California Consumer Privacy Act (CCPA) Disclosure
Effective Date: August 23, 2023
This California Consumer Privacy Act Disclosure (“CCPA Disclosure”) explains how Manufacturers Bank collects, uses, and discloses personal information subject to the California Consumer Privacy Act (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”). It also describes the privacy rights of California residents under the CCPA and how they may exercise those rights.
This CCPA Disclosure applies solely to California residents and supplements all other applicable Manufacturers Bank privacy policies and notices.
What Information is Covered by the CCPA?
Under the CCPA, “Personal Information” is defined as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.
The CCPA does not apply to certain information, such as information subject to the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, and certain other state or federal privacy laws. For example, this CCPA Disclosure does not apply to information that we collect about individuals that is subject to our U.S. Consumer Privacy Notice.
What Categories of Personal Information Does Manufacturers Bank Collect?
Most of the information we have collected has been collected in the context of providing financial products and services, and therefore, is not subject to the CCPA. We also may collect Personal Information related to California residents in other contexts, including relative to our marketing activities, website traffic, or mobile applications.
In the past 12 months, we have collected the following categories of Personal Information, as defined in the CCPA, related to California residents. The examples provided in each category below are provided solely for illustrative purposes.
CCPA Category Examples
Identifiers: Name, address, email address, Social Security number, online identifiers, internet protocol address, or other similar identifiers
Personal information as defined in the California Customer Records Act, Cal. Civ. Code § 1798.80: Contact and financial information
Protected classifications under California or federal law: Age, marital status, sex, and veteran or military status
Commercial information: Information about past transactions or purchases
Biometric information: Voiceprints and behavioral characteristics derived from interactions with our websites or mobile apps
Internet or similar network activity information: Browsing history, search history, information about a consumer’s interaction with a website, application, or advertisement
Geolocation data: Device location
Audio, electronic, visual, or similar information: Call and video recordings
Inferences drawn from other personal information: Certain inferences concerning an individual’s preferences and characteristics
What Categories of Sensitive Personal Information (SPI) Does Manufacturers Bank Collect?
Manufacturers Bank may collect the following categories of SPI related to customers, employees, and/or job applicants (examples are provided solely for illustrative purposes):
Government ID — Social Security, driver’s license, state identification card, or passport number
Finances — account log‐in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
Geolocation — precise geolocation
Race, religion and union membership — racial or ethnic origin, religious or philosophical beliefs, or union membership
Communications — contents of certain private communications
Biometrics — biometric information processed for the purpose of uniquely identifying a consumer
Health — personal information collected and analyzed concerning a consumer’s health
How Long Does Manufacturers Bank Retain These Categories of Personal Information and Sensitive Personal Information?
As a regulated financial institution, Manufacturers Bank is required to retain records of the above categories of Personal Information and Sensitive Personal Information to meet numerous legal, compliance, and auditability requirements. All Personal Information and Sensitive Personal Information is continuously assessed against and retained in a manner to maintain compliance with these requirements.
How Does Manufacturers Bank Collect These Categories of Personal Information and Sensitive Personal Information?
Manufacturers Bank may collect Personal Information and Sensitive Personal Information from the following categories of sources:
- Directly from consumers
- Service providers
- Publicly available sources and registries
- Manufacturers Bank affiliates
- Business partners
- Third parties authorized to share information with us
- Government entities
Why Does Manufacturers Bank Collect These Categories of Personal Information and Sensitive Personal Information?
Manufacturers Bank uses Personal Information and Sensitive Personal Information for the following purposes:
- Providing products and services to consumers
- Identifying and preventing fraud
- Verifying your identity
- Conducting data analysis and research
- Improving products and services
- Marketing and advertising
- Maintaining internal systems and infrastructure
- Ensuring compliance with all other applicable laws and regulations
- Responding to civil, criminal, or regulatory requests
- For any other use disclosed at, or before the point of collecting the Personal Information
Manufacturers Bank may also use Personal Information for any one of the following specific “business purposes” described in the CCPA:
- Auditing related to a current interaction with the consumer
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity
- Identifying and debugging errors that impair functionality
- Permissible short-term transient use
Who Does Manufacturers Bank Disclose Personal Information and Sensitive Personal Information To?
Manufacturers Bank may disclose Personal Information and Sensitive Personal Information to the following parties:
- Our parent company - Sumitomo Mitsui Banking Corporation ("SMBC")
- Other SMBC affiliates
- Business partners
- Service providers
- Third parties with whom you authorize or direct us to share your information
- Government entities and others with whom we share information for legal or necessary purposes
In the past 12 months, we have not shared Personal Information relating to California residents in any manner that we consider a "Sale” or “Share” as defined by the CCPA.
Rights Under the CCPA
If you are a California resident, you may request that we disclose to you the following information covering the 12 months preceding your request:
- The categories of non-exempt Personal Information that we have collected about you and the categories of sources from which we collected such personal information
- The business or commercial purposes for collecting any non-exempt Personal Information
- The categories of non-exempt Personal Information about you that we have disclosed to third parties for a business purpose, and the categories of third parties to whom we have disclosed such Personal Information
- The specific pieces of non-exempt Personal Information we have collected about you
California residents also have the right to submit a request for deletion of non-exempt Personal Information, request to limit certain use of their SPI, and opt-out of automated decision making under certain circumstances. Although these rights apply only to non-exempt Personal Information or SPI and there may be legal, compliance, or business reasons that Manufacturers Bank will need to retain and use the information.
How to Make Requests
If you are a California resident and would like to exercise your right as stated above, please submit your request by:
To protect your information, we can only honor access or deletion requests upon receipt of a verifiable consumer request. Accordingly, we may require additional information to authenticate your identity before processing your request.