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1. Introduction

This CCPA Privacy Notice for California Residents provides information that applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). Bank of Hope (the “Bank,” “we” or “us”) adopts this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”).

Bank of Hope is a financial institution subject to the Gramm-Leach-Bliley Act (GLBA) and its implementing regulations, and the California Financial Information Privacy Act and accordingly, part of the information we collect, use and share from California consumers is exempted from the CCPA (for example, non-public personal information).

For information on how non-public personal information is used and disclosed under GLBA, please see our GLBA Privacy Notice. We also have a separate privacy policy for our employees or prospective employees.

2. Collection, Sources and Use of Personal Information

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information” or “PI”).
Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like personal information covered by certain sector-specific laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“CFIPA”), the Driver’s Privacy Protection Act of 1994 among other exemptions.


In the table below we provide the list of categories of PI that Bank of Hope has collected within the last twelve (12) months and some examples for a better understanding. We also have identified the main sources and purposes for collection:

Personal Information Examples Table
Categories of Personal Information Examples Collected Sources of PI Purposes for PI Collection
A. Personal Identifiers This may include but is not limited to: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, username, Social Security Number, or other similar identifiers. Yes Consumer directly (e.g. forms you complete or services you obtain from us)

Consumer indirectly (e.g. from activity on our websites or applications)
Performing customer services, processing and managing interactions and transactions

Security and debugging

Analytics

Advertising and marketing activities of Bank of Hope

Quality assurance
B. Personal Records This may include but is not limited to: A name, telephone number, address, signature, passport number, insurance policy number, bank account number, credit card number, debit card number, or any other financial information Yes Consumer directly Performing customer services, processing and managing interactions and transactions

Security and debugging

Analytics

Advertising and marketing activities of Bank of Hope

Quality assurance
C. Protected classification characteristics under California or federal law This type of PI may include but is not limited to: sex, marital status, familial status, race, and gender identity, age, disability. Yes Consumer directly (this PI may potentially be captured depending on the information you exchange via email with BoH) Security and debugging
D. Commercial Information This may include but is not limited to: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Yes Consumer directly

Consumer indirectly
Performing customer services, processing and managing interactions and transactions

Advertising and marketing activities of Bank of Hope
E. Biometric Information This may include but is not limited to: physiological, or biological characteristics used as a form of identification and access control, such as, fingerprints, faceprints, and voiceprints. No N/A N/A
F. Internet or other similar network activities This may include but is not limited to: search history, information on a consumer's interaction with a website, application, or advertisement. Yes Consumer directly

Consumer indirectly
Analytics

Advertising and Marketing activities of Bank of Hope
G. Geolocation Data This may include but is not limited to: location based on IP address. Yes Consumer indirectly Analytics

Advertising and Marketing activities of Bank of Hope
H. Sensory Data This may include but is not limited to: Audio (voicemails), electronic, visual, or similar information. Yes Call Center

CCTV security cameras
Performing customer services, processing and managing interactions and transactions

Compliance with regulatory requirements

Quality assurance Analytics

CCTV Security
I. Professional or Employment Related Information This may include but is not limited to: professional education, or employment related information. Yes Consumer directly Providing services
J. Non-public Education Records This may include but is not limited to: Education records directly related to a student maintained by an educational institution, such as grades, transcripts, class lists, or student disciplinary records. No N/A N/A
K. Inferences drawn from other personal information This may include but is not limited to: Profile reflecting a person's preferences, characteristics, predispositions, behavior, or attitudes. Yes Consumer directly

Consumer indirectly
Advertising and marketing activities of Bank of Hope

For additional information on the purposes listed in this chart, you can find some examples in the list below:

  • Performing customer service, processing and managing interactions: To fulfill or meet the reason you provided the information. For example, to respond to your inquiries or process your requests and transactions, for documenting and archiving safe deposit box or to manage the ticketing system for the call center.
  • Security and debugging: To create, maintain, customize, and secure your account with us. To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
  • Quality assurance: To guarantee the quality of our services, websites and products, including to investigate and address your concerns and monitor and improve our responses.
  • Compliance with regulatory requirements: To prevent transactional fraud, respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. According to applicable law, we may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Bank of Hope’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our customers is among the assets transferred.
  • Advertising and marketing activities of Bank of Hope: For example, providing content and product offerings relevant to your interests via our Website sweepstakes, email marketing, text messages (with your consent, where required by law) or other mechanisms.
  • Analytics: For research and analysis of your interactions with our call center, Website, applications, and online platforms to improve our products and services, and for product development. For example, we use Google Analytics on our Website to count the visitors of our Website, identify the pages most visited and improve our services and offerings; however, we have implemented mechanisms to limit the type of information Google accesses when providing this service and, also how it is used.
  • CCTV Security: Monitoring Bank of Hope’s offices and locations for security purposes.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA Privacy notice.

Subject to restrictions and obligations of the CCPA, our service providers may also use your PI for some or all the above listed business purposes.

3. Disclosure and Business Purposes

At times, Bank of Hope engages service providers, and other qualified vendors for the same business purposes for which we collect such PI as described in the previous section, to that end a contractual agreement is signed with each vendor to restrict the use of your PI.

In the description below we provide categories of PI that Bank of Hope has disclosed to our service providers within the last 12 months.

Note that the categories of service providers listed in the chart below do not represent an exhaustive list but provide a better understanding of vendors we usually engage.

Disclosure of Business Purposes Table
Categories of Personal Information Collected Is PI shared for business purposes? Categories of service providers with whom PI has been shared for business purposes
A. Personal Identifiers Yes Service Providers and Vendors such as Internet Service Providers (ISP), security audit, and quality assurance services, software and IT providers, sales/marketing, analytics and advertising providers
B. Personal Records Yes Service Providers and Vendors such as ISP, security audit, and quality assurance services, software and IT providers, sales/marketing and advertising providers
C. Protected classification characteristics under California or federal law. Yes Information security providers
D. Commercial information Yes Service Providers and Vendors such as ISP, security audit, software and IT providers, sales/marketing and advertising providers
E. Biometric information No N/A
F. Internet or another similar network activity Yes Service Providers and Vendors such as ISP, security audit, software and IT providers, analytics, sales/marketing and advertising providers
G. Geolocation data Yes Service Providers and Vendors such as ISP, security audit, software and IT providers, analytics, sales/marketing and advertising providers
H. Sensory data Yes Service Providers and Vendors such as ISP, security audit, software and IT providers, and quality assurance services
I. Professional or employment related information. Yes Service Providers and Vendors, such as for advertising or marketing purposes, ISP, software and IT providers
J. Non-public Education Records No N/A
K. Inferences drawn from other personal information. Yes Service Providers and Vendors such as ISP, software and IT providers, analytics, sales/marketing and advertising providers


4. Disclosure of the Purposes of "Sale"

In the description below we provide categories of PI that Bank of Hope has “sold” (as the term “sell” is defined by the CCPA) within the last 12 months:


Disclosure of Purposes Sale Table
Categories of Personal Information PI "Sold" Purpose for selling Categories of third parties with whom PI has been sold
A. Personal Identifiers Yes Online identifiers such as cookies and pixel tags are used for analytics on our website/ applications to optimize our ads and marketing initiatives. For example, we count the number of times you have visited our website and remarket to people who have already taken action on our website. Data analytics and Social network providers
B. Personal Records No N/A N/A
C. Protected classification characteristics under California or federal law. No N/A N/A
D. Commercial information No N/A N/A
E. Biometric information No N/A N/A
F. Internet or another similar network activity Yes Data Analytics and social network providers that we use for our online advertising initiatives may have some type of access to this PI Data analytics and Social network providers
G. Geolocation data Yes Social network providers that we use for our online advertising initiatives may have some type of access to this PI Social network providers
H. Sensory data No N/A N/A
I. Professional or employment related information. No N/A N/A
J. Non-public Education Records No N/A N/A
K. Inferences drawn from other personal information. Yes Data Analytics and social network providers that we use for our online advertising initiatives may have some type of access to this PI Data analytics and Social network providers

You have the right to Opt-Out of these selling practices at any time. For more information, please see Section 7.E below on how to exercise your “do not sell” rights or click .

5. Other Legal Disclosures

In certain circumstances, Bank of Hope may use or disclose your PI when authorized by law, public authorities, courts or law enforcement, or when required to protect our legal rights. See some examples below:

  • Sometimes, we refer clients to our wealth management partners, however this only happens upon customers’ request with their prior opt-in authorization. In these cases, a contractual relationship is often established between the customer and the wealth management partner.
  • We may also share your personal information as part of a merger, acquisition, bankruptcy, or other transaction in which a third party takes control of all or some parts of our business. Any changes to this Policy after the takeover will be communicated to you by that third party.

6. Our Policy Towards Children

Bank of Hope does not knowingly collect PI directly from minors and does not sell PI from minors. Any information we collect from minors is always with the consent of a parent or guardian. If you are under 16 years old, do not use or provide any information on our Website or on or through our services. For additional information on your California privacy rights, please follow the instructions in the next Section 7.

7. Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes those CCPA rights and explains how to exercise those rights.

  1. Right to Know
  2. Right to Delete
  3. Right to Opt-Out
  4. Non-Discrimination
  5. How to Exercise your California Privacy Rights

A. Right to Know

You may have the right to send us a request, no more than twice in a 12-month period, for any of the following:

  • The categories of personal information (PI) we collected about you.
  • The categories of sources for the PI we collected about you
  • Our business or commercial purposes for collecting or selling that PI.
  • The categories of third parties with whom we share that PI.
  • A list of the categories of PI disclosed for a business purpose or that no disclosures occurred.
  • A list of the categories of PI sold about you, or that no sale occurred. If we sold your personal information, we will explain the categories of your PI we have sold and the categories of third parties to whom we sold your PI.
  • The specific pieces of PI we collected about you. You can obtain a transportable copy of your PI that we have collected during the 12 month period prior to the request date. This type of request requires a stricter verification standard.

B. Right to Delete

Except to the extent we have a basis for retention under applicable law, you may request that we delete your personal information that we have collected directly from you and are maintaining -–We are not required to delete your PI that we did not collect directly from you.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another customer to exercise their free speech rights, or exercise another right provide for by law.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation or when otherwise authorized by law, including the CCPA.
  • Make other internal and lawful uses of that information that are compatible with the context in which your provided it.

C. Right to Opt-Out

In the previous Section 4 above, we provide categories of PI that Bank of Hope has “sold” (as the term “sell” is defined by the CCPA) within the last 12 months. These categories of PI mainly involve online identifiers and your interactions with our website/applications that we have shared with our social media vendors and analytics providers to optimize our ads and obtain statistics.

You have the right to Opt-Out of these selling practices at any time. Note that we do not knowingly sell the PI of consumers we know are under 16.

For more information on how to exercise your do not sell rights, please see Section 7.E below or click .

D. Non-Discrimination

We will not discriminate against you for exercising your CCPA rights.

According to the law, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data.

In addition, we may offer you financial incentives for the collection, sale and retention and use of your PI as permitted by the CCPA that can; result in reasonably different prices, rates, or quality levels. Participating in these programs is entirely optional and requires your opt-in consent. If we decide to offer one of these programs, we will provide you with additional details in advance.

E. How to Exercise your California Privacy Rights

a. Exercising Your Right to Know and Deletion Rights

Mechanisms to submit Requests to Know and to Delete: To exercise the right to know and the right to delete, please submit a verifiable consumer request to us by either:

  • Completing an Online form by clicking here
  • Calling us at our toll-free telephone number: (888) 811-6272

Call Center Business Hours
Mon-Fri: 5:30 am - 6:00 pm (PST)
Sat: 6:00 am - 1:00 pm (PST)

Initial Identification and Verification: Any request to know or request to delete that you submit to us is subject to an identification and verification process. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Making a verifiable consumer request does not require you to create an account with us. However, we cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request.

Process: Once the initial identification and verification process is complete, we will send you an acknowledgement of receipt within 10 days from receiving your request and a reference number. If you submit the request via the toll-free telephone number, we will provide you with the reference number during the call to confirm receipt of your request.

When you submit an online request to delete PI, we will confirm your request before proceeding to the deletion.

For requests to know specific pieces of PI, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

On some occasions, we may not be able to comply with your requests. This could be in instances where we cannot verify your identity, when compliance with your request(s) would cause unreasonable risk to the security of PI, your account or the security of our systems and network, when it would be in breach of applicable federal or state laws, or because compliance might infringe data privacy rights of other individuals whose details are contained in it, among others. If this is the case, we will inform you in writing and explain the reasons.

Time period: We will endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 45-90 days), we will inform you in writing.

Designating an authorized agent: To exercise any of these privacy rights you can also designate another person to act on your behalf. We will need this person to provide us with a written authorization (such as a Power of Attorney) to show that you gave them your permission to submit information requests on your behalf.

Fees: We will typically not charge a fee to fully respond to your requests; however, we may charge a reasonable fee if we consider that your request is excessive, repetitive, unfounded or overly burdensome. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

To obtain this information in an alternative format: If you require this notice to be provided in a different format (e.g., audio), please contact us using the following mechanisms:

  • Online form found here
  • Toll-free telephone number: (888) 811-6272

Call Center Business Hours
Mon-Fri: 5:30 am - 6:00 pm (PST)
Sat: 6:00 am - 1:00 pm (PST)

8. Changes to Our Privacy Notice

Bank of Hope reserves the right to amend this privacy notice at our discretion at any time, as we continue to develop our compliance program in response to legal developments and new interpretations of the CCPA. When we make changes to this privacy notice, we will post the updated notice on the Website and update the effective date of the notice.

9. Contact Information

If you have any questions or comments about this notice, the ways in which Bank of Hope collects and uses your PI or wish to exercise your rights under California law, please feel free to contact us by either:

  • Filling out an online form by clicking here
  • Calling us at our toll-free telephone number: (888) 811-6272

Call Center Business Hours
Mon-Fri: 5:30 am - 6:00 pm (PST)
Sat: 6:00 am - 1:00 pm (PST)