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FNBO PRIVACY NOTICE


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PRIVACY NOTICE

 

Enterprise Privacy Notice

Effective Date: January 1, 2022

The privacy and security of your information is very important to First National
Bank of Omaha (“FNBO”, “we”, “us”, “our”). We are deeply committed to
maintaining industry standard levels of security that comply with applicable
federal and state laws to help protect the personal information that we collect.
Additional information on our security practices may be found at the “Security
Center” link at the bottom of this page.  For purposes of this Enterprise
Privacy Notice, the terms “FNBO”, “we”, “us” and “our” include First National
Advisers, LLC and FNN Trust Company, LLC.

This Enterprise Privacy Notice applies to your interaction and communication
with FNBO, including, without limitation, in person, by phone, through mail or
email or through any online or mobile site, application or social media account
that FNBO owns and controls (collectively, “Sites”), unless a separate privacy
notice is posted or made available to you and supplements this Enterprise
Privacy Notice.

This Enterprise Privacy Notice applies only to the Sites and does not extend to
other websites, including websites owned and controlled by our partners or
third-party websites for which we have provided links, or to any social media
platforms, which are governed by their own terms of use and privacy policies.

By accessing or using our Sites or otherwise disclosing information to us, you
consent to our collection, use, and sharing of your information in accordance
with this Enterprise Privacy Notice.

Information we collect:

We collect the below categories of information directly and indirectly from
individuals and the parties with which we do business in a variety of ways,
including in person, by phone, through mail or email and through our Sites.
These may include parties that interact with us directly (our customers or
individuals that apply for our products, respond to our surveys, request
information about our products or services or otherwise voluntarily provide us
with their information), parties to which we provide goods or services, parties
that provide goods or services to us and other parties with whom we offer or
provide products and services.

We may continue to collect and store the following types of information:

 * Identifiers, such as, name, address, email address, phone number, date of
   birth, social security number, tax payer ID, driver’s license number,
   passport number, government ID or IP address.
 * Protected classification characteristics, such as, race, color, national
   origin, marital status, sex, veteran or military status.
 * Geolocation data, such as, physical location or movements.
 * Biometric information, such as, face prints, voice recordings, fingerprints
   or keystroke patterns or rhythms.
 * Commercial information, such as, organizational information, records of
   personal property or purchasing history.
 * Internet or other similar network activity, such as, browser information,
   search history, device type or service provider information.
 * Professional or employment related information, such as, income or current or
   past job history.
 * Educational information, such as, transcript, student records, grades and
   performance, activities, school name or school ID.
 * Health information, such as, medical history, insurance information, benefit
   plan information, claims history or payment history.
 * Inferences drawn from other information, such as, person’s preferences,
   trends or behaviors.
 * Personal records, such as, family history or power of attorney.
 * Information that you provide by filling in forms or providing other
   contributions on our Sites.
 * Information received from a government entity or other third party.
 * Records and copies of your correspondence (including email addresses), if you
   contact us.
 * Responses to surveys.
 * Details of transactions you carry out through our Sites, such as, financial
   information, account information, credit information or transactional
   information.

Certain information set forth above may be categorized as “personal information”
to the extent it identifies, relates to, describes, references, is capable of
being associated with, or could reasonably be linked, directly or indirectly,
with a particular consumer or device. Such personal information may receive
additional protections under applicable state or federal law (see below).
Personal information specifically does not include information that is publicly
available information from government records, or information that is
deidentified or aggregated information.

How we use information we collect:

We may use information:

 * To detect, investigate or prevent activity that may be illegal, violate our
   policies, cause harm to our operations or compromise our security.
 * To optimize, improve or enhance our products, services and operations.
 * To respond to your inquiries or fulfill your requests, including to provide
   individuals with, or evaluate their eligibility for, products and services
   that they have requested from us.
 * To communicate with individuals about their accounts or transactions that
   they have made with us.
 * To provide important information regarding our products or services,
   including changes to our policies or other terms, conditions or agreements
   and our Sites.
 * To allow participation in surveys, sweepstakes, contests and other
   promotions.
 * To comply with legal and regulatory requirements, required disclosures and
   choices or controls that may be available.
 * To send offers and promotions for our products and services or for other
   products and services that may be of interest.
 * To personalize online or mobile content and user experiences.
 * To verify the identity or location of an individual for security, fraud
   prevention and other risk control purposes.
 * To provide advertising based on activity on our Sites.
 * To perform operational functions in connection with our business, including
   data analysis, audits, developing and improving products and services,
   enhancing the Sites, identifying usage trends and determining the
   effectiveness of promotional campaigns.
 * In connection with your employment (to the extent applicable to you).
 * For any other purpose disclosed by us to you at the time you provide us
   information.

We may disclose each of the categories of information we collect for any of the
business purposes set forth above.

To the extent you have obtained a financial product or service from FNBO that is
used primarily for personal, family or household purposes, please refer to the
supplemental privacy statement found here with respect to how FNBO will use and
share your personal information collected in connection with such financial
product or service.

If you are a California resident, you may have additional rights with respect to
your personal information. Please refer to the Section below entitled
“California resident privacy rights”.

How we share information we collect:

Generally, our sharing of information is subject to additional rights available
under applicable federal or state law.

We may disclose information that we collect:

 * To our subsidiaries and affiliates.
 * To contractors, service providers and other third parties we use to support
   our business.
 * To a buyer or other successor in the event of a merger, divestiture,
   restructuring, reorganization, dissolution or other sale or transfer of any
   or all of FNBO's assets, whether as a going concern or as part of bankruptcy,
   liquidation or similar proceeding, in which information held by FNBO about
   our Site users is among the assets transferred.
 * To third parties to market their products or services to you.
 * To fulfill the purpose for which you provide it.
 * For any other purpose disclosed by us when you provide the information.
 * With your consent.
 * To comply with any court order, law or legal process, such as, responding to
   any government or regulatory request.
 * To enforce or apply our terms of use with respect to our Site and other
   agreements, including for billing and collection purposes.
 * If we believe disclosure is necessary or appropriate to protect the rights,
   property or safety of FNBO, our customers or others. This includes exchanging
   information with other companies and organizations for the purposes of fraud
   protection and credit risk reduction.

We may disclose aggregated information about you, and information that does not
identify any individual, without restriction. We may disclose each of the
categories of information we collect for any of the business purposes set forth
above.

To the extent you have obtained a financial product or service from FNBO that is
used primarily for personal, family or household purposes, please refer to the
supplemental privacy statement found here with respect to how FNBO will use and
share your personal information collected in connection with such financial
product or service.

If you are a California resident, you may have additional rights with respect to
your personal information. Please refer to the Section below entitled
“California resident privacy rights”.


Cookies and similar technologies:

We or our service providers may automatically collect information about you or
visitors to our Sites using cookies. A cookie is a small file placed on a
computer or mobile device by a webpage server that allows the webpage server to
determine things like how much time each visit by the computer or device lasts
and what the computer or device is viewing and clicking on during each visit.
This information may be used for security purposes, to help in navigation, to
display content more effectively, to improve experiences, optimize our sites and
better serve you with appropriate and relevant marketing offers. The cookies
that we use do not track activities that occur on websites other than our own.

Cookies that are used as part of our Sites may include cookies of a third party
website that are being co­browsed, for example, to deliver the Sites as intended
by the third party website operator. Our Sites may also use tracking pixels or
other similar technologies embedded in online advertising, often distributed to
third party websites using ad exchanges that allow the gathering of data about
viewers of their online advertising.

In addition, we may contract with third party advertising networks that collect
IP addresses and other information from our Sites, from emails and on
third-party websites. Ad networks follow your online activities over time by
collecting information through automated means, including through the use of
cookies and use this information to provide advertisements about products and
services tailored to your interests. We may also partner with third parties to
provide certain features on our Sites or to display advertising based upon your
web browsing activity.

In addition, we use advertising service providers to place advertisements for
our accounts and services on websites not affiliated with us, and to help us
determine which of our advertisements are most likely to be of interest to you
using non­Personal Information. Advertisements placed by these service providers
may use tracking technologies that allow monitoring of your responsiveness to
such advertisements. We restrict access and collection of information by
advertising service providers for purposes other than assisting us with our
advertising efforts.

While most web browsers are automatically set to accept cookies, web browser
preferences can be modified to disable cookies. Disabling or declining cookies,
however, will likely impact or disable some of our Sites’ functionality and/or
your user experience. While cookies are not required to browse our Site, they
may be required for access to accounts.  You may opt-out of certain advertising
and web analytic cookies by visiting the “Modify Privacy Options” link at the
bottom of this page. 

Children’s Online Privacy Protection Act:

We recognize that protecting children's identities and privacy is important. We
do not knowingly market to or solicit information from children under thirteen
(13) without the affirmative consent required under applicable law.

USA PATRIOT Act:

To help the government fight the funding of terrorism and money laundering
activities, the USA PATRIOT Act requires all financial institutions to obtain,
verify and record information that identifies each person (including business
entities) who opens an account.

What this means to you: When you open an account, we will ask for your name,
physical address, date of birth, tax payer identification number and other
information that will allow us to identify you. We may also ask to see your
driver's license or other identifying documents. We will let you know if
additional information is required.

Notice to International Users:

The Sites and bank products and services are offered and hosted in the United
States and subject to U.S. law, and are intended for users located only in the
U.S. If you are accessing the Sites or bank products and services from outside
the United States, please be advised that U.S. law may not offer the same
privacy protections as the laws of your jurisdiction. By accessing and using the
Sites or bank products and services, you consent to the transfer to and
processing of your personal information in the U.S.

California resident privacy rights:

If you are a California resident, California law may provide you with additional
rights regarding our use of your personal information; subject to exclusions
from the rights granted under California law with respect to certain information
governed by certain sector-specific privacy laws, including the Fair Credit
Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or the California
Financial Information Privacy Act (FIPA).

Subject to certain exceptions, California residents have the following rights
regarding their personal information:

 * Access to Personal Information and Data Portability Rights. The right to
   request that we disclose certain personal information to you about our
   collection, use, disclosure and sale of your personal information over the
   prior twelve (12) month period. Once we receive and confirm your verifiable
   request, we will disclose to you: the categories of personal information
   collected, the sources collected from, the purpose for collection, the
   categories of third parties shared with, and the specific pieces of personal
   information collected about you.
 * Deletion Request Rights. The right to request we delete any of your personal
   information we’ve collected from you and retained (subject to exceptions
   granted under law). Once we receive and confirm your verifiable request, we
   will delete your personal information records, unless an exception applies.

To exercise a request described above, a California resident may click here to
submit a verifiable consumer request or call our toll-free number: 855-578-8488.

Only a California resident, or someone legally authorized to act on such
California resident’s behalf, may make a verifiable consumer request related to
his or her personal information. In connection with submitting a request, we may
require you to provide certain of the Identifiers noted above and your
relationship status. In general, we have the right to require you to provide
written permission granting authority to your representative and for your agent
to verify its identity directly with us, and we may deny a request from your
representative who does not submit proof of authorization as we request.

A California resident may only make a verifiable consumer request for access or
data portability twice within a twelve (12) month period. The verifiable
consumer request must provide sufficient information that allows us to
reasonably verify the requestor is the person about whom we collected personal
information or an authorized representative and describe the request with
sufficient detail that allows us to properly understand, evaluate, and respond
to it. We cannot respond to a request or provide personal information if we
cannot verify the identity or authority to make the request.

We will endeavor to confirm receipt of a request within ten (10) days following
submission and provide information about how we will process the request. We
endeavor to respond to a verifiable consumer request within forty-five (45) days
of its receipt. If we require more time (up to an additional forty-five (45)
days), we will provide notice in writing explaining the reason for the extended
time period.

Making a verifiable consumer request does not require a California resident to
create an account with us. We will deliver our written response by mail or
electronically, at your option.

Any disclosures we provide will only cover the twelve (12) month period
preceding the request receipt date. If we deny a request, we will provide a
response explaining the reasons we cannot comply with a request, if applicable.

In the preceding twelve (12) months, we have not sold and will not sell
California resident personal information. The foregoing statement is subject to
certain exclusions governed by sector-specific privacy laws, including the Fair
Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or the California
Financial Information Privacy Act (FIPA).

A California resident has the right to not receive discriminatory treatment by
FNBO for the exercise of the privacy rights conferred under California law. We
will not discriminate against a California resident for exercising any of his or
her rights.

Do-Not-Track signals are certain consumer browser settings that request that a
web application disable its tracking of an individual user. While our Sites do
not currently recognize Do-Not-Track signals, we do not track activities that
occur on websites other than our own and declining to accept cookies will ensure
that online activities on our Sites are not tracked.

Changes to this Enterprise Privacy Notice:

We may change this Enterprise Privacy Notice at any time. The most current
version of this Enterprise Privacy Notice will be posted and available on the
Sites. Any changes to this Enterprise Privacy Notice will be effective at the
time we post the revised Enterprise Privacy Notice to the Sites. If we make
material changes to how we treat your information, we will notify you through a
notice on our Sites home page. Please review it periodically. Your use of the
Site following any changes made means that you accept the revised Enterprise
Privacy Notice.

Contact Information:

If you have any questions or comments about this Enterprise Privacy Notice,
please do not hesitate to contact us at:

Website: Contact Us
Email: firstnational@fnni.com
First National Bank of Omaha
1620 Dodge Street, Stop Code 3089
Omaha, Nebraska 68102

FNBO is a leading credit card issuer with over 250 financial institutions,
co-brand, and affinity partners nationwide.
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