Jenius Bank™ CCPA Disclosure
Last Updated: December 2024
This California Consumer Privacy Act Disclosure (“CCPA Disclosure”) explains how Jenius Bank, a division of SMBC MANUBANK, collects, uses, and discloses personal information subject to the California Consumer Privacy Act as amended by the California Privacy Rights Act (together, the “CCPA”). 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 the Jenius Bank Online Privacy Policy.
In addition to the purposes for uses and disclosures of personal information and sensitive personal information described above, we may use or disclose personal information and sensitive personal information obtained about you as reasonably necessary to comply with law and legal requirements, to cooperate with and respond to law enforcement requests, or as otherwise required by applicable law, court order or governmental regulation.
What Categories of Personal Information and Sensitive Personal Information Does Jenius Bank Collect?
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. Personal information does not include information that is publicly available, de-identified, or aggregated. Personal Information we collect about you may differ based on how you interact with us.The examples below describe the Personal Information we may have collected about you in the twelve months preceding the “Last Updated” Date, as well as our current practices. The examples provided in each category below are provided solely for illustrative purposes.CCPA Category Examples
| Category of Personal Information | Purpose for Collection, Use, & Disclosure of Personal Information |
|---|---|
| Identifiers, including your name, physical address, phone number, email address, or other similar identifiers | • Providing products and services • Providing customer service and responding to requests• Marketing and advertising our products• Conducting data analysis and research• Identifying and debugging errors that impair functionality• Permissible short-term transient use• Performing identity verification • Improving products and services• Auditing related to interaction with consumer• Helping to ensure security and integrity |
| Personal information as defined in Cal. Civ. Code § 1798.80(e), such as contact information and financial information | • Providing products and services• Providing customer service and responding to requests• Marketing and advertising our products• Conducting data analysis and research• Performing identity verification• Auditing related to interaction with consumer |
| Protected classifications under California or federal law, such as age, marital status, sex, and military status | • Providing products and services• Providing customer service and responding to requests• Conducting data analysis and research• Performing identity verification |
| Commercial information, such as information about past transactions or purchases, and products or services of interest to you | • Providing products and services• Providing customer service and responding to requests• Marketing and advertising our products• Conducting data analysis and research• Permissible short-term transient use• Performing identity verification• Auditing related to interaction with consumer |
| Professional/Employment information, such as your employment history and current employer | • Providing products and services• Marketing and advertising our products• Permissible short-term transient use• Performing identity verification |
| Internet or similar network activity information, such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement | • Marketing and advertising our products• Conducting data analysis and research• Identifying and debugging errors that impair functionality• Permissible short-term transient use• Helping to ensure security and integrity |
| Geolocation data, such as device location | • Marketing and advertising our products• Conducting data analysis and research• Identifying and debugging errors that impair functionality• Permissible short-term transient use |
| Audio, electronic, visual, or similar information, such as call and video recordings | • Providing products and services• Conducting data analysis and research• Providing customer service and responding to requests• Auditing related to interaction with consumer |
| Education information, such as education records and date of graduation | • Providing products and services• Conducting data analysis and research• Permissible short-term transient use |
| Inferences derived from another category of personal information, such as deriving products of interest from other personal information we have collected about you | • Providing products and services• Marketing and advertising our products• Conducting data analysis and research• Permissible short-term transient use |
| Category of Sensitive Personal Information | Purpose for Collection, Use, & Disclosure of Personal Information |
|---|---|
| Information that reveals social security, driver’s license, state identification card, or passport number | • Providing products and services• Providing customer service and responding to requests• Performing identity verification• Helping to ensure security and integrity |
| 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 | • Providing products and services• Providing customer service and responding to requests• Performing identity verification• Identifying and debugging errors that impair functionality• Helping to ensure security and integrity |
| A consumer’s precise geolocation | • Providing products and services• Providing customer service and responding to requests |
How Long Does Jenius Bank Retain These Categories of Personal Information and Sensitive Personal Information?
We retain personal information in compliance with our records retention schedule and for as long as needed based on the purpose(s) for which it was obtained and consistent with applicable law.The criteria used to determine our retention periods include:- whether the information is necessary to manage our business, manage your relationship with us, or satisfy the purpose for which the information was collected,
- whether there is a legal obligation we are subject to (for example, certain laws require the retention of records related to certain transactions for a certain period),
- whether we are subject to a contractual obligation, or
- whether the information is reasonably required to protect or defend our legal rights or property (e.g., due to statutes of limitation, litigation, or regulatory investigations).
How Does Jenius Bank Collect Personal Information and Sensitive Personal Information?
Jenius Bank may collect Personal Information and Sensitive Personal Information from the following categories of sources:- Directly from you.
- Service providers.
- Publicly available sources and registries.
- Business partners.
- External sources authorized to share information with us.
- Government entities.
- Cookies.
Who Does Jenius Bank Disclose Personal Information and Sensitive Personal Information To?
Jenius 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.
- External parties to whom you authorize or direct us to disclose your information.
- Government entities and others to whom we disclose information for legal or regulatory purposes.
Rights Under the CCPA
- The Right to Know. You have the right to request any or all of the following information relating to the personal information we have collected about you or disclosed in the last 12 months:
- The Right to Request Deletion of Personal Information. You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
- The Right to Opt Out of the Sale or Sharing of Personal Information. We do not engage in the sale or sharing of your personal information. If we decide to sell or share personal information in the future, we will update this Notice accordingly and provide a method of opting out of the sale or sharing.
- The Right to Correct Personal Information. You may request that we correct personal information that we maintain about you if you believe the information is inaccurate. We may request supporting documentation from you in connection with your request. You may also be able to correct certain personal information that we maintain about you by logging into your account.
- The Right to Limit the Use of Your Sensitive Personal Information. The CCPA grants individuals the right to limit the use and disclosure of their sensitive personal information to uses/disclosures that are reasonably necessary to provide goods and services, as needed to ensure security and integrity, to prevent fraud or illegal activity, for physical safety, for short-term, transient use, including for non-personalized advertising, to perform services on behalf of the business, to verify or maintain the quality or safety of a service controlled by the business, and to improve, upgrade, or enhance such services. Because we do not use nor disclose sensitive personal information to infer characteristics nor for other purposes not listed here, there is no need to submit a request to limit use and disclosure of your sensitive personal information.
- The Right to Non-Discrimination. You have the right not to receive discriminatory treatment for exercising any of the rights described above. However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.