Herring Bank’s Mobile Privacy Policy

Last updated: October 16, 2023

We want you to understand the types of information we access, collect, use, store, and transfer (“Process”) through our mobile banking application (our “App”), including when you are using the App as well as when the App is running in the background. We may disclose internally and appoint or remit certain information for operational purposes or to third parties to enhance your banking experience or as set forth otherwise in this Mobile Privacy Policy . Further disclosures relating to privacy may be found in the Herring Bank Online Banking Agreement and Disclosure, Deposit Account Terms and Conditions, Herring Bank Account Agreement and other agreements or disclosures governing your chosen Herring Bank products. For more information, you should also review our insert link to Privacy Policy, which more broadly governs our handling of your personal information.

The App processes your information only for the following limited purposes to:

• provide you with digital banking and related services (“Services”);
• to verify your identity;
• maintain,improve and provide our Services;
• tailor marketing efforts
• ensure our Services are working as intended, such as tracking outages or troubleshooting issues that you report to us to:
  • develop new Services and features;
  • provide you with personalized Services and content;
  • measure the performance of our App and Services;
  • communicate with you;
  • protect our institution and customers from fraud, abuse, security risks, and technical issues; and
  • accomplish any other specific purposes referenced or described in this Herring Bank Privacy and Security Policy.

We will always ask for your consent before using your information for a purpose that isn’t covered in this Herring Bank Privacy and Security Policy.

If you arrive at our App through an advertisement link, we may also record the webpage that you accessed the App from. When you register, access, and use the App, you provide us with personal and sensitive information that includes your name, password, government identifiers like your social security number (SSN) or driver’s license number, phone number, email address, place of employment, physical or mailing address, financial information, payment information, payment card information, credit information and account and other transactional activity information affecting third parties.

We may require Authentication Information (“AAI”), such as tokens or authentication codes to use our App for your protection and to maintain the security of your information.

Our App has the capacity to but is not enabled to collect your image or contact list information. If our App becomes enabled to collect your image or contact list information, we or an authorized third party will obtain your affirmative consent consistent with applicable law.

The App may request access to information stored on your device such as location, camera, contacts, images, or other features to enhance your user experience, improve our services and provide additional security to protect your account.

It is important for you to understand that:

• Before granting access to this information, you will be prompted to give the App that permission.
• If you do not wish to grant that permission, you may decline.
• If you later change your mind, those permissions can be updated in your device’s settings.

Some examples of infomration the App will request access to are:

• Location – your location is used to prevent fraudulent activity and display locations near you.
• Contacts/Contact Lists – access to your contacts and contacts lists lets you add contacts to use with features that allow you to send money via the App for contacts that you choose, and that information will not be shared.
• Camera Images – the App uses your camera to capture check images, take pictures of receipts, scan ID(s) or authorized QR codes.

Your consent to our access of your image and contact list information may be obtained by us or an authorized third party by requesting you to click an item, digitally sign a field or another method that will affirmatively obtain and record your consent to providing us or an authorized third party with access to your image and contact list information.

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. The information collected and Processed by the App is retained in accordance with state and federal record retention laws. Any third parties that collect or utilize your image or contact list information on our behalf are subject to confidentiality requirements which will require such parties to properly maintain the security of your information. Please contact us at (866)348-3435 or [email protected] regarding questions about this information or this Mobile Privacy Policy.

The information we, or other third parties may collect on our behalf includes cookies unique identifiers, browser type and settings, device type and settings, operating system, mobile network information including carrier name and phone number, and application version number. We may also collect information about your location, search history, device’s internet protocol, activity on the App and the interaction or selection of other apps, preferences, browsers, and devices interacting with our digital banking services.

Additionally, and as described in more detail below, your device may periodically contact our backend digital banking systems to provide information about your device and connection to the digital banking services. This information may include things like your device type and carrier name, crash reports, which apps you’ve installed, and, depending on your device settings, other information about how you’re using your mobile device.

We collect information about your activity in connection with our App, in order to better understand:

• your interactions and behavior associated with App content and features;
• the ways in which you are moving through and navigating the App;
• the Services and features that are most valuable to you;
• areas or stages of the App where you may disengage or get stuck; and
• your typical patterns of behavior in connection with the App.

The activity information we collect may include:

• logs, tags, reporting, and other analytics reflecting your specific use of screens, workflows, buttons, and features;
• logs, tags, reporting, and other analytics reflecting your navigation through, engagement with, and disengagement with the App;
• haptic information related to your use of your device (e.g., swipes, taps);
• your financial, payment, and transaction activity and history (including purchase history); and
• your navigation to or activity on third-party sites and apps linked to our App.

This information enables us to improve, modify, or expand the services, features, and experience delivered through the App as well as to support in-App messaging, deliver user guides and polls, and optimize performance of the App. Additionally, and in particular, this information also enables us to detect and flag suspicious or potentially fraudulent activity. We may be obligated to use, disclose or retain certain communication and information provided in accordance with applicable law or to maintain audit trails and for anti-fraud purposes.

We access and collect information related to your device and other Apps along with associated data. This information may be collected both while you use the App and while the App is running in the background or is otherwise not in use.

Information we Process concerning your device and other Apps include your:

• device type;
• device ID;
• other available device identifiers;
• device operating system;
• network and IP address information;
• cellular data carrier; and
• device and App diagnostic information.

Additionally, if our App needs to access protected features of your device, then you will have an opportunity to provide consent. In the event that you decline to provide express consent, then the App will not be permitted to access data gated by your device’s permissions model. Without your express consent, the App will not allow use of the protected feature or related data.

If and when our App accesses your:

• phone or contact book data;
• device location; or
• other background restricted permissions,

then all related data is treated as personal or sensitive data subject to this Herring Bank Privacy and Security Policy.

Restricted permissions accessed by our App include:

• Use of Fingerprint
  • We collect information about your biometric identifiers when you use our App, which enables us to streamline your authentication and login experience and access our Services with less friction.

• Precise or Fine Location
  • We collect information about your location when you use our App, which helps us offer features like search results for branch and ATM locations, credit card controls, and messages based on your general location.

• Read or Access Contacts, Contacts List, or Phone Log
  • We may collect information about your contacts when you use our App, which enables us to facilitate requested P2P and other payment transactions.
  • If this information is collected by us or a third party on our behalf, we will request your affirmative consent, consistent with applicable law.

• Access Camera or Pictures/Photos
  • We may collect information from your device’s camera and photos when you use our App, which enables use of mobile check deposit and other image scanning or capturing features of the App.
  • If this information is collected by us or a third party on our behalf, we will request your affirmative consent, consistent with applicable law.

Our App will only share information with third-parties with your consent, for the purpose of providing you with Services or marketing, or for the other ancillary purposes described in this Herring Bank Privacy and Security Policy.

Our App Processes your financial or payment information or government identification numbers and will never publicly disclose any personal and sensitive user data related to financial or payment activities or any government identification numbers.

Our App may Process non-public phonebook or contact information, and we don’t allow unauthorized publishing or disclosure of your or others’ non-public contacts.

Our App includes third-party code and software development tools that may collect personal and sensitive user data solely for the purposes described in this Herring Bank Privacy and Security Policy. All third-party providers of code and software development tools will Process your data in accordance with this Herring Bank Privacy and Security Policy and all applicable law and standards. We are committed to maintaining the security of your information, which is consistent with our core values and commitment to customer service. When you send information to us using our App, we use TLS (Transport Layer Security) or SSL (Secure Socket Layer) protocols to secure the transmission of information that you send to us. Once we receive information, we store and protect it using industry-standard firewalls and other technology. Please remember, though, that no method of electronic transmission or storage is 100% secure. Neither we nor our third-party providers will ever sell your personal and sensitive data Processed by the App.

The App may also transfer data as necessary for legal reasons including compliance with a valid governmental request, applicable law, or as part of a merger or acquisition with legally adequate notice to users.

The App handles all personal and sensitive user data securely, including transmitting it using modern cryptography.

You can limit sharing of information within the Herring family of affiliates as described in the insert link to Privacy Policy, To limit sharing, call (866) 348-3435, and ask to speak to a Herring customer service representative. Should you have any questions or concerns regarding your information or privacy-related issues, please contact us via any of the methods listed directly below:

Customer Service/Privacy
Herring Bank
2201 Civic Circle
Amarillo, Texas 79109
Via Email
[email protected]
Via Telephone
(866)348-3435

Upon your verifiable request using any of these methods, we will do our best to correct inaccurate information that we have concerning you.

We may need to make changes to this Privacy Disclosure from time to time, in order to reflect changes to our Websites or services, or to accommodate new technology or legal requirements and guidelines. Please check the links on our Websites to this Privacy Disclosure for any updates periodically. Information collected in connection with you use of our Websites after any changes to this Privacy Disclosure become effective will be handled in accordance with the revised Privacy Disclosure.