Privacy Policy

At Westwind Trust Alliance, your privacy is our priority. With over 10 years of trusted banking service, we are committed to protecting your personal and financial information. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our banking products, services, website, and mobile applications.

1. Information We Collect

We collect various types of personal information to provide and improve our banking services. This includes:

a. Information You Provide to Us

• Personal Identification Information: Name, address, email address, phone number, date of birth, Social Security number, driver's license number, and tax ID
• Financial Information: Income, assets, employment information, credit history, account balances, transaction history, and payment information
• Application Information: Information you provide when applying for accounts, loans, credit cards, or other banking products
• Communications: Records of your correspondence with us, including emails, phone calls, and chat messages

b. Information We Collect Automatically

• Device and Usage Information: IP address, browser type, operating system, device identifiers, pages visited, time spent on our site, and clickstream data
• Location Information: Approximate geolocation based on IP address or precise location if you enable location services
• Cookies and Similar Technologies: We use cookies, web beacons, and similar technologies to enhance your experience and analyze usage

c. Information from Third Parties

• Credit Reporting Agencies: Credit scores, credit history, and identity verification information
• Service Providers: Information from payment processors, fraud detection services, and identity verification partners
• Public Sources: Information from government records and publicly available databases

2. How We Use Your Information

We use your personal information for the following purposes:

• Provide Banking Services: Process transactions, maintain accounts, disburse loans, and provide customer support
• Verify Identity: Confirm your identity and prevent fraud, money laundering, and unauthorized access
• Improve Our Services: Analyze usage patterns, enhance our website and mobile app, and develop new products
• Communicate with You: Send account alerts, transaction notifications, policy updates, and marketing communications (with your consent where required)
• Comply with Legal Obligations: Meet regulatory requirements, respond to legal requests, and prevent financial crimes
• Protect Our Rights: Enforce our terms and conditions, protect our property, and ensure the security of our systems

3. Legal Bases for Processing

We process your personal information based on one or more of the following legal grounds:

• Contractual Necessity: Processing is necessary to provide banking services you have requested
• Legal Obligations: Processing is required to comply with banking regulations, anti-money laundering laws, and tax reporting requirements
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security, and service improvement
• Consent: For marketing communications and certain data collection practices, we may request your explicit consent

4. Information Sharing and Disclosure

We do not sell your personal information. We may share your information in the following circumstances:

a. Affiliates and Subsidiaries

We may share information with our affiliated companies for business purposes, including offering you additional products and services. You may opt out of certain affiliate sharing as permitted by law.

b. Service Providers

We share information with trusted third-party service providers who perform services on our behalf, such as payment processing, fraud detection, customer support, and marketing. These providers are contractually obligated to protect your information and may only use it for specified purposes.

c. Legal and Regulatory Authorities

We may disclose information to government agencies, law enforcement, or courts when required by law, subpoena, or legal process, or to protect our rights, property, or safety.

d. Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of the transaction. We will notify you of any such change.

e. With Your Consent

We may share your information with third parties when you have provided explicit consent.

5. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience. Types of cookies we use include:

• Essential Cookies: Necessary for the website to function properly (e.g., login sessions, security)
• Performance Cookies: Help us understand how visitors interact with our site
• Functional Cookies: Remember your preferences and settings
• Targeting Cookies: Used to deliver relevant advertising (only with your consent)

You can manage cookie preferences through your browser settings. However, disabling essential cookies may affect website functionality.

6. Data Security

We implement industry-standard security measures to protect your information, including:

• 256-bit SSL encryption for data transmission
• Multi-factor authentication for account access
• Firewalls and intrusion detection systems
• Regular security assessments and audits
• Employee training on data protection
• Secure data storage and access controls

While we strive to protect your information, no method of transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your login credentials.

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, including to:

• Maintain your account for the duration of our relationship
• Comply with legal and regulatory record-keeping requirements (typically 5-7 years after account closure)
• Resolve disputes and enforce our agreements
• Detect and prevent fraud

When information is no longer needed, we securely delete or anonymize it.

8. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information, subject to legal exceptions
• Restriction: Request restriction of processing in certain circumstances
• Portability: Request transfer of your data to another organization
• Opt-Out: Opt out of marketing communications and certain data sharing
• Withdraw Consent: Withdraw previously provided consent without affecting lawful processing

To exercise these rights, please contact us using the information in Section 13. We will respond within 30 days as required by law.

9. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe a minor has provided us with personal information, please contact us, and we will take steps to delete such information.

10. Third-Party Links and Services

Our website and mobile app may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies before providing any personal information.

11. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place, such as standard contractual clauses, to protect your information in accordance with this Privacy Policy.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be effective upon posting to our website. For material changes, we will provide notice via email or through your online banking account. Your continued use of our services after changes are posted constitutes your acceptance of the updated policy.

13. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• By Mail: Westwind Trust Alliance, Attn: Privacy Officer, 6500 Rockside Rd, Suite 210, Cleveland, OH 44131
• By Phone: +1 (337) 230-2816
• By Email: privacy@westwindtrust.com
• Online Form: www.westwindtrust.com/privacy-request

14. State-Specific Privacy Rights

California Residents: Under the California Consumer Privacy Act (CCPA), California residents have additional rights, including the right to know what personal information is collected, disclosed, or sold, and the right to opt out of the sale of personal information. We do not sell personal information. For a complete list of your CCPA rights, please contact us.

Virginia, Colorado, Connecticut, Utah Residents: Residents of these states have additional privacy rights under applicable state laws. Please contact us for more information.