The Treasury Bank is an treasury banking network that operates as a proprietary non-consumer-based website at https://treasurybank.org (the “Treasury”). This Privacy Policy describes how (“we,” “us,” “our”) collect, use, share, and protect non solicited information, and your choices about the collection and use of business information. This Privacy Policy applies to all business information collected or processed through our data bank (collectively, the “Service”).
If you have questions about this Privacy Policy, please do not hesitate to contact us at contact@treasurybank.org
What is Proprietary Information?
Proprietary means one that possesses, owns, or holds the exclusive right to private business products and services that is used, produced, or marketed under the exclusive legal right of the inventor or maker that is protected by secrecy, patent, or copyright against free competition as to name, product, composition, or process of manufacture.
It is also information that, either alone or in combination with other information, identifies account holders. Examples of personal Information include, among others, name, email address, phone number, and mailing address of proprietorship, partnership, limited liability company, corporations, association or trust companies. When we combine Proprietary Information with other information (such as the name of the company you work for), we treat the combined information as Proprietary Information.
Types of Proprietary Information We Collect and Use
A. Information That You Provide to Us
We only request need-to-know information on this website. You may provide your email address on this website; this is optional, and you may choose not to provide it to us.
B. Information We Receive through Your Use
We collect the following types of information automatically through your use of the Treasury.
Cookies, Device Identifiers, and Similar Technologies
When you use or access Treasury Bank, we and/or our service providers may use cookies, device identifiers, and similar technologies such as pixels, web beacons, and local storage to collect information about how you use Treasury Bank.
Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of Treasury Bank may not be available, or some functionality may be limited or unavailable. Please review the help pages of your browser or mobile device for assistance with changing your settings.
Location Data
If you grant us access (via browser or device settings), we may collect information concerning the location of your device. We use this information to help personalize your service by providing you with more relevant information and to help expedite the insertion of your address when signing up for an account. You may deny us access to this information but doing so may make certain features unavailable.
Log File Information
When you use Treasury Bank, our servers automatically record information, including your Internet Protocol address (“IP Address”), browser type, referring URLs (e.g., the site you visited before coming to this website), number of clicks, and how you interact with links on Treasury Bank, domain names associated with your internet service provider, pages viewed, and other such information (collectively, “Log File Information”). Treasury Bank may also collect similar information from emails sent to you which then help us track which emails are opened and which links are clicked by recipients. We use Log File Information collected from our implementation of Treasury Bank to further our legitimate interests in securing company data by identifying potential threats and vulnerabilities, and in analyzing the effectiveness of our site to improve Treasury Bank’s function and content.
How We Use Proprietary Information
Currently, we do not use Proprietary information in any way other than to identify clients or members. However, we may in the future use Proprietary Information as necessary to provide the clients a high-quality experience on consent.
More specifically, we may in the future process proprietary Information to:
- Facilitate transactions ;
- Communicate with you about account transactions or provide you with information about the Treasury Bank’s content, product, or services;
- Send you requested information, such as newsletters;
- Enable secure use of the Service;
- Screen for and reduce fraud, spam, abuse, and security problems;
- Provide you with support;
- Show you content that may be of particular interest to you while you are on the Service;
- Improve our data bank, such as improving the content or organization, developing new platform features, identifying target audiences for our external advertising, and supporting publicity efforts;
- Comply with applicable laws and regulations (e.g., determining your eligibility to complete transactions on our system);
- Protect our rights or our property; and
- Use for other purposes related to the reasons for which you provide proprietary Information.
If the European Union General Data Protection Regulation (“GDPR”) applies, our legal basis for collecting and using the information described in this Privacy Policy will depend on the information concerned and the context in which we collect it. We collect proprietary Information from our members:
- Where we need it to perform a contract with you;
- Where the processing is in our legitimate interests (which include the purposes listed, above);
- Where processing is necessary for compliance with an applicable legal obligation; or
- If we otherwise have your consent
How We Disclose Proprietary Information to Others
Treasury Bank will not disclose proprietary Information about you to third parties except with your consent or as follows:
- To Service Providers: We may provide information, including proprietary Information, to third parties who work for us, such as companies that verify credit card information, process credit card payments, manage e-signing, analyze data, manage contact information and communications, remove repetitive information from customer lists, and provide marketing services. Further, our Site is hosted by third parties and we use third-party infrastructure monitoring services. These third parties may have inadvertent or incidental access to your data. These providers are not authorized to further disclose your data or to use your data for any purpose other than providing services to us.
- To Companies Involved in Mergers and Acquisitions Transactions: We may in the future sell all or part of our assets or be involved in a merger. Any information collected through the Service, including business Information, may be among the items sold or transferred.
- To Comply with Applicable Law or Protect against Fraud or Other Harm: When we believe disclosure is appropriate to comply with the law, to enforce our terms of use and other rights, or to protect the rights and safety of others. This may include exchanging information with government regulatory or law enforcement agencies, or with other companies and organizations for fraud protection and legal compliance.
How We Protect Personal Information
We have implemented security measures to protect business information from loss, misuse, and alteration. For example, we use bank-level security measures to protect sensitive commercial information (such as bank account information) from unauthorized use and disclosure. Your submissions of sensitive Proprietary Information on our website are encrypted using secure socket layer technology (SSL). We may update our security methods and procedures as appropriate. Nonetheless, it is important to note that no method of transmission of information over internet is free of security risk. Despite our security measures, Treasury Bank makes no guarantee that Proprietary Information will not be breached. We cannot assume responsibility or liability for unauthorized access to our servers and systems.
Retention of Business Information
We will retain your information for as long as your account is active or is needed to provide you with our system, and we will retain and use your information as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements.
Data Transferred from Outside the United States
If you are using Treasury Bank from outside the United States, please be aware that Information may be transferred to, stored, and processed in the United States. Although we take steps to provide adequate safeguards, the data protection laws of the United States might not be as comprehensive as those in your country. By using Treasury Bank, you consent to proprietary Information being transferred to the United States for the purposes described in this Privacy Policy.
Opting Out of Receiving Email Communication
With your permission, we may send notifications, promotions, or other information via email (“Communications”). You may follow the unsubscribe instructions in any email you receive. You may also send a global unsubscribe request to contact@treasurybank.org. Please note that certain Service-related Communications are necessary for the proper functioning and use of Treasury Bank (e.g., to provide you with confirmation of your account setup) and you may not have the ability to opt out of those Communications.
Your Rights
If you would like to access, amend, erase, export, or object to or restrict the processing of, proprietary Information about your business, you or your business may submit a request to contact@treasurybank.org. We will promptly review all such requests in accordance with applicable laws.
Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning proprietary Information. We encourage you to first reach out to us at contact@treasurybank.org, so we have an opportunity to address your concerns directly before you do so.
Children Online Privacy Protection
Treasury Bank is not directed to children. Accordingly, we will not knowingly collect any data from or about any person under the age of 16.
Change to Our Privacy Policy
We may change, modify, add, or remove portions of this Privacy Policy at any time. We will provide you with notice of material changes to the Privacy Policy as appropriate under the circumstances (e.g., by posting a notice on Treasury Bank; by sending an email to you if you are a registered user). Any changes or updates will be effective immediately upon posting to this page, I and the date of such change or update will be posted at the top of the page.
Identification
Treasury Bank policies, procedures and internal controls are designed to ensure compliance with all applicable BSA regulation rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our deposits. To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.
When you open an account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents. Rule: 31 C.F.R. §103.122(b)(5).
Each member shall provide Treasury Bank with contact information for the AML BSA and FinCen including:
- legal state issued picture ID or License
- name;
- title;
- mailing address;
- email address;
- telephone number; and
Comments
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymized string created from your email address (also called a hash) may be provided to a third party to see if you are using it. The third party service privacy policy is in the respect as Treasury Bank policy. After approval of your comment, your profile picture is visible to the public in the context of your comment.
Media
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
Cookies
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
Embedded content from other websites
Suggested text: Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
How long we retain your data
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
Where your data is sent
Visitor comments may be checked through an automated spam detection service.
Data Integrity
Treasury Bank is an assure that member data is accurate, complete, and consistent at any point in time. It’s important to maintain data integrity to protect sensitive information from unauthorized access and to ensure that data analytics are based on reliable information based on:
- Validation: Verify that data meets predefined criteria, such as data type, format, range, and uniqueness
- Access control: Limit data access to authorized personnel based on their roles and permissions
- Backups: Create backups of data
- Error checking: Use error-checking and validation procedures to identify and correct errors in data
- Security measures: Use encryption and other security measures to protect data
- Data entry training: Train employees on how to enter data correctly
- Audit trail: Keep an audit trail of data activities
- Penetration testing: Perform penetration testing and security audits
Treasury Bank use a subset of data quality measures that include accuracy, completeness, consistency, validity, uniqueness, and timeliness.
