Updated March 2023

LightStream has a longstanding commitment to protecting the confidentiality and security of our clients' personal information. We believe it is helpful to have an overview of how this commitment is applied as LightStream collects, uses, and protects your personal information when you visit us online.

For California residents, the California law requires that we provide consumers with advance notice of the types of personal information we collect from consumers, our intended use of such information, and a description of your privacy rights under California law. This includes rights to request disclosure of the types of personal information we have collected on you and your right to request that we delete certain information we have collected from you. Please see the CCPA Notice at Collection section of this Privacy page for further information on your specific consumer privacy rights.

This LightStream Statement of Online Privacy Practices (“Privacy Practices”) describes how we collect information when you visit or use our websites, mobile application, and other online services (“Online Services”) that link to this Privacy Policy. It also describes how we use and share such information and explains your privacy rights and choices.

LightStream’s business address is LightStream, PO Box 117320, Atlanta, GA, 30368-7320, USA. Our Customer Service Team may also be contacted via email at customerservice@lightstream.com.

What isn’t covered by this policy?

This Privacy Practices do not apply to the websites, mobile applications, or services of LightStream that do not directly link to this policy. It also does not apply to non-LightStream companies, such as third-party websites to which we link online. Please review the privacy policies of other websites and services you visit to understand their privacy practices.

Other important notices

Our Consumer Privacy Policy applies to information that we collect about individuals who seek, apply for, or obtain our financial products and services for personal, family, or household purposes. In addition, our CCPA Notice at Collection related to the California Consumer Privacy Act applies to certain information we collect about California residents.

What information do we collect?

When you visit the LightStream website, application, or otherwise interact with us online, we may collect the following information:

• Your browser type (such as Google Chrome, Microsoft Edge, Apple Safari, Mozilla Firefox)
• Your Internet Protocol or “IP” address (Your IP address is a number that is automatically assigned to your device by your Internet Service Provider. An IP address is identified and logged automatically whenever you visit a site, along with the time of the visit and the page(s) that were visited.)
• The presence of any software on your device that may be necessary to view our site
• Configuration information about the device you are using, including, but not limited to, your device type, web browser type and version, operating system type and version, display/screen settings, and language preferences
• Information from your mobile device, such as contacts, photos (for example, to deposit checks or capture receipts), mobile network information, and cross-device IDs
• Personal information submitted on applications, forms, and onsite electronic messaging. Types of personal information typically include:
• • Name
  • Social Security number
  • Driver’s license number or other government-issued ID
  • Address
  • Email
  • Telephone number
  • Account numbers and account information
  • Usernames
  • Passwords and other authentication information like PINs, security questions, and other secure sign-on methods¹
  • Other non-public information, including credit and income information
• Website analytics information such as pages visited and average time spent on a particular page
• • If you would prefer that your movements and actions online at lightstream.com not be monitored, you can opt-out of tracking.
  • • NOTE: It is necessary to install a cookie on your browser to identify that you have opted-out. If you delete the opt-out cookie, or change devices or web browsers, you will need to opt-out again.
• Search engine traffic referral information
• Responses to advertisements and promotions
• Transactional information from behind the secure login about your relationship with us (such as types of accounts or the state in which you bank)

_{¹About biometric-enabled sign-ons: Your device stores the information it needs to recognize your facial features or fingerprints. The LightStream Mobile App uses your device’s functionality to obtain a signal that your device recognizes your facial features or fingerprints when you sign on. LightStream does not have access to the information your device uses to enable facial or fingerprint recognition, nor do we have access to or store your facial image or fingerprint data. You can always turn off facial or fingerprint recognition and go back to inputting user ID and password at any time. Your device’s user information will have additional information regarding its user controls and settings, including its privacy and security controls.}

How does LightStream use collected information?

The information we collect online helps us to:

• Effectively manage your account:
• • Ensure your identity and protect the security of your personal and account information from unauthorized access
  • Process transactions on your account
  • Respond to product applications and questions
  • Fulfill regulatory requirements
• Fulfill regulatory requirements
• Analyze our site usage and enhance the user's experience:
• • Diagnose server problems
  • Alert users of any possible software compatibility issues
  • Help us make decisions about how various technologies are used and identify usage trends
• Send marketing communications:
• • Present personalized or targeted offers, ads, or content we believe may be of interest to you
  • Determine the effectiveness of promotional campaigns
• Make business decisions:
• • Analyze data and credit risk
  • Perform market research
  • Conduct audits
  • Develop and improve products and services
• Carry out other day-to-day business operations, such as to comply with applicable laws; share with our affiliates and subsidiaries; disclose to contractors, business partners, and other third parties under specific contracts and agreements; perform compliance activities; conduct credit reporting activities; and engage in human resources activities
• Prevent and detect fraud
• Protect against risks to security:
• • Monitor network activity logs
  • Detect security incidents and conduct data security investigations
  • Protect against malicious, deceptive, fraudulent, or illegal activity

We only use personal information that we have about you when we have a legal basis to use such personal information under applicable data protection laws.

How does LightStream share collected information?

LightStream shares your information in different ways as permitted and required by law. For example, we may share your information with:

• Affiliates and other entities in the LightStream family
• Businesses with which we partner to offer products and services for our clients or prospective customers, such as joint marketing partners or bill pay partners
• Service providers that provide various services to us, such as those we use to help detect and prevent fraud, improve our online services, and to better market and advertise our services to you
• Credit reporting agencies to report on or learn about your financial circumstances and as permitted by law
• Government entities and other third parties as needed for legal or similar purposes, such as:
• • To respond to requests from our regulators
  • To respond to a warrant, subpoena, governmental audit or investigation, law enforcement request, legal order, or other legal process
  • To facilitate a merger, acquisition, sale, bankruptcy, or other disposition of some or all of our assets
  • To exercise or defend legal claims

Please see the Privacy Policy section of this Privacy page for more information on how we may share your personal information and how you may be able to limit certain types of sharing.

Please note, we may also share aggregated and de-identified data, such as aggregated statistics regarding product usage, with third parties.

We reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including, without limitation, in the event of a reorganization, dissolution, or liquidation).

What if I’m visiting the LightStream website from outside the United States?

Our Online Services are intended for a U.S. audience. If you are visiting the LightStream website, please be aware that your personal information may be transferred to, or stored and processed in, the United States. We will rely on legally provided mechanisms (for example, derogations such as performance of a contract) to lawfully transfer personal data across borders.

How long does LightStream retain records?

We store your personal information as long as it is required to meet our contractual and legal obligations, or if we have a legitimate business need to do so.

What technologies does LightStream use?

LightStream and its online advertising and marketing partners may employ various technologies to collect information, including:

• Cookies – Cookies are pieces of information stored directly on your device. Cookies provide information that is used for security purposes, to facilitate navigation, to display information more effectively, and to personalize/customize your online experience. The cookies LightStream uses do not collect or store any personally identifiable information about you. LightStream uses persistent cookies to learn how visitors use our site, such as which pages are viewed the most, to identify the most common navigation paths, or to customize the presentation of information on the site. LightStream also uses session cookies to assist in delivering some online transactions, like online banking. Session cookies are no longer active after you log off the service that initiated them, and all session cookies are automatically deleted when you close all browser windows. LightStream may also contract with third parties, including, but not limited to, Adobe (see Cross-Device Tracking, below), to track user activity on our website. You can choose to block or disable these cookies as most devices and browsers offer their own privacy settings. Doing so, however, may result in diminished performance on our site.
• Marketing pixels, web beacons, clear GIFs, or other technologies – This technology may be placed on certain pages of our website, applications, emails, and other marketing initiatives. These tags usually work in conjunction with cookies and allow us to measure the effectiveness of our site and compile statistics about usage and response rates.
• Software Development Kits (SDKs) – Our mobile applications may include third-party SDKs that allow us and our service providers to collect information about your mobile app activity. In addition, some mobile devices come with a resettable advertising ID (such as Apple’s IDFA and Google’s Advertising ID) that, like cookies and pixel tags, may allow us and our service providers to identify your mobile device over time for advertising purposes in compliance with applicable app store consent rules.
• Advertising and Cross-Device Tracking – LightStream uses certain Adobe Analytics services and products, which help companies build websites, applications, and advertisements that seamlessly flow between all your devices (such as a desktop, laptop, tablet, phone, or smart watch). The Adobe services recognize which of your devices are linked through use of technology that includes cookies and your IP address (without collecting your sensitive personal information). Visit the Adobe website for more information on opting out of certain services, cross-device tracking, and/or to unlink your devices. NOTE: Adobe needs to install a cookie on your browser to identify that you have opted out. If you delete the opt-out cookie, or change devices or web browsers, you will need to opt out again.
• Firewalls, passcodes, data encryption, and other safety features – LightStream uses these technologies to ensure that the information you provide us remains secure. To learn more about how we safeguard your information online please go to the Security Policy section of this Privacy page.
• Third-party plugins – Other companies may have plugins that appear on certain pages of our website or applications. Some of these, for example, may be from social media companies (for example, the Facebook “Like” button). These plugins may collect information, such as information about the pages you visit, and share it with the company that created the plugin even if you do not click on the plugin. These third-party plugins and the way they operate are governed by the privacy policies and terms of the companies that created them.

How does LightStream interact with me online?

Online advertising on LightStream website and application

LightStream advertises its products and services on pages within our sites and on mobile applications. To make the content and advertising as informative and useful as possible, LightStream may target and personalize content and advertisements for products and services on our site.

Online advertising on third-party websites and applications

LightStream advertises its products and services on websites and applications not affiliated with LightStream. The third-party companies we hire to display these ads use their own tracking technologies to measure the effectiveness of these ads and to understand your interests. Many of our third-party partners have their own privacy policies. We encourage you to review these policies carefully.

Some of our third-party advertising is interest-based and may use information about your online interests to customize the online ads you see. Many ad platforms have adopted the use of the AdChoices Icon for our interest-based advertising (excluding ads appearing on platforms that do not accept the icon). Anyone receiving an interest-based ad can click on the displayed icon to receive more information. The AdChoices Icon does not prevent you from receiving advertisements; instead, it allows you to control whether you receive interest-based advertisements and from which companies. Visit the Digital Advertising Alliance website for more information about the AdChoices Icon and interest-based advertising. If you would like to know more about how to opt out with your specific browser and device, you may visit the DAA Webchoices Browser Check and NAI Opt Out of Interest-Based Advertising tools for additional options. You can also download the AppChoices app to opt out in mobile apps.

Third-party aggregation services and tools

Aggregation allows you to gather information from many websites and view that information in a consolidated format. An example of why you might use a third-party aggregation tool is if you wanted a comprehensive view of assets and liabilities held within your financial accounts. If you provide information about your LightStream accounts (including your access information) to an aggregation service provider, we will consider that as your having authorized all transactions initiated by that aggregation site. LightStream reserves the right to disable aggregation for any account without notice. If you wish to cancel your third-party aggregation services, you should also change your password at LightStream.com.

Social Media

LightStream provides experiences on social media platforms such as Facebook, Instagram, LinkedIn, or Twitter that enable online sharing and collaboration. We use social media to facilitate social engagement and sharing, when such sharing is appropriate and safe. Please note, any content you post, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms, is subject to the terms of use and privacy policies of those platforms. Please refer to them to better understand your rights and obligations with regard to such content.

Given the very public nature of social media, it is critical that we all safeguard confidential financial information. If you post information on a LightStream site that we feel should be shielded from public view, we will remove it. This includes not only specific details about your LightStream accounts and other private, confidential information (such as your Social Security number), but details of information relayed in private conversations between you and LightStream representatives. Please know that in taking down or editing your posts, we are focusing our experience and best judgment to keep your personal information safe.

Email

Email transmitted across the internet is normally not protected and may be intercepted and viewed by others. Therefore, you should refrain from sending any confidential or private information via unsecured email to LightStream. We'll never ask you to send confidential information to us via email, such as your logon ID, password, full account numbers, or Social Security number.

Occasionally, we will retain the content of your email—and our replies—to confirm proper responses to your questions and requests, to comply with legal and regulatory requirements, and to ensure that we consistently deliver an enjoyable client experience to you.

Linking to other sites

LightStream may provide links to non-LightStream companies, such as credit bureaus or merchants, and will notify you when leaving the LightStream site. If you choose to link to websites not controlled by LightStream, we are not responsible for the privacy or security of these sites, including the accuracy, completeness, reliability or suitability of their information. If you are asked to provide information on one of these sites, we urge you to carefully study their privacy policies before sharing.

Control your online and other privacy preferences

In summary, the following links can help you to customize and control your privacy preferences when interacting with LightStream online:

• If you are a current LightStream customer, you can control your marketing preferences for direct mail, email, and telemarketing preferences, along with the sharing of your personal information via our Preferences page. You may also email LightStream at privacy@lightstream.com.
• Do Not Track and Global Privacy Control
• • We will respond to the Global Privacy Control signal as explained further in our CCPA Notice at Collection. At this time, we do not currently respond to other browser “do not track” signals or other mechanisms that allow you to tell websites you do not want to have online activities tracked.

Protecting your children

LightStream strictly follows the federal guidelines of the Children’s Online Privacy Protection Act (COPPA), which gives parents control over what type of information is collected online about their children. We do not knowingly collect, maintain, or use personally identifiable information from children under age 13 on our websites. We are not responsible for the data collection and use practices of nonaffiliated third parties that are linked from our websites. Visit the Federal Trade Commission’s COPPA Website for more information.

How does LightStream protect me from fraud and secure my information?

To protect personal information from unauthorized access and use, we use security measures that comply with applicable federal and state laws. These measures may include device safeguards and secured files and buildings as well as oversight of our third-party service providers to ensure information remains confidential and secure.

How can I make sure my information is accurate and use my individual rights?

Keeping your account information accurate and up to date is very important. If your account information is incomplete, inaccurate or not current, please login to your online account and make appropriate updates. If you need help logging into your online account, please contact us at customerservice@lightstream.com.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We will ask you to verify your identity to help us respond efficiently to your request.

Under non-U.S. data protection laws, you may have the right to complain to a data protection authority about our collection and use of your personal information.

What is LightStream’s cellular phone identity verification statement?

You authorize your wireless carrier to use or disclose information about your account and your wireless device, if available, to us or our service provider for the duration of your business relationship, solely to help them identify you or your wireless device and to prevent fraud. LightStream’s Statement of Online Privacy Practices and Privacy Policy detail how we treat your data.

How will LightStream notify me about online privacy practices updates?

LightStream’s Online Privacy Practices may be revised from time to time, so please review them periodically. Any changes will become effective when we post the revised Practices on the site (Please note the effective date listed at the top of this page). If we revise our Online Privacy Practices in a material way, we will provide a conspicuous notice on our website when any changes take effect.