Consumer Privacy Disclosure
Our Commitment to Your Privacy
The Compass family of companies values your trust and respects the privacy of your personal financial information. As part of our commitment to you, we want you to be informed about our policies to protect and safeguard your information.
We are committed to protecting your privacy and maintaining the security of your information. When we share information within or outside the Compass family of companies, we follow strict security standards, maintain confidentiality policies, and comply with applicable laws regarding the use of customer information. Our aim is always to deliver improved service and quality products to meet your needs.
Information About Our Privacy Disclosure
This disclosure describes our privacy practices applicable to the information of our individual customers who obtain a product or service primarily for personal, family, or household purposes. This disclosure is made on behalf of the following companies in the Compass family:
- Compass Bank
- Compass Brokerage, Inc.
- Compass Consulting and Benefits, Inc.
- Compass Financial Corporation
- Compass Insurance Agency, Inc.
- Compass Mortgage Corporation
- Capital Investment Counsel, Inc.
- St. Johns Investment Management Company
(also doing business as St. Johns Wealth Management) - Stavis, Margolis Advisory Services, Inc.
This disclosure statement takes the place of all previous notices or statements of the above-listed companies, or their predecessor companies, involving privacy and use of consumer information and is subject to change at any time. This disclosure statement is provided under the federal Gramm-Leach-Bliley and Fair Credit Reporting Acts. Compass affiliates also will comply with any applicable state laws that impose additional requirements relating to privacy and use of consumer information.
Collection of Information
We collect, retain, and use information about you when we reasonably believe that it will help conduct our business or provide products, services, and other opportunities to you. For example, we use your information to protect and administer records, accounts, and funds; to comply with certain laws and regulations; to help us design and improve our products and services; and to understand your financial needs so we can provide you with quality products and superior service.
Information about you is collected from several sources, such as:
- Information you provide in applications for products and services and through other means (for example: assets, income, and debts);
- Information about your transactions and experiences with us and our affiliates (for example: account balances, account activity and usage, and payment history);
- Information we receive from consumer reporting agencies and other outside sources (for example: creditworthiness, credit history, and employment verification); and
- Information we gather at your request or with your consent from third parties (for example: to assist us with servicing your account(s), providing special services to you, or preparing offers for other products).
Our Information-Sharing Practices With Outside Parties
We may disclose customer information we collect, as described above in "Collection of Information," to non-affiliated third parties as permitted by law. For example, we may disclose customer information about you to credit reporting agencies, in response to a subpoena or court order, as required by certain federal and state laws, to help complete a transaction initiated by you, and pursuant to your request or authorization.
We also may disclose customer information we collect to companies that perform services or functions on our behalf--such as account processing, check printing, marketing services, and consulting services--and to other financial institutions with which we have joint marketing agreements—such as banks, insurance providers, commercial or consumer leasing companies, securities brokers or dealers, and investment companies. Joint marketing agreements with other financial institutions allow us to bring information to you about financial products and services that are different from those we provide. We require our service providers and those with which we jointly market financial products or services to adhere to confidentiality standards governing the privacy of your information. These companies may use and disclose the information we provide to them only for the purposes for which it is provided or as otherwise permitted by law.
We do not sell your customer information to outside marketers to allow them to independently solicit you for a product unless we first ask your permission to send your information.
Our Information-Sharing Practices Within the Compass Family of Companies
Information About Our Experiences and Transactions With You
The Compass family of companies consists of financial service providers such as banks, insurance agencies, brokerage companies, leasing companies and other financial services companies that work together to serve you. These companies are our affiliates. By sharing your information with our affiliates, we are able to serve you more efficiently and conveniently. We are permitted by law to share with our affiliates information about our own transactions and experiences with you and your accounts. This type of information includes, but is not limited to, identification information, account balances, account transactions, and payment history information. For example, our affiliates may use transaction and experience information to provide you with information about additional products and services, to evaluate and improve existing products and services, and to help identify you as our customer to prevent unauthorized access to your information. If you choose to limit marketing (see box below), then our affiliates will not use any information we share with them about your transactions and experiences with us to make a marketing solicitation to you. This will not prevent us from sharing this type of information with them, but will restrict their use of that information. This restriction will not apply in certain circumstances, such as if you currently do business with one of our affiliates or if you ask to receive information or offers from them.
Information That Is Not About Our Experiences and Transactions With You
We also may share certain information with our affiliates in the Compass family that is considered credit information but is not information about our own transactions and experiences with you. Examples of this type of information include:
- information in an application, such as your income, marital status and assets;
- information we obtain to verify representations made by you, such as your open lines of credit;
- information we obtain from a consumer credit report, such as your credit score and credit history; and
- information we obtain from a person or company regarding its employment, credit, or other relationship with you, such as your employment history.
Our affiliates may use this information in determining your eligibility for consumer loans, brokerage services, insurance, and similar products and services they offer. If you choose to limit marketing (see box below), then we will not share any of this type of credit information with our affiliates to use for credit purposes, such as determining your eligibility for or soliciting you for their products or services. This will prevent us from sharing your credit information with our affiliates except for other uses, such as performing technical or operational support services. Examples of technical and operational support services include preparation of account statements, data processing services, and underwriting services.
Your Choice To Limit Marketing
You may limit our affiliates from marketing their products or services to you based on information that we share with them, such as your income, your account history with us, and your credit score.
To limit marketing offers, call us toll free at 1-800-275-7219.
Things You Should Know About Making A Choice to Limit Marketing By Our Affiliates
As long as you remain a customer, you only have to tell us once to limit marketing by our affiliates based on information we share with them. If you have chosen to "opt out" of our sharing credit information with affiliates in past years and have continued to be a customer, your "opt out" will also limit marketing based on other information we share, as described in this disclosure. Joint account holders may limit sharing of information for each other. If we receive a request to limit information sharing for only one joint account holder, we can continue to share information about other account holders.
If you stop doing business with us, your choice to limit marketing by our affiliates will continue to apply to the information we have collected while you were a customer for as long as that information remains on our systems. If you become a customer again after you have stopped doing business with us, however, you will have to tell us again to limit marketing by our affiliates based on information we share about you related to your new account(s). This is because we remove all information about former customers, including choices to restrict marketing, from our systems after a period of time in order to safeguard the information.
Other Types of Information
Certain trust and fiduciary account information maintained by Compass Bank's trust division (known as the Compass Bank Wealth Management Group) may be subject to special protections from disclosure under applicable fiduciary laws and our own policies and practices to carefully safeguard such information.
We may receive health or medical information about you, for example, in connection with an application for insurance. We will not use health and medical information, or share that information with our affiliates, except as necessary or appropriate to process your application or transaction, provide services requested by you, or to maintain your account information. We will comply with all applicable laws or regulations governing the disclosure of health or medical information.
Security of Your Information
Our commitment to the privacy of your information includes maintaining the security of your information. We use physical, electronic, and procedural safeguards to help prevent unauthorized access to customer information. We periodically test and update our safeguards to help ensure the protection and integrity of our customer information.
We train and regularly educate our employees about the importance of maintaining the confidentiality of customer information and the proper handling of customer information. All of our employees are governed by a code of conduct that authorizes access to customer information for business purposes only and includes strict standards for keeping your information confidential.
Maintaining Accurate Information
Our procedures help assure that your financial information is accurate, current, and complete. You play an important part in helping us maintain accurate records by always reviewing your account statements, notices, payment coupons, tax reporting, and other information that we provide you. You also may have access to information about your account(s) through our customer service department and, if applicable, our Web site. If you ever believe any information we have about you is not complete or correct, please call us or follow the instructions on your account statement, if any.
Former Customers
Our policies and practices for the collection and disclosure of information about individual customers contained in this Consumer Privacy Disclosure apply to both current and former customers.
Online Banking Privacy
We employ proven processes and technologies to protect the privacy and security of your information when you bank online with us, such as firewalls, encryption techniques, and authentication procedures. If you visit our Web site or use any of our electronic banking services, we may put a "cookie" or similar file on your hard drive to facilitate navigation and personalize your experience. By using cookies, we can collect technical and navigational information, such as computer browser type, Internet protocol address, and other computer identification information, and match that with pages visited and time spent on our Web pages. This helps us improve our Web site. When you use our online banking services, we also may use the information in the cookie or similar file to match the Internet browser and computer you use with your online account for security purposes. We do not knowingly collect, maintain, or use personal information from our Web sites about children under the age of 13. For more information about our online security practices, please visit our Web site at: www.compassbank.com.
Revision date: 9/25/2007
