PRIVACY POLICY FOR CALIFORNIA RESIDENTS
Last updated: June 29, 2020
This Privacy Policy provides California residents with a description of American Savings Bank’s (“ASB”, “we”, “us”, or “our”) online and offline practices regarding the collection, use, disclosure, and sale of personal information.
Personal Information We Collect
We have collected in the past twelve months, and will continue to collect going forward, the following categories of personal information about consumers:
| Category | Examples | Collected? |
| Identifiers | Real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers | Yes |
| Information listed in California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information | Yes |
| Protected classifications under California or federal law | Age (40 years or older), race, color, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, pregnancy or childbirth and related medical conditions), veteran or military status, genetic information (including familial genetic information) | Yes |
| Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies | Yes |
| Biometric information | Physiological, biological, or behavioral characteristics, including DNA, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data | Yes |
| Internet of other electronic network activity | Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement | Yes |
| Geolocation data | Information used to precisely determine the actual geographic location of a person or device | No |
| Sensory data | Audio, visual, thermal, olfactory, or similar information | No |
| Professional or employment-related information | Application materials, personnel records, and payroll records | Yes |
| Education information | Student records maintained by an educational institution, such as grades, transcripts, class lists, and student disciplinary records | No |
| Inferences drawn from any personal information | Profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | Yes |
| Category | Identifiers |
| Examples | Real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers |
| Collected? | Yes |
| Category | Information listed in California Customer Records statute (Cal. Civ. Code § 1798.80(e)) |
| Examples | Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information |
| Collected? | Yes |
| Category | Protected classifications under California or federal law |
| Examples | Age (40 years or older), race, color, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, pregnancy or childbirth and related medical conditions), veteran or military status, genetic information (including familial genetic information) |
| Collected? | Yes |
| Category | Commercial information |
| Examples | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies |
| Collected? | Yes |
| Category | Biometric information |
| Examples | Physiological, biological, or behavioral characteristics, including DNA, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data |
| Collected? | Yes |
| Category | Internet of other electronic network activity |
| Examples | Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement |
| Collected? | Yes |
| Category | Geolocation data |
| Examples | Information used to precisely determine the actual geographic location of a person or device |
| Collected? | No |
| Category | Sensory data |
| Examples | Audio, visual, thermal, olfactory, or similar information |
| Collected? | No |
| Category | Professional or employment-related information |
| Examples | Application materials, personnel records, and payroll records |
| Collected? | Yes |
| Category | Education information |
| Examples | Student records maintained by an educational institution, such as grades, transcripts, class lists, and student disciplinary records |
| Collected? | No |
| Category | Inferences drawn from any personal information |
| Examples | Profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes |
| Collected? | Yes |
We collect the personal information in the table above from a variety of sources, including:
- Consumers (or their agents or representatives), directly, when they provide the information to us in our branches or offices, by mail, e-mail, or phone, or over the web;
- Public records and other widely available sources, such as publicly visible social media accounts or posts;
- Government entities and law enforcement;
- Private companies or organizations, including credit bureaus and consumer reporting agencies; and
- Computers or devices when consumers visit our website or use our mobile application (e.g., device type, operating system, browser type, browser settings, IP address, language settings, and dates and times when you visit, some of which may constitute personal information).
Purposes of Collection and Use
In the past twelve months, we collected and used personal information for the following purposes:
- Originating and maintaining deposit accounts, loans, investment accounts, and other products and services that we provide to consumers; performing credit reviews, underwriting, and due diligence; and processing transactions and collecting payments;
- Providing consumers with messages and other information relating to our company, policies, practices, products, services, or events;
- Improving and troubleshooting our website, mobile application, communication channels, infrastructure, and operational efficiency and effectiveness;
- Supporting the management and general business operations of our company, including accounting, finance, budgeting, tax, human resources, vendor management, insurance, and computer network and database administration;
- Researching, testing, analyzing, and developing our product and service offerings;
- Marketing our products and services to prospective and existing customers; responding to inquiries and requests; and providing customer service;
- Protecting against malicious, deceptive, fraudulent, and illegal activity; detecting and preventing security incidents; and assisting in law enforcement activities; and
- Performing audits; responding to requests and demands of claimants and government authorities; prosecuting and defending against claims; and complying with federal, state, and local laws and regulations, court orders, or the directives of our regulators.
Disclosure of Personal Information
We have not sold your personal information in the past twelve months, nor do we have any plans to do so in the future. Still, we may disclose all categories of personal information to affiliates and third-party vendors that provide services to us, including companies that provide the following services:
- Employment benefits, background reports, payroll administration, and human resources support;
- Transaction, account, and payment processing services, card services, and collections;
- Building services and equipment maintenance;
- Governance, financial and compliance analysis and support, audits, and records management;
- Fraud prevention and detection, information security, and technology support;
- Insurance and legal compliance;
- Loan origination, sales, and servicing, underwriting, credit review, and due diligence; and
- Marketing and communication support.
We may also provide personal information to:
- Our regulators, law enforcement authorities, and other governmental entities, when appropriate and/or required by law; and
- Third parties authorized by consumers or their agents.
Rights under the California Consumer Privacy Act
California residents may have a right under the California Consumer Privacy Act of 2018 (“CCPA”) to:
- Request the deletion of their personal information;
- Request the disclosure of: (1) the categories of personal information that a business has collected about consumers; (2) the categories of personal information that a business has disclosed to third parties; (3) the categories of sources from which the personal information is collected; (4) the business or commercial purpose for collecting or disclosing personal information; (5) the categories of third parties with whom a business shares personal information; and (6) the specific pieces of personal information that a business has collected;
- Opt out of any sale of personal information; and
- Be free from discrimination for exercising any privacy rights under the CCPA.
A business is not required to grant a consumer’s request when the business is not subject to the CCPA, or when there is a regulatory or statutory exemption. For instance, the following information is excluded from the CCPA’s scope:
- Information not related to a natural person who is a California resident;
- Information collected while the California resident was physically outside of California;
- Information provided to or maintained by a financial institution related to a financial product or service used primarily for personal, family, or household purposes; and
- Information provided to and received by credit bureaus and other consumer reporting agencies.
How to Make a Request to ASB
California residents may submit a request for disclosure or deletion by:
- Calling us toll-free at (800) 272-2566; or
- Completing this form
Applicability
This Privacy Policy for California Residents supplements ASB’s Privacy Policy. ASB shall not be deemed to be subject to the CCPA by virtue of this policy or any action taken pursuant to this policy.
Changes to the Privacy Policy
We may revise this Privacy Policy for California Residents at any time. When we do, we will post the revised policy on our website.
Questions
If you have any questions about this Privacy Policy for California Residents or any other privacy notices, please write to us at:
American Savings Bank, F.S.B.
Attn: Legal Department, Privacy Officer
P.O. Box 2300
Honolulu, HI 96804