Who we are

Trovex Bank, a top global commercial bank managing over 700 million in assets, is committed to protecting your privacy when you use Trovex Bank Digital Services worldwide. This Privacy Statement explains how we collect, use, share, and safeguard your information across our Digital Services.

Trovex Bank, together with its banking and non-banking affiliates, subsidiaries, and service providers (referred to as “Trovex Bank,” “we,” or “our”), prioritizes the privacy of our valued customers and visitors (“you” or “your”).

Our Digital Services encompass a wide range of financial solutions, including our websites, mobile applications, social media accounts, and other online platforms, which are accessible to individuals worldwide.

By utilizing our Digital Services, including visiting our websites, reading our emails, or engaging with us on third-party sites, you signify your consent to the terms and conditions outlined in this Privacy Statement, unless a different online and/or mobile statement is explicitly indicated to replace this Statement.

Please note that this policy applies to individuals worldwide. Regardless of your geographic location, your information may be transferred or processed in countries worldwide, including those outside your home country.

Information We Collect

Through our Digital Services, we collect various types of information to deliver our services effectively. These include:

1. Personal Information: We collect personal information that directly or indirectly identifies individuals. This includes data you provide on our forms, surveys, applications, or similar online fields. Examples of personal information we may collect include your name, postal address, unique device identifier, email address, telephone number, Social Security number, date of birth, account information, or IP address.

2. Anonymous Information: We collect anonymous information that cannot reasonably be used to identify specific individuals. This information may include data about your internet browser, information gathered through tracking technologies, and aggregated or de-identified data.

3. Location Information: Certain mobile applications may collect location information to identify your physical location. This information is obtained from location-aware features on your mobile device when you request services dependent on your physical location.

4. Biometric Information: Biometric information encompasses physical or behavioral human characteristics used for digital identification. This may include fingerprints, hand or facial geometry or patterns, voice characteristics, typing cadence, and signatures.

5. Other Information: We collect additional information about your activity and usage of our mobile and Digital Services. For instance, we gather information about the browser, device, or applications you use to access our sites, your interactions with our platforms, and the pages you visit. Traffic and location data may also be collected.

How We Use Your Information

We utilize the information we collect through our Digital Services, either independently or in combination with other data, for various purposes, including:

• Personalizing your experience with Trovex Bank’s Digital Services to enhance your satisfaction and convenience.
• Responding to your inquiries, fulfilling your requests, and providing the necessary information you seek.
• Delivering marketing communications that we believe may be of interest to you, keeping you informed about relevant products, services, and offers.
• Providing important updates regarding our Digital Services, products, services, and changes to terms, conditions, and policies.
• Enabling you to apply for products or services, processing transactions, and assessing your eligibility.
• Verifying your identity, authenticating your access to our Digital Services, and confirming your location to ensure a secure user experience.
• Allowing your participation in surveys, market research, sweepstakes, contests, and similar promotions, as well as administering these activities effectively.
• Offering the use of financial planning tools through our Digital Services, storing entered information for future access, and providing you with the option to save or decline saving this data.
• Conducting data analysis, audits, and usage trend assessments to evaluate the effectiveness of our campaigns, improve our products and services, and enhance the functionality of our Digital Services.
• Enhancing risk control for fraud detection and prevention, complying with laws and regulations, and meeting legal process and law enforcement requirements.
• Granting you access to specific features of our Digital Services by utilizing information from your device, such as contact lists or geo-location, to provide tailored and location-based services.
• Utilizing your information in other ways as required or permitted by law or with your consent.

How We Share Your Information

To ensure the efficient provision of our services, we may share your information with our affiliates and selected third parties worldwide for the following purposes:

• Sharing information with affiliated Digital Services and businesses worldwide to improve the quality of service across our diverse range of financial solutions, in accordance with applicable laws and regulations.
• Collaborating with third-party service providers who assist us in operating our business and delivering necessary services.
• Establishing partnerships with other companies to offer co-branded services, products, or programs that add value to your banking experience.
• Sharing information with third parties or affiliates in the context of corporate transactions, such as sales, consolidations, or mergers of Trovex Bank businesses.
• Disclosing information to comply with legal requirements, such as applicable subpoenas and court orders, to enforce our terms of use, rights, or policies, address fraud, security, or technical issues, respond to emergencies, or protect the rights, property, or securityof our customers or third parties.

For customers worldwide, we utilize and share information collected from or about you in accordance with the Customer Privacy Notice applicable to your account. The Customer Privacy Notice provides choices regarding the use and sharing of information.

As a global company, we may share your personal information among Trovex Bank’s affiliated Digital Services, businesses, and service providers located in various countries worldwide. This ensures the provision of high-quality products and services.

We may also share anonymous or aggregated information with third parties to improve product offerings, provide better-tailored content, and for other purposes.

Trovex Bank Mobile

Our mobile app, available worldwide, offers access to our Digital Services. When using our mobile app, we collect information such as your unique device identifier, screen resolution, geo-location (with your permission), and other data used for anonymous analytical purposes. Please refer to the respective terms of use and privacy policies of each Trovex Bank mobile app for further details. The Trovex Bank US Mobile App is developed by HSBC Global Services (UK) Limited.

Use of Aggregation Tools through Trovex Bank Digital Services

If you utilize our money management tools or online aggregation services, we collect information about your accounts, including registration information such as your name and email address. Additionally, we gather details about designated accounts used with these tools, such as account balances, transactions, payment history, and other related activity. We do not disclose information obtained solely through money management tools to non-affiliates unless necessary for providing the intended services or as required by law. This information may be used to offer you other Trovex Bank products and services that may be beneficial. For further details, please refer to the money management tools section of the Personal Internet Banking Terms and Conditions.

Cookies & Other Technologies

Our Digital Services worldwide use cookies and other technologies to improve user experiences. Cookies are electronic information bits transferred to your devices to record your usage and visits, enhancing future interactions. Temporary “session” cookies facilitate navigation during your visit and are deleted when you close your browser. “Persistent” cookies remain on your computer after your visit to identify your preferences and enhance future visits.

Log files anonymously track website actions, providing insights into browsing habits and assessing digital activity. These log files enable us to analyze interest in specific promotions, troubleshoot technical concerns, and improve our Digital Services. They are used internally, are anonymous, and not associated with any specific user, device, computer, or browser.

Web beacons embedded in our Digital Services’ images assist in analyzing website traffic patterns and user engagement. These technical methods may transmit information to us or authorized third parties. We also utilize web beacons in emails to determine if recipients have opened or interacted with the content. Information from these technical methods may be collected in a personally identifiable format.

Behavioral Advertising/Online Tracking

We may use information about your online activities, combined with other data, to select advertisements, products, or offers aligned with your interests. This online behavioral advertising (OBA) or interest-based advertising allows us to provide personalized content. You have the option to exercise choice regarding information collection for interest-based advertising purposes by visiting sites such as the Network Advertising Initiative and Digital Advertising Alliance. Opting out ensures that online advertising is not tailored to your behavior or usage.

At present, Trovex Bank does not respond to web browser “do not track” signals. We await guidance from the policy community and industry to determine the appropriate response and implementation.

To develop our Digital Services, we may work with third parties worldwide to track usage patterns within our platforms. These third parties provide statistics on page visits, duration, and other anonymous information. This information helps us plan improvements and ensure our services meet the diverse needs of our global customer base.

Third-Party Links

Certain links within our Digital Services may redirect you to external websites or display information from other sources. These linked sites may have different terms and conditions, privacy provisions, and confidentiality policies than Trovex Bank’s Digital Services. Such links are provided for convenience, and their inclusion does not imply endorsement of the services, content, or sponsoring organizations by Trovex Bank or its affiliates. We assume no responsibility or liability for the accuracy, reliability, completeness, or opinions expressed on linked sites, as they are not monitored or investigated by Trovex Bank. It is your responsibility to evaluate the accuracy, reliability, timeliness, and completeness of any information available on linked sites. Products, services, and content obtained from linked sites are provided “as is,” without any warranties.

Security

Safeguarding your information is a top priority for Trovex Bank globally. We implement physical, technical, and procedural safeguards in compliance with applicable legal standards to protect your information from unauthorized access, use, alteration, or destruction. Please refer to the Security section on our website for further details.

Social Security Number Protection Policy

Trovex Bank, in the normal course of business and as required by law, may collect Social Security numbers to establish, maintain, and service customer accounts. We implement reasonable measures to protect and limit access to these Social Security numbers, prohibiting their unlawful disclosure. Social Security numbers are classified as “Restricted” information under Trovex Bank’s Information Security Risk Policy and Information Classification Policy. Authorized Trovex Bank team members and others with a legitimate business need-to-know access Social Security numbers in accordance with applicable laws and regulations.

Social Media

Trovex Bank maintains a presence on various social media platforms worldwide, including Facebook, Twitter, YouTube, and LinkedIn. These platforms facilitate online sharing and collaboration among registered users. Please note that when visiting any official Trovex Bank social media site, this Privacy Statement, along with the respective terms and conditions of each social media platform, applies. For more information, please refer to the Trovex Bank Social Media Terms and Conditions.

State Specific Data Privacy Rights

Regardless of your location, you may have specific data privacy rights. For customers based in the United States, please refer to the relevant state-specific privacy noticesfor information regarding your privacy rights. Additionally, if you are a California resident, please review the California Consumer Privacy Act (CCPA) Statement for details on your privacy choices.

Children’s Online Privacy Protection Act

Our Digital Services are not directed towards children, and we do not knowingly collect personal information from individuals under the age of 13 without parental consent.

Updating Your Information

Keeping your account information up-to-date is crucial. If you believe your account information is incomplete or inaccurate, please contact us through our Customer Service page or reach out to an Trovex Bank representative or designated relationship manager.

Data Retention and Deletion

We retain your information for the duration of our relationship with you in compliance with our data retention policy and applicable laws.

Changes to this Privacy Statement

As we continually enhance our global online privacy practices, we may update this Privacy Statement. Any updates will be reflected in the “last updated” date at the bottom of the Statement. Your continued use of our Digital Services following the posting of updates signifies your acceptance of the revised Statement and consent to the identified use and sharing provisions.

For any further inquiries or concerns regarding the processing of your personal information, please contact us at the provided contact information. We are committed to addressing your privacy-related requests promptly and effectively.