Website Privacy Policy
ARROW BANK NATIONAL ASSOCIATION
Website and Mobile Application Privacy Policy
Last Updated: December 31,2024
This Website and Mobile Application Privacy Policy (“Policy”) describes our privacy practices regarding
information we collect from users of Arrow Bank National Association’s (“ABNA”) website and mobile
application (together, the “Online Services”). We recognize that users of our Online Services are
concerned about their privacy, and we are committed to preserving your privacy when using the Online Services.
This Policy describes what data we collect, how we use it, and how we may share it. ABNA may, at its sole discretion,
change modify, add, or delete portions of this Policy. Because this Policy only applies to the Online Services, you
should examine the privacy policy of any third-party website that you access through the Online Services.
The terms “Arrow Bank National Association”, “ABNA,” “we”, “us”, or
“our” on any website we own or control and, in this Policy, refers to Arrow Bank National Association,
its parent company Arrow Financial Corporation, our affiliates, and subsidiaries. This Policy provides general
policies applied across all web platforms used by ABNA. This Policy covers the following ABNA Online Services:
- ABNA Website
- Upstate Insurance Agency’s Website
- ABNA Consumer Mobile Banking App
- ABNA Business Mobile Banking App
The complete list of our online service-specific policies, practices, terms and conditions and disclosures can be
found here:
Please note that when you opt to (1) open a checking or savings account, (2) apply for a home equity loan, (3) apply
for a mortgage, (4) pay a loan or (5) order checks through the ABNA website, each of those products is hosted on a
site through one of ABNA’s non-affiliated third-party partners. To the extent you engage with any of those
offerings, please review the applicable privacy policy, which will govern your activities on the respective site.
We encourage you to review and familiarize yourself with this Policy. As always, we thank you for being our valued
customer.
Types of Information We Collect
Personal Information
We collect personal information that you provide to us when using our Online Services, including if you send an
e-mail to ABNA. This may include your name, postal or e-mail address, telephone, fax, or mobile number.
This Policy does not apply to any personal information that we collect from you in connection with
products or services that you obtain for personal, family, or household purposes. If you have a financial product or
service with us primarily for personal, family or household purposes, please review ABNA’s Privacy Notice,
available here(link to GLBA Notice), which describes how ABNA processes your personal information in connection with
these products and services.
It is important to remember that regular (non-encrypted) e-mail is not secure. Please do not send Arrow any sensitive
information (such as your Social Security number, driver's license number, account number(s), credit or debit
card number(s), or any log-in information or passwords that you may use to access your financial information through
the Site) via regular e-mail.
Usage and Other Information
In addition to the personal information described above, we may collect certain information about your use of our
online services. For example, we may capture the IP address of the device you use to connect to our Online Services,
the type of operating system and browser you use, and information about the site you came from, the parts of our
Online Services you access, and the site you visit next. We or our service providers may also use cookies and other
technologies to collect and store other information about your visit to, or use of, our Online Services (more on
that below). We may also later associate the usage and other information we collect online with personal information
about you.
Information Related to Mobile Application Use
If you use our Mobile App, in addition to the information above, we and our service providers may collect the
following additional information from you:
- Device and Carrier Information:We may collect information about your device, such as your phone
number, the device model, installed applications, identity of the carrier, and the name and version of the
operating system to ensure your device’s compatibility with our Online Services.
- Location Tracking:There may be certain information transmitted to us regarding your location
when you log in or request information through Online Services. We collect the Internet Protocol (IP) address of
the device to determine your physical location for Online Services. This information may be provided to mapping
applications, for example to assist you in locating nearby branches and ATMs and for security purposes. We will
retain your location data only for as long as needed to fulfill business purposes and will not use it for any
other purpose.
- Transaction Information: Wemay collect information when you initiate
a transaction. This information will only be used or shared in order to provide the service that you requested.
This information is also collected and analyzed to assist us with fraud detection and for other security
purposes, and to enhance our ability to optimize your experience while on our site. We will use this information
only for the purpose(s) stated in this Policy and will retain it for only as long as needed to fulfill the
business purpose(s).
- Camera/Image:We may request your permission to access the camera for your device in order to
collect images, such as scanning QR codes, facilitating account transactions (including but not limited mobile
check deposits), or processing other images or videos to fulfill any other purpose for which you provided the
information, such as for purposes of secure messaging, customer service, or to enable us to provide you products
and services you request.
How We Use Your Information
We may use your information for the following purposes:
- Communicate with you – respond to your requests, feedback, and inquiries
- Prevention of Fraud and other harm – to verify your identity, detect, prevent or
investigate fraudulent transactions, potential security breaches, and monitor against theft
- Provide, market, and develop our products and services – market our products and services
to you, analyze and understand how you have interacted with our Online Services, and track the effectiveness of
our advertisements
- Internal Business Operations – maintain and improve the effectiveness of our services,
conduct research and analysis, and perform other business activities as needed
- Comply with law – comply with our legal and regulatory obligations,
defend ourselves in litigation and investigations, and prosecute litigation
- Enforce Our Contractual Rights – to enforce our Terms of Use and other agreements
How We Share Your Personal Information
We may share the personal information we collect in the following ways:
- Affiliates and Subsidiaries: We may share your personal information among our affiliates and
subsidiaries.
- Service Providers: We may provide personal information to our vendors, contractors, business
and service providers, or third parties who provide services to us, including data storage firms, credit
reporting agencies, payment companies, technology suppliers, technology services, customer service, risk
solution providers, analysis firms, fraud prevention companies, advertisers, marketers and others.
- Governmental Authorities: As required by law, or legal process, we may share your personal
information with federal or state regulatory agencies, law enforcement, courts and other governmental
authorities or when we believe that disclosure is necessary to detect, prevent or report suspicious activities,
prevent physical harm, financial loss or violations of our agreements and policies.
- Professional Advisors: We may share your personal information with our professional advisors,
such as auditors or law firms, as well as other financial institutions and entities with whom we jointly develop
or offer, endorse, or sponsor financial products or services.
- Parties Involved with Business Transfers: We may share your personal information with third
parties in the event we sell or transfer all or a portion of our business or assets.
- At your direction: We may disclose your personal information at your direction or with your
consent.
State laws may give you additional rights to limit sharing of your personal information. Residents of California
should see our California Consumer Privacy
Notice page for information specific to the rights of California residents.
How We Use Cookies and Other Data Collection Tools
Cookies, Web Beacons and Pixel Tags. To better serve you and to provide more effective
Online Services, we use "cookies" as part of our interaction with the device you are using. Cookies are
small text files that a website's server places on your computer or other device. In addition to cookies, we may
use other devices for tracking online activity, including web beacons and pixel tags. Web beacons and pixel tags are
small strings of software code that represent a graphic image on a website, or in e-mail that is used to monitor the
user's behavior.
These data collection tools provide a means for sites that you visit to track browsing activities conducted with the
device you are using, your language preference, and your relationship with the site owner. This may include
information such as pages and content viewed, time and duration of visits, search queries entered into search
engines, and whether you clicked on an advertisement. Cookies make the personalization of your Online Services
experience possible and can also be used to retain data related to a particular browser. We use these data
collection tools to determine whether you have previously visited our website, the location from which you are
visiting our website, and for several administrative purposes (for example, to store your preferences for certain
kinds of information), website traffic reporting, unique visitor counts, advertising / auditing / reporting, and for
personalization of a website. The data collection tools may be used in connection with some Online Services and
e-mail messages to measure the effectiveness of our communications and/or the success of our marketing campaigns, to
compile statistics about usage and response rates, to personalize your experience while engaging with us online and
offline, for fraud detection and prevention, for security purposes, for advertising, and to assist us in resolving
account holders' questions regarding use of our Online Services.
We and our service providers may also use cookies, or similar technologies, to collect information about your
browsing activities over time and across different websites following your use of our Online Services. We may use
other technologies, such as the capture of screenshots while you are using the Services, to understand how you
navigate and use the Services. This information helps us to better understand how the Services are used and to
improve them. We may associate this tracking data with any personal information you provide, in which case we will
treat it as personal information.
Google Analytics Our Online Services also utilize Google Analytics to better understand and
serve your needs. Google Analytics is a secured platform used to track web activity, including but not limited to
session duration, pages per session, engagement rate and the sources of web traffic. Cookies used by Google
Analytics are used to identify each customer as a unique user, and are protected by Google encryption from being
used by any other tracking platform. Just as with Our Online Services’ cookies, your web browser may enable
you to decline Google cookies. For more information on Google Privacy or Terms of Use, visit https://policies.google.com/privacy?hl=en and https://marketingplatform.google.com/about/analytics/terms/us/.
You can refuse to accept these cookies, and most devices and browsers offer their own privacy settings for cookies.
You may manage your cookie settings for each device and browser you use. However, you may experience some
inconvenience in your use of our Online Services and some online products and services.
You should visit the "Help" section of your browser for how to manage your cookie settings. For further
general information on cookies and more detailed advice on how to disable and enable them, please visit www.allaboutcookies.org.
How We Secure Your Information
We employ measures to protect your personal information from unauthorized access and use. These include computer
safeguards and secured files and buildings. We also restrict access to nonpublic personal information about you to
those employees who need to know that information to provide products or services to you.
Do Not Track
While, as described above, you may have the ability to control the use of cookies through your web browser, unless
the browser settings block our data collection, we do not currently respond to “Do Not Track” signals or
other mechanisms. The available settings vary greatly by browser; please refer to your Internet browser settings for
more information. For more information about Do Not Track, please visit www.allaboutdnt.com
Children's Privacy
We recognize that protecting children's identities and privacy online is important and that the responsibility to
do so resides with both the business and the parents. We do not knowingly solicit data from children under the age
of 13, and we do not knowingly market through our website to such children. We comply with the requirements of the
Children's Online Privacy Protect Act (COPPA) that are applicable to us.
Making Sure Your Information is Accurate
It is important for us to have your most accurate and up-to-date contact information. If any of your contact
information has changed, please call or write us at the proper telephone number or address located within the Help page. You may also call or write us at the telephone number or mailing address located on
your account statements or other records as indicated.
Changes to this Digital Privacy Policy
You should review this Policy periodically as it is subject to change from time to time. When a change has been made,
we will post the revised Policy on this page with a new "Last Updated" date at the top of the page. All
changes will become effective when posted unless indicated otherwise.
Your continued use of any of our Online Services following the posting of a revised version of this Digital Privacy
Policy will constitute your acceptance of the revised Policy. If you do not agree with the revised Digital Privacy
Policy, do not use any of our Online Services.
Notice to California Residents
The California Consumer Privacy Act (“CCPA”) governs financial institutions’ collection and
processing of certain information belonging to consumers who reside in California.
For further information on the application of the CCPA to the ABNA and with regard to the rights of consumers
residing in California, please visit the California
Consumer Privacy Notice page.
Questions about our Privacy Practices
If you have questions or concerns about our privacy notices or practices, please contact us toll-free at
866-248-6366.