Rev 08/2015

image Metropolitan Commercial Bank

FACTS WHAT DOES METROPOLITAN COMMERCIAL BANK DO WITH YOUR PERSONAL INFORMATION?
Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What? The types of personal information we collect and share depend on the product or service you have with us. This information can include:
  • Identification Information
  • Account Balances
  • Transaction History
  • Account Transactions
  • Checking Account Information
  • Wire Transfer Instructions
When you are no longer our customer, we continue to share your information as described in this notice.
How? All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons Metropolitan Commercial Bank chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information Does Metropolitan
Commercial Bank share?
Can you limit this sharing?
For our everyday business purposes such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus Yes No
For our marketing purposes to offer our products and services to you Yes No
For joint marketing with other financial companies Yes No
For our affiliates' everyday business purposes information about your transactions and experiences No We don't share
For our affiliates' everyday business purposes information about your creditworthiness No We don't share
For non-affiliates to market to you No We don't share
Questions? Call 1-866-363-8226 or visit www.metropolitanbankny.com
What We Do
How does Metropolitan Commercial Bank protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We also maintain other physical, electronic and procedural safeguards to protect this information and we limit access to information to those employees for whom access is appropriate.
How does Metropolitan Commercial Bank collect my personal information? We collect your personal information, for example, when you
  • Open an account
  • Apply for financing
  • Transaction history
  • Provide account information
  • Give us your contact information
  • Wire Transfer instructions
We also collect your personal information from others, such as credit bureaus, affiliates or other companies
Why can't I limit all sharing? Federal law gives you the right to limit only:
  • sharing for affiliates' everyday business purposes - information about your credit worthiness
  • affiliates from using your information to market to you
  • sharing for non-affiliates to market to you
State laws and individual companies may give you additional rights to limit sharing.
Definitions
Affiliates Companies related by common ownership or control. They can be financial and non-financial companies. Metropolitan Commercial Bank does not share with our Affiliates so they can market to you.
Non-affiliates Companies not related by common ownership or control. They can be financial and non-financial companies. Metropolitan Commercial Bank does not share with non-affiliates so they can market to you.
Joint Marketing A formal agreement between non-affiliated financial companies that together market financial products or services to you. Our joint marketing partners include credit card account companies.
Other Important Information

For Alaska, Illinois, Maryland and North Dakota Customers. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing – without your authorization.

For California Customers. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing – without your authorization. We will also limit our sharing of personal information about you with our affiliates to comply with all California privacy laws that apply to us.

For Massachusetts, Mississippi and New Jersey Customers. We will not share personal information from deposit or share relationships with nonaffiliates either for them to market to you or for joint marketing – without your authorization.

For Texas Customers. If you have a complaint, first contact the customer service division of Metropolitan Commercial Bank at 1- 866-363-8226. If you still have an unresolved complaint regarding the company’s money transmission activity, please direct your complaint to Texas Department of Banking, 2601 North Lamar Boulevard, Austin, Texas 78705, 1-877-276-5554 (toll free), www.dob.texas.gov.

For Vermont Customers. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing without your authorization, and we will not share personal information with affiliates about your creditworthiness without your authorization.



JELLI FINANCE CO. PRIVACY POLICY

Jelli Finance Co., and their Affiliates, (collectively and individually "Jelli,") respect your privacy, and we assure you that we take the protection of your personal information very seriously. We therefor provide this Privacy Policy to disclose our information collection, utilization, and sharing practices for this Site. This Privacy Policy applies to any website or mobile application that includes, attaches, references, or links to this Privacy Policy (the "Site"). Unless explicitly provided herein, this Privacy Policy does not apply to the practices of companies that Jelli does not own or control or to people that Jelli does not employ or manage. If you do not agree to these terms, do not access Jelli Site or other related services. The information we receive from you depends on what you do when you visit this Site. Except as described in this policy, we do not sell, rent, share or disclose your personally identifiable information to or with any other organizations.

In addition to this Privacy Policy, the Site may provide additional disclosures and policies that relate to the collection, use, and sharing of your information in relation to various financial services, including without limitation disclosures required by third parties such as banks that receive and process the information you provide through our website. Please review these additional disclosures and policies for more information.

TYPE AND USES OF INFORMATION WE COLLECT FROM YOU:

Personally Identifiable Information ("PII") – Generally, you can visit our Site without revealing any personal information about yourself. At times, though, we may need information about you. Unless otherwise indicated, the information we request is optional. We may gather certain personal information from you to help us better serve you through e-commerce transactions and promotions, as well as to respond to inquiries and provide employment information and opportunities. We only collect personally identifiable information when you choose to reveal it to us.

Our Site collects information from our web forms that may be displayed on our Site. At these places, we may ask you to give us contact information (like name, title, email address, phone number, nearest store, social security number, birthday, company name, and address, along with answers to questions topical to the web form and an ability to state additional information).

When you submit an inquiry about a job at Jelli through this Site, we may ask for information such as your name, address, telephone number, email address, career selection, nearest store, and a brief description of your related work experience with an option to upload your resume. We may use the information you provide to match your experience and preferences with the job openings we have, and someone from Jelli may contact you about a possible employment opportunity. Please note that by submitting your information regarding employment opportunities with Jelli, you authorize us to transmit and store your information in our recruitment database.

When you email a question to one of our team members, we receive your email address and any other information you choose to include in your email. If you use other web forms to submit inquiries or sign up for mailing lists or other information, we will collect the information you submit. If we receive similar questions from other users, we may post the most frequently asked questions on our site under a "Q & A" section. The question we post may be similar to, or the same as, the question you submitted, but we will not identify you (or anyone else) as the questioner.

In other areas of this Site we may ask for your email address and solicit information about the Jelli products you enjoy most, other products you might enjoy, and similar questions in order to create convenience for the consumer to activate preference features or enrollment opportunities.

The primary purpose of many web forms is to allow you to request and purchase information, products, and services from us, including without limitation to apply for financial related services subject to the terms and conditions, disclosures, and privacy policies related to those services and the third parties with which Jelli works to offer those services. We use the information you provide to process your applications and otherwise provide the product and services you request, as well as support for those products and services. We may use your PII to send you information and advertising about our company and its products and services including without limitation to provide you with products and services you have expressed interest in, requested, and/or purchased. We also reserve the right, but not the obligation, to contact you regarding changes to this Privacy Policy and other matters relevant to the Site.

INFORMATION AUTOMATICALLY COLLECTED

When you visit our Site, we may collect some information automatically. By collecting this information we get a better understanding of your needs and what products and services we can develop to meet those needs. Some of the information we automatically collect is necessary for the proper functioning of the Site, such as cookies as explained below. All the information we gather helps us understand your preferences and how well our Site is functioning so we can continually improve your online experience with us.

  1. Links, Embedded Content, and Buttons

    We may keep track of how you interact with links across our services, including our email notifications. We do this to help improve our services, provide information and advertising, and to be able to analyze aggregate click statistics such as how many times a particular link was clicked on. This Site may contain links to other websites, content embedded in our Site that comes from or relates to other websites and services, and buttons from other websites and services such as social media websites like YouTube, Facebook, Twitter, Pinterest, Foursquare, and Instagram. Several of these third parties may use cookies or other tracking devices to collect and track information about you across the Internet. We are not responsible for the privacy practices or the content of these other websites or their data collection practices. You should check the privacy policies of these other websites when providing personally identifiable information or to find out what other information they collect from users, whether while on their platform or website or in relation to links, buttons, or embedded media on the Site or elsewhere.

  2. Information From Your Computer

    We may ourselves, or through our third party service providers, collect information about your computer, such as the browser, operating system, IP address, country and other geolocation data, date and time of visit, whether you are using a mobile device, referring websites, the search engine queries you used to get to our Site, the pages of our Site you visit and your activities on our Site such as what images, videos, or other imbedded media you view, as well as the amount of time spent on our pages, and the number of pages visited. Some of this information may be collected using cookies, as further explained below. This information is used for a variety of purposes to improve our Site and its content, including without limitation to gather broad demographic data, identify trends and statistics, help diagnose problems with our server, and to administer our Site and its content. We may also collect and share information between pages of our Site for the proper functioning of our Site, as well as authentication. We may also use this information to provide you with information and advertising regarding our products and services.

  3. Cookies

    Our Site may use "cookies" to provide information on your computer. Cookies are pieces of data that a website can send to your browser, which may then be stored on your device. We may use both session and persistent cookies on our own or through our third party service providers as described below. Cookies may save your preferences while you are at our Site, such as allowing for persistent login on pages that require logging in, and we may use them to provide you with tailored information and tracking as you use our Site. Cookies help us, among other things, to determine which areas of our Site are popular by tracking hits to those areas, which may in turn allow us or our third party providers to provide you with targeted information or advertising regarding our products and services. By modifying your browser preferences, you have the choice to accept cookies, to be notified when a cookie is sent, or to reject cookies. The rejection or limitation of cookies by your browser may limit your ability to use the Site.

  4. Third-Party Service Providers

    We may use a variety of third-party services to help provide our services, to help us understand the use of our services, provide information and provide advertising regarding our Site and our products and services. Third party services providers may include, but are not limited to Google Analytics and a variety of third party social media platforms used such as YouTube, Facebook, Twitter, Pinterest, Foursquare, and Instagram. In addition, we may collect PII and other information in your applications for credit cards, loans, and other financial services, and that information may be shared with or directly collected through our Site by financial institutions such as Metropolitan Commercial Bank to process your application and provide services. These third-party service providers may collect, store, and share information as further dictated by the privacy policies and disclosures of those third parties.

    We may use services through companies such as Google and Facebook to target ads to you related to your usage of our Site, such as to display advertising for our Site, products, and services on other websites you visit based on your activities on our Site in the past. Google, Inc. may utilize the data collected to track and examine the use of this Site, to prepare reports on its activities and share them with other Google, Inc. services. Google, Inc. may also use the data collected to contextualize and personalize the ads of its own advertising network. You may view Google’s privacy policy here: http://www.google.com/intl/en/policies/privacy/, with more information located here: http://www.google.com/policies/privacy/partners/ (including information regarding how to control how information is shared through your Ads Settings) and here: https://support.google.com/analytics/answer/6004245?hl=en. You may opt out of Google Analytics data as instructed here: https://tools.google.com/dlpage/gaoptout/. Facebook similarly provides more information regarding the information it collects and how it is used in relation to advertising along with methods to opt out of collecting and sharing of information here: https://www.facebook.com/settings?tab=ads.

  5. Web Beacons

    We may employ Web beacons (also called single-pixel gifs), which are customized links or similar technologies, on the Site and when sending you messages, newsletters, or promotional emails or in using third party service providers. Web beacons allow us to (a) determine whether you have opened, or acted upon, a promotional email and which links you have clicked on in order to deliver to you more focused communications and other content, (b) allow us to count the number of users who have visited certain webpages and effectively deliver services, and (c) enable us to compile aggregated statistics and determine the efficacy of promotions by using Web beacons from third parties.

    We may combine information we collect from or about you from various sources including public information we obtain about you to identify you and to provide you with products and services, information, and advertising.

SHARING OF YOUR INFORMATION

We will not sell, rent or lease your information to others without your consent, except as provided in this Privacy Policy. In general, the information you provide will be used to support your customer relationship with us and to enhance and improve our Site, products, services, and advertising.

We may engage third party service providers, consultants, and independent contractors to perform functions and provide services for us including without limitation those third party service providers mentioned in this Privacy Policy. We may share the information we collect through our Site with these service providers so that they can perform services for us in relation to the Site and our business. For example, we may share your information with our advertising and email vendors so that they can provide services to us such as emailing you about our products and services. We may also share information we collect with service providers providing you services in relation to the Site as stated elsewhere in this Privacy Policy, including without limitation financial services such as prepaid debit cards, collateral loans and lines of credit.

When submitting information regarding jobs, the information you submit is used only for recruiting purposes and is not shared with any third party except for purposes of evaluating your application or inquiry. You authorize us to transmit and store your information in our recruitment database, and to circulate that information as necessary for the purpose of evaluating your qualifications for job vacancies at Jelli.

We may share information we collect about you between Jelli and their Affiliates. Affiliates, for purposes of this Privacy Policy, shall mean any parent or subsidiary entities and any entity controlling, controlled by or under common control of the entity, where "control" is defined as (a) the ownership of at least fifty percent (50%) of the equity or beneficial interests of such entity, (b) the right to vote for or appoint a majority of the board of directors, managers, governors or other governing body of such entity, or (c) the power to exercise a controlling influence over the management or policies of the entity.

In addition to the situations described above, we may use and disclose visitor information in special instances when we have reason to believe disclosing this information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interfering with our rights or property, other Site visitors, or anyone else. We may disclose visitor information when subpoenaed, for government investigations, and when we otherwise believe in good faith that the law requires it.

OTHER INFORMATION PRACTICES

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