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Privacy Policy Notice & General Security Guidelines
This Notice is effective as of July, 2010
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If you have questions or concerns regarding this statement, you should first contact WTDirect at ClientCare@WTDirect.com. If you do not receive acknowledgement of your inquiry or your inquiry has not been satisfactorily addressed, you should contact TRUSTe. TRUSTe will then serve as a liaison with us to resolve your concerns.
Privacy Policy Notice
Protecting your privacy is a critical component of the way we do business. We do not sell client lists or any other information about any of our clients to anyone. Our relationship management philosophy means that we want to work with you to help you achieve your financial goals. Selling your information to others would be contrary to that philosophy. We do believe, however, that some sharing of your information with other companies, both inside of the Wilmington Trust family and with carefully selected companies outside of our family, may often be an essential step in enabling us to help you meet your financial goals. This could include introducing you to the financial products and services of these other companies, as well as collaborating and/or partnering with these other companies in connection with managing your financial relationship.
In addition to protecting the confidentiality of your information, we are also very careful to safeguard the security of your information. We restrict access to your personal and account information to those staff members who need to know that information to provide products and services to you. In addition, we diligently maintain physical, electronic, and procedural safeguards that comply with federal standards to guard the security of your information. With all of this in mind, we have developed this Privacy Policy Notice so that you can understand exactly what information we obtain from you, how we use it, and, most importantly, how we protect it. Even if you are no longer our client, we will continue to treat your information in the same way as if you were still a client.
What Information We Obtain
Since some of the information we obtain about you and/or your joint accountholder(s) are not publicly available, we take great care to ensure that this information is protected from unauthorized access, and we would not share your information in violation of any regulation or law. This information also called "non-public personal information" is obtained when we provide a financial product or service to you. We may obtain this type of information about you from the following sources, among others:
- Your applications, financial statements, tax returns, or other forms we obtain from you in connection with your opening of an account with us (examples include name, address, social security number, birthday, assets and income);
- Communications we have with you, including by telephone, mail, e-mail, or face-to-face contact;
- Information you provide when you register for our Internet website or use our on-line services;
- Transactional information regarding deposit accounts you have with us, members of the Wilmington Trust corporate family, or others (examples include your deposit, trust or loan account balance; overdraft history and loan payment history); and
- Information we obtain about you from third parties, such as consumer reporting agencies, to verify statements you've made to us regarding your employment, credit or other relationships.
When you register with our website, we will request information from you in connection with your registration. In addition, if you choose to apply for various online products and services that we offer, such as Online Banking, we will request personal information that we need to process your application. Subsequent to signing up for these online services, we will request information from you, such as your email address or your account number, to enable you to perform certain tasks (for example, review your accounts or correspond with us). In this case, we will collect your information if necessary to interact with you. If you do not register with us or sign up for our online services, we do not collect any personal information from you.
On our website, we use cookies to determine if you have previously visited our website, to log the pages you use on our site, to evaluate the effectiveness of our online marketing, and for a number of administrative purposes - for example, to store your preferences for certain kinds of information. A "cookie" is a small text file placed on your computer hard drive by our web server. Cookies are commonly used on websites and do not harm your system or read or collect information from your computer's hard drive. To better serve you and to provide a more effective website experience, we use "cookies" as part of our interaction with your web browser. These cookies do not collect personally identifiable information, but we may combine information collected through cookies with other personal information you have provided to us in connection with your use of our website to determine who you are or your email address. All of this information helps us in our efforts to continually improve our website and to be responsive to your specific needs.
Cookies will not contain information that will enable anyone from WTDirect to contact you via telephone, email, or U.S. mail. You can set up your web browser to inform you when cookies are present or to prevent cookies from being set up. However, by rejecting a cookie, some of the features available on our website may not function properly or be accessible to you. If while inside our website you receive a pop-up box asking if you would like to "accept the cookie," you must answer "yes" in order to advance beyond the area that prompted the message.
Some of the companies with which we do business (e.g., advertisers) may use cookies on their sites. We have no access to or control over these cookies.
We also utilize other online technologies such as web beacons to help us gather anonymous information regarding site usage and to better manage the overall user experience. Our web beacons are not tied to personally identifiable information.
As is true of most websites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users' navigation, to gather demographic information about our user base as a whole, and for security purposes. We do not link this automatically-collected data to personally identifiable information.
Sharing of Information Within the Wilmington Trust Corporate Family
How We Share Information
From time to time, such as for responding to client inquiries, for risk control purposes, or when we think it may help to meet your financial goals and objectives, we may share information with companies that are part of the Wilmington Trust corporate family. These companies all provide financial services, such as loans, deposit products and brokerage and insurance services. The information we share within our corporate family might come from any of the sources described previously under "What Information We Obtain."
Your Privacy Choices
Under federal law, you may limit Wilmington Trust and its affiliates, such as our banking and brokerage affiliates, from marketing their products or services to you based on personal information about you that they receive from another Wilmington Trust affiliate. This information may include information about your accounts, your income and assets, and your credit, including your credit score.
If you have no objection to our sharing of information about you within our corporate family for marketing purposes, you do not have to do anything. (However, if you do nothing and have previously submitted a "Privacy Choices" form to us, we will continue to honor those elections unless you indicate a different choice on the "Privacy Choices" form). If you prefer that we not disclose any non-transaction information about you to members of the Wilmington Trust corporate family for marketing purposes, you must check the appropriate box under the "Sharing Within Our Corporate Family" section of the attached "Privacy Choices" form, print out this form and mail it to us at the address noted therein.
Your election will also apply to all individuals with whom you hold joint accounts, unless the joint accountholder(s) specifically notifies us of a choice different from your own on his/her own "Privacy Choices" form. But please note that we may still share some or all of your joint non-transaction information if either you and/or your joint accountholder(s) do not object to sharing of such information within our corporate family.
Please remember that if we are not permitted to share information about you with other members of our corporate family for marketing purposes, it may affect our ability to help you fulfill your financial goals and the way in which we manage our relationship with you.
Sharing of Information Outside of the Wilmington Trust Corporate Family
How We Share Information
We may disclose some or all of the non-public, personal information we obtain about you under certain circumstances, and only as permitted by law. For example, we may share information with companies that perform marketing or research services on our behalf, or with financial institutions or other companies with which we have joint marketing arrangements (including, but not limited to,financial service providers or other companies with which we offer products such as credit cards, insurance, identity theft protection, credit monitoring services, merchant and other discounts, rewards, and rebates, etc.).
We also may share some or all of the information we obtain about you, as described above, with other companies that are not part of the Wilmington Trust corporate family in certain circumstances, including but not limited to third parties that assist us in servicing your loan or account, preparing monthly statements and/or processing and printing of checks; governmental agencies in response to subpoenas, court orders or regulatory requirements; credit, reporting agencies to which we report information about your transactions with us; when we believe that disclosure is necessary to protect our rights; and, as required by law.
We also may share information about you with financial service providers outside of the Wilmington Trust corporate family that we believe will be able to help us help you meet your financial goals by supplementing the financial products and services that we have to offer. These financial service providers could include securities broker-dealers, investment advisors, insurance companies and others. The information we might provide to these companies could come from the sources described previously under "What Information We Obtain" and might include your name, address and telephone number or other information we have obtained about you.
Your Privacy Choices
If you have no objection to our sharing of non-public personal information about you to such other financial service providers, you do not have to do anything. However, if you do nothing and have previously submitted a "Privacy Choices" form to us, we will continue to honor those elections unless you indicate a different choice on the "Privacy Choices" form below. If you prefer that we do not disclose any non-public personal information about you outside of the Wilmington Trust corporate family, you must check the appropriate box under the "Sharing Outside of Our Corporate Family" section of the "Privacy Choices" form, print out this form and mail it to us at the address noted therein.
Your election will also apply to all individuals with whom you hold joint accounts, unless the joint accountholder(s) specifically notifies us of a choice different from your own on his/her own "Privacy Choices" form. But please note that we may still share some or all of your joint information if either you and/or your joint accountholder(s) do not object to the sharing of such information outside of the Wilmington Trust corporate family.
This Notice updates and replaces any previous Privacy Policy Notice from Wilmington Trust. The examples given in this Notice are for illustrative purposes only and may not be all inclusive. We may amend this Privacy Notice at any time, and we will inform you of changes as required by law.
Inaccurate Information About You or Your Accounts
Keeping your account information up-to-date is very important to us. We have established procedures to help ensure that your financial information is as accurate and up-to-date as reasonably possible. If you believe that our records contain inaccurate or incomplete information, please call us at 1-800-WTDIRECT or write to us at the address listed on your account statement or at the address listed below:
Client Care
WTDirect Correspondence
1100 North Market Street
POB 8892
Wilmington, DE 19899-8892
If you write to us, please include the following information:
1. Your name and account number.
2. Describe the inaccurate information and explain as clearly as you can why you believe it to be an error.
3. Your signature.
We will investigate and take prompt steps to make appropriate corrections.
(Please complete and return this page)
Click here for a printable version of this Privacy Choices Form
Privacy Choices
(please print clearly and complete all fields)
Name___________________________________________
Address_________________________________________
Social Security Number_____________________________
(required to properly identify you and process your request)
Daytime Telephone Number_________________________
(in case we need to contact you regarding this form)
| Sharing Within Our Corporate Family | ||||
| | I agree that Wilmington Trust may disclose information about me with members of the Wilmington Trust corporate family for marketing purposes. | | I do not wish Wilmington Trust to disclose information about me with members of the Wilmington Trust corporate family for marketing purposes. | |
| Sharing Outside of Our Corporate Family | ||||
| | I agree that Wilmington Trust may disclose non-public personal information about me with persons and companies outside of the Wilmington Trust corporate family. | | I do not wish Wilmington Trust to disclose non-public personal information about me with persons and companies outside of the Wilmington Trust corporate family. | |
Signature_____________________
Date_____________________
Please note that we must receive this form at the post office address listed below in order for your privacy choices to be effective with us. All fields must be completed, or your request may not be processed. We will process your request within a reasonable period of time following our receipt of your completed "Privacy Choices" form.
Our Address:
Please return your completed "Privacy Choices" form to us at:
Client Care
WTDirect Correspondence
1100 North Market Street
POB 8892
Wilmington, DE 19899-8892
Security Statement
WTDirect is dedicated to protecting the security of your information. Security of your information is a Priority for us! We recognize that whether you are an existing client or are considering a relationship with us, you have an interest in how we collect, retain, use and protect information about you and your financial relationship with us. Our systems and policies have been engineered to provide maximum protection against unauthorized access to sensitive customer information. The following information details what we have done to answer your financial security concerns:
Security Standards
We have established and continually maintain security standards and procedures to help us protect you from unauthorized access to confidential information we may have about you, including through the Internet.
Protecting Website Information
When you visit WTDirect.com, you may ask yourself, "Is it really safe to conduct bank business on the Internet?" At WTDirect, the answer to that question is YES. WTDirect.com displays the VeriSign SecuredTM Seal, confirming the site's use of strong encryption to help ensure the security of your information and online transactions. While no system is impenetrable, our systems are designed for maximum protection of your information.
For your protection, we use 128-bit encryption for our online services. Data is transferred via a "secure session" established with Secure Sockets Layer (SSL) 128-bit encryption technology. This technology protects information as it crosses the Internet by encrypting - or scrambling - your account information so it is virtually impossible for anyone other than you and WTDirect to read it. If your Internet browser does not support 128-bit encryption, you can download the most current version of the Mozilla Firefox® browser or Microsoft® Internet Explorer free of charge. (If you access the Internet from a corporate network, we recommend that you contact your network administrator before downloading a new browser.) If your browser is provided as part of a national Internet Service Provider ("ISP"), such as America Online, you will need to check to see if your version is capable of supporting SSL 128-bit encryption technology. If your browser does support the 128-bit encryption, it will activate SSL automatically whenever you log in to our online services.
When you have completed any online session (such as Online Banking), you should always remember to log out or close all WTDirect.com browser windows so that your information remains protected.
Note to International Customers
Under current U.S. export laws, web browsers that encrypt data in 128-bit sessions may only be exported to a limited number of countries outside of the U.S. Therefore, if you are located outside of the U.S., you may not have access to such a browser. In this case, you would not be able to use our online services, and your ability to enjoy other features of our site would also be limited.
Password Protection
Your unique User ID and Password also protect access to accounts you may have with us and to transactional information through our online services. You can also help maintain the security of your financial information by not sharing your User ID or Password with anyone, by changing your Password regularly, and by remembering to log out of our website when you have finished your session.
Protecting Your Identity
Please see our Security and Privacy page for information on protecting your identity and what you should do if you believe that you have been a victim of identity theft.
Use of Email to Communicate With Us
We encourage you to use email to communicate with us, but please call us at 1-800-WTDIRECT if you need to communicate with us immediately about a matter, such as lost or stolen information or possible fraudulent or unauthorized transactions. If you communicate with us by email, we may preserve the content of your email, your email address, and our response so that we can more efficiently handle any questions you may have and also to meet legal and regulatory requirements.
If we think that a particular Wilmington Trust product or service may help you achieve your financial goals, we may occasionally contact you at your email address to inform you of its potential benefits and availability. You may opt out of receiving these types of emails by emailing us at ClientCare@WTDirect.com.
For secure transmissions, your email messages to us should be sent using your WTDirect Mailbox within Online Banking, which is secured with Secure Sockets Layer technology. Please do not send sensitive or confidential information such as social security or account numbers to us via an unsecured email, because it is possible that the information could be intercepted during transmission. Any communications of sensitive or confidential information should be sent to us via the secured Mailbox within Online Banking, by U.S. mail, or you may call 1-800-WTDIRECT.
Consolidation Sites or Account Aggregators
We recommend that you exercise caution when using account aggregator or consolidation sites. These sites are Internet sites that offer the ability to collect some or all of your personal information on one site. For example, you might be encouraged to provide an account aggregator with your personal financial information, such as your User ID and Password for online services. You should never provide personal information to a site that you do not recognize and fully trust.
Use of your personal information is governed by the policies and practices of the companies providing such services and not by the policies of WTDirect. You should also note that all transactions initiated by an account aggregator, using access information provided by you, are considered to be authorized by you whether or not you were aware of the specific transaction. You may revoke this authority only by notifying us at ClientCare@WTDirect.com, and we may need to block your account until we issue a new User ID and/or Password to you.
Links to Other Sites
This Web site contains links to other sites that are not owned or controlled by WTDirect. Please be aware that we, WTDirect, are not responsible for the privacy practices of such other sites.
We encourage you to be aware when you leave our site and to read the privacy statements of each and every Web site that collects personally identifiable information.
This privacy statement applies only to WTDirect and information collected by this website.
Protecting Our Children
We recognize that protecting children's identities and privacy online is important and that the responsibility to do so rests with both the online industry and with 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.
"Tips for Safe Banking Over the Internet"
Click here to view the FDIC's brochure for bank customers on "Tips for Safe Banking over the Internet."
Changes in this Privacy Policy Notice and Security Statement
As required under federal law, we will provide you with a copy of the Privacy Policy Notice part of this document, either by mail or by email: (a) on an annual basis; and, (b) if we make any material changes. In addition, if we decide to make any material changes to any part of this document, including the Privacy Policy Notice part or the General Security Guidelines part, we will notify you here, by email or by means of a notice on our home page so that you are aware of what information we collect, how we use it, under what circumstances, if any, we disclose it, and how we protect it.
We reserve the right to modify this Privacy Policy Notice & General Security Guidelines at any time, so please review it frequently.
If you have any specific questions related to our Privacy Policy Notice & General Security Guidelines, please send us an email at ClientCare@WTDirect.com or call us at 1-800-WTDIRECT.
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