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The Cooperative Bank of Cape Cod Online Privacy Statement

The Cooperative Bank of Cape Cod Online Banking and Mobile Application  (together, “Online Banking”)  allow you to conveniently access your Online Banking accounts through your computer or mobile device, making it easy to manage your finances on the go.

This Privacy Policy, in combination with other relevant privacy notices that we provide to you (e.g., pursuant to financial privacy laws), inform you of the policies and practices regarding the collection, use and disclosure of any personal information that we collect from or about users, or that users provide to us, in connection with Online Banking’s website and mobile application (the “Services”).

Online Banking also contains certain functions and links to third party sites that are not owned or controlled by us.  If you elect to use certain functions or links available through Online Banking that are provided by service providers, the service providers may have their own privacy and security policies.  We are not responsible for the privacy practices of such other sites, and you should review the privacy and security policies of these service providers before providing your personal or confidential information.

By visiting or using our website or interacting with our online services, you accept and consent to the data collection, usage, and sharing practices described below and agree to this Statement.

THE TYPES OF INFORMATION WE COLLECT

Through your use of the Services, we may collect personal information from you in the following ways:

  • Personal Information You Provide to Us.
    • We may collect personal information from you, such as your first and last name, address, e-mail, telephone number, and social security number when you create an account.
    • We will collect the financial and transaction information necessary to provide you with the Services, including account numbers, payment card expiration date, payment card identification, verification numbers, and transaction and payment history.
    • We may collected personal information from you when you provide feedback or contact us via email or chat, such as your name and email address, as well as any other content included in the email or chat, in order to send you a reply.
  • We also collect other types of personal information that you provide voluntarily, such as any information requested by us if you contact us via email regarding support for the Services.
  • Personal Information Collected from Third Parties. We may collect certain information from identity verification services and consumer reporting agencies, including credit bureaus, in order to provide some of our Services.
  • Personal Information Collected Automatically Via Technology. We and our service providers may automatically collect information about you, your device used to interact over time with our Services, our communications, and other online services, such as:
    • Device data, such as your device’s operating system, manufacturer and model, browser type, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, network information, and general location information such as city, state or geographic area.
    • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
    • Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns. If you decline cookies by activating the appropriate setting in your browser, the performance and functionality of Online Banking may be affected.
    • Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
    • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
    • To enable some optional features, you may be asked to grant  permission to access your device contacts, camera, or photos.
    • Location Information. If you have enabled location services on your phone and agree to the collection of your location when prompted by the Services, we will collect location data when you use the Services even when mobile application is closed or not in use; for example, to provide our fraud detection services. If you do not want us to collect this information, you may decline the collection of your location when prompted or adjust the location services settings on your device.

HOW WE USE YOUR INFORMATION COLLECTED

  • General Use. In general, we use your personal information collected through your use of the Services to respond to your requests as submitted through the Services, to provide you the Services you request, and to help serve you better. We use your personal information, in connection with Online Banking, in the following ways:
    • facilitate the creation of, and secure and maintain your account
    • identify you as a legitimate user in our system
    • provide improved administration of the Services
    • provide the Services you request
    • improve the quality of experience when you interact with the Services
    • camera or photo access to facilitate some transactions such as mobile deposit or to allow customization of your profile
    • access to your contacts to facilitate digital transactions such as transfers
    • send you administrative e-mail notifications, such as security or support and maintenance advisories; and
    • send surveys, offers, and other promotional materials related to the Services.
  • Compliance and Protection. We may use your personal information to:
    • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities
    • protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims)
    • disclose to trusted third parties, who are bound by contractual obligations to keep personal information confidential, to support our business and to use it only for the purpose for which we disclose it to them
    • audit our internal processes for compliance with legal and contractual requirements and internal policies
    • carry out obligations and enforce our rights arising from any contract entered into between you and us
    • protect the rights, property, or safety of The Cooperative Bank of Cape Cod, its employees, its customers, or others
    • enforce our terms and conditions
    • permit us to pursue available remedies and/or limit the damages we sustain
    • prevent, identify, investigate / deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft
    • fulfill our recordkeeping obligations and practices
    • fulfill any other purpose disclosed by us when you provide the information
  • Creation of Non-Identifiable Data.  Online Banking may create de-identified information records from personal information by excluding certain information (such as your name) that makes the information personally identifiable to you. We may use this information in a form that does not personally identify you to analyze request patterns and usage patterns to enhance our products and services. We reserve the right to use and disclose non-identifiable information to third parties in our discretion.

INFORMATION COLLECTED THROUGH GOOGLE ANALYTICS

We use Google Analytics and other third party analytic tools to collect information about use of our website. Google Analytics collects information such as how often users visit our website and what pages they visit when they do so. We use the information we get from Google Analytics and other third party analytic tools to improve our website, products and services.

Google Analytics does not collect your name or other personally identifiable information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a cookie on your device to identify you as a unique user the next time you visit our website, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your usage of our website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. If you wish to prevent your data from being used by Google Analytics, visit Google’s currently available opt outs for the web, including downloading the Google Analytics Opt-Out Browser Add-On.

In the future, we may also use Google Analytics Advertising Features. If we do, this Online Privacy Statement will include information about the Google Analytics Advertising Features we’ve implemented; how we and third party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together; and how you can opt-out of the Google Analytics Advertising Features we use, including through Ads Settings, Ad Settings for mobile apps, or any other available means.

Browsing

When you visit our website, we gather information such as page or URL requests, time of your visit, your IP address, operating system, web browser software, and any cookies set during a previous visit to our site. We use this information to improve your overall experience. We use cookies to help with navigation through our web pages; they are not used to gather any personal information about users.

Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. This information is anonymized, and we do not collect specific site visitor information.

DISCLOSURE OF YOUR PERSONAL INFORMATION

We disclose your personal information collected through your use of the Services as described below.

  • In Accordance with Our Other Privacy Notices. Other than as described in this Privacy Policy in connection with the App, this Privacy Policy does not apply to the processing of your information by us or third parties with whom we share information.
  • Third Party Service Providers. We may share your personal information with third party or affiliated service providers that perform services for or on behalf of us in providing the App, for the purposes described in this Privacy Policy, including: to provide you with the Services; to conduct quality assurance testing; to facilitate the creation of accounts; to optimize the performance of the Services; to provide technical support; and/or to provide other services to the App.
  • Legal Authorities.  Regardless of any choices you make regarding your personal information, we may disclose your personal information to law enforcement, government authorities, and private parties, for the compliance and protection services described above.

LINKS TO OTHER SITES

The Services may contain links to third party websites. When you click on a link to any other website or location, you will leave Online Banking and go to another site and another entity may collect personal and/or anonymous information from you. Our provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites. We encourage you to read the privacy policy of every website you visit.

YOUR CHOICES REGARDING YOUR INFORMATION

You have several choices regarding use of information on the Services.

  • How We Respond to Do Not Track Signals. Some web browsers transmit “do not track” signals to the websites and other online services with which your web browser communicates. There is currently no standard that governs what, if anything, websites should do when they receive these signals. We currently do not act in response to these signals. If and when a standard is established, we may revise its policy on responding to these signals.
  • Access, Update, or Correct Your Information. You can access, update, or correct your information by changing preferences in your For additional requests, please contact us.
  • Opting Out of Email or SMS. If you have signed-up to receive our email marketing communications, you can unsubscribe any time by clicking the “unsubscribe” link included at the bottom of the email or other electronic communication. Alternatively, you can opt out of receiving marketing communications by contacting us at the contact information under “Contact Us” below. If you provide your phone number through the Services, we may send you notifications by SMS, such as provide a fraud alert. You may opt out of SMS communications by unlinking your mobile phone number through the Services.
  • Opting Out of Location Tracking. If you initially consented to the collection of geo-location information through the Services, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. Please note, however, that if you withdraw consent to our collection of location information, you may no longer be able to use some features of the

SAFEGUARDS AND RETENTION

We implement reasonable administrative, technical, and physical measures in an effort to safeguard the information in our custody and control against theft, loss and unauthorized access, use, modification, and disclosure. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information. It is your responsibility to protect the security of your login information used to access Online Banking. Please note that e-mails and other communications you send to us through our website are not encrypted, and we strongly advise you not to communicate any confidential information through these means.

A NOTE ABOUT CHILDREN

The Services are not directed towards individuals under the age of 18, and we do not, through the App, intentionally gather personal information about visitors who are under the age of 18. If a child under 18 submits personal information to us through Online Banking and we learn that the personal information is the information of a child under 18, we will attempt to delete the information as soon as possible.

DELETING YOUR ONLINE BANKING PROFILE

At any time, you can submit a request to us to delete your online banking profile and associated data. To delete your online banking profile with us, please contact us at (800) 641-1100 or (508) 568-3400 during regular business hours.

Deleting your online banking profile will terminate your use of our Online Banking services but will not close your accounts.  You will remain responsible for any fees or other obligations incurred through Online Banking prior to deletion of your online banking profile, and it is your responsibility to maintain sufficient funds in your accounts to cover any outstanding items initiated through Online Banking.

When you request deletion of your Online Banking profile, the following will occur:

  • Your username will no longer be associated with your accounts, personal data, or mobile application settings.
  • You will no longer be able to access Online Banking Services either in the mobile application or via our website.
  • Configured alert preferences will be deleted.
  • Scheduled one time and recurring bill payments and transfers will be cancelled.
  • Accounts enrolled in eStatements/eDocuments will be returned to paper delivery, which could result in a fee.  See our Fee Schedule for current fees.
  • If you want to access Online Banking Services, you will need to re-enroll.

Your personal information such as your name, email address, and phone number will be temporarily retained in Online Banking for fraud prevention and to comply with data retention and audit requirements.

Records of transactions conducted within Online Banking (either via the mobile application or website), and records of your activity and usage of Online Banking, will be temporarily retained in our internal system for fraud prevention and to comply with data retention, audit requirements, and applicable law.

We are required to retain personal information in certain circumstances, including:

  • Personal information needed to service accounts, applications, or financial services you maintain with us.
  • Personal information for the period required to comply with federal, state, and local laws.
  • Personal information needed in relation to active or potential legal claims.

PRIVACY POLICY UPDATES

This Privacy Policy is subject to occasional revision. We will notify you of any material changes in its collection, use, or disclosure of your personal information by posting a notice on the Services. Any material changes to this Privacy Policy will be effective thirty (30) calendar days following notice of the changes on the Services. These changes will be effective immediately for new users of the Services. If you object to any such changes, you must notify us prior to the effective date of such changes that you wish to deactivate your account. Continued use of the Services following notice of any such changes shall indicate your acknowledgement of such changes.

CONTACT US

If you have any questions or complaints about this Privacy Policy or The App’s data collection or processing practices, or if you want to report any security violations to The App, please contact customer service at (800) 641-1100 or (508) 568-3400, by email at: [email protected], or by mail to:

The Cooperative Bank of Cape Cod
25 Benjamin Franklin Way
Hyannis, MA 02601

Last revised: July 25, 2025