from you during the prior twelve (12) months. You also have a right to request that we delete personal information about you that we have collected from you. You have a right not to receive discriminatory treatment from us for exercising the privacy rights granted by the California Consumer Privacy Act.
You may submit such requests by contacting us at CCPA@promnetwork.com or (866) 776-6426. After receiving a request, Promontory Network will take measures to verify the request, which may include asking you to verify certain information about yourself, which we will compare to the information we have collected. Please allow up to forty-five (45) days for a response. Contact us at the above email or telephone number if you want to designate an authorized agent to make requests on your behalf under the California Consumer Privacy Act.
If your request relates to personal information that you have provided to a financial institution that uses one of the Services, and not directly to Promontory Network, you should submit the request directly to that financial institution.
Notifications of Changes
This document was last updated on January 1, 2020.