PRIVACY POLICY

Effective as of January 1, 2020

INTRODUCTION

First Midwest Bank (“First Midwest,” “we,” “our,” or “us”) respects the privacy of your information. This Privacy Policy is designed to assist you in understanding how we collect, use and safeguard the information you provide to us in using our website (the “Site”), the services provided through our Site, and the mobile applications we offer (collectively referred to as the “Services”).

If you have a consumer financial product or service with us, we will use and share any information that we collect from or about you in accordance with our U.S. Consumer Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information.

From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage. Please review this Privacy Policy periodically. Your continued use of the Site and Services after any such amendment signifies your acceptance thereof.

COLLECTING AND USING INFORMATION

Personally Identifiable Information We Collect Online 

Through your use of the Site and Services, we may collect Personally Identifiable Information from you. “Personally Identifiable Information” is individually identifiable information about an individual consumer that we collect online and that we maintain in an accessible form. We collect the following types of Personally Identifiable Information:

Information You Provide

We may collect the following Personally Identifiable Information that you voluntarily provide to us:

  • Online Banking. If you open an online banking account, we will collect your first and last name, social security number, and email address. We will also collect the pin number associated with your banking account. Every time you log on to use our online banking feature we will request that you enter your User ID—personal online identifier.
  • Applications. If you apply for one of our financial products or services, such as a credit card, bank account, or loan, we will collect your first and last name, postal address, email address, telephone number, and social security number. We also will collect other information such as your date of birth, marital status, driver’s license number and expiration date, months and years you have resided at your current residence, current rent or mortgage monthly payment, employment information such as your occupation, employer name and address, your gross monthly income, and if you are applying for a loan, we will request your bank account number.
  • Mobile Apps. If you use our mobile applications we, through our mobile application service providers, will collect your User ID and password information. We also will collect a device identifier.
  • Talk to an Expert. If you request communication with one of our experts, we will collect your first name and telephone number.
  • Business Express. If you enroll in our Business Express service, we will request the name of your business, your first and last name, postal address, telephone number, and email address. We will also collect your financial information such as your bank account and routing number.

Information as You Navigate Our Site 

We automatically collect certain Personally Identifiable Information through your use of the Site and Services, such as the following:

  • Usage Information. We collect information automatically through your use of the Site and Services, such as which of the pages on the Site you access, the frequency of access, and what you click on while on the Site.
  • Device Information. We collect information about the device you are using, such as hardware model, operating system, application version number, and browser.
  • Mobile Device Information. In addition to the Device Information listed above, when you access our Site via a browser on your mobile device, we collect and aggregate information about whether you are accessing the Site via a mobile device or tablet, device type, and carrier.
  • Location Information. We collect location information from Site visitors on a city-regional basis. 

Third Party Information 

In some cases, we may receive certain Personally Identifiable Information from you about a third party. For example, as part of our application process, you may provide the information of a third party. If you submit any Personally Identifiable Information about another individual to us, you are responsible for making sure that you have the authority to do so and to allow us to use their Personally Identifiable Information in accordance with this Privacy Policy.  

How We Use Your Personally Identifiable Information 

We use the Personally Identifiable Information we collect to provide the Services to you, to improve our Services and Site, and to protect our legal rights. In addition, we may use the Personally Identifiable Information we collect to:

  • Process your account registration and application;
  • Provide customer service;
  • Review your job application;
  • Contact you regarding our products and services that we feel may be of interest to you;
  • Communicate with you about our Site or Services or to inform you of any changes to our Site or Services;
  • Provide support;
  • Maintain and improve our Site and Services;
  • Defend our legal rights and the rights of others;
  • Efficiently maintain our business; and
  • Comply with applicable law.

How We Share Your Personally Identifiable Information  

We may share the information that we collect about you in the following ways:

  • With service providers who perform data services on our behalf (e.g., email, hosting, maintenance, backup, analysis, etc.). Any such service providers will be under an obligation to us to maintain the confidentiality of your Personally Identifiable Information;
  • To service providers to prepare, deploy, and analyze advertising content;
  • To the extent that we are required to do so by law;
  • In connection with any legal proceedings or prospective legal proceedings;
  • To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention;
  • To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personally Identifiable Information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personal Information;
  • To any other person or entity as part of any business or asset sale; and
  • To any other person or entity where you consent to the disclosure.

COOKIES AND OTHER TRACKING TECHNOLOGIES

We use cookies and other tracking technologies (such as pixels and web beacons) (collectively “Cookies”). “Cookies” are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets).

We use Cookies to:

  • Estimate audience size and usage patterns;
  • Understand and save your preferences for future visits, allowing us to customize the Site and Services to your individual needs;
  • Advertise new content and services that relate to your interests;
  • Keep track of advertisements and search engine results;
  • Compile aggregate data about Site traffic and Site interactions to resolve issues and offer better Site experiences and tools in the future;
  • Ensure browsing security; and
  • Recognize when you return to the Site.

We set some Cookies ourselves and others are set by service providers. We use Cookies set by service providers to provide us with useful information to help us improve our Site and Services, to conduct advertising, and to analyze the effectiveness of advertising.

Cookies can be blocked by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Site.

You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org.

You can understand which third parties have currently enabled Cookies for your browser or mobile device and how to opt-out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.

Third Party Processors 

To ensure that your Personally Identifiable Information receives an adequate level of protection, we have put in place appropriate procedures with the service providers we share your Personally Identifiable Information with to ensure that your Personally Identifiable Information is treated by those service providers in a way that is consistent with and which respects the applicable laws on data security and privacy. For example, we use service providers to allow us to accept applications and deliver our financial products and services.

Google Analytics 

We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the Site and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The technologies used by Google Analytics do not gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google, click here.

“Do Not Track” Signals  

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Site does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.

CHOICES ABOUT YOUR PERSONALLY IDENTIFIABLE INFORMATION

Review and Request Changes to Your Personally Identifiable Information 

You may use your account to access, correct, or view certain Personally Identifiable Information we have collected and which is associated with your account. To review or request changes to any of your Personal Information, please contact us at CustomerCare@FirstMidwest.com

MARKETING COMMUNICATIONS

To unsubscribe from emails from us, please click the unsubscribe link included in the footer of our emails. You also may submit a request to us at CustomerCare@FirstMidwest.com.

SECURITY

First Midwest safeguards client information by maintaining physical, electronic, and procedural safeguards that comply with federal standards to guard non-public personal information about you. This is accomplished by operating under a detailed information security policy and program designed to protect the security of your information. The information security program is subject to ongoing regulatory oversight and examination. 

A critical part of protecting your information includes steps you should take to protect yourself when using computers to access online services, communicate and store information. If you'd like to know more about how First Midwest Bank protects information about you, click here for details about our Website Privacy & Security Practices.

THIRD PARTY LINKS

The Site may contain links that will let you leave the Site and access another website. Linked websites are not under our control. Except as stated below, this Privacy Policy applies solely to Personally Identifiable Information that is acquired on this Site. We accept no responsibility or liability for these other websites.

CHILDREN’S PRIVACY

The Site and Services are not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal information from children under 13 years of age.

NOTICE TO CALIFORNIA RESIDENTS

The California Consumer Privacy Act (CCPA) requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of California residents regarding their personal information.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include information that is publicly available, deidentified or aggregate information. For purposes of this “NOTICE TO CALIFORNIA RESIDENTS” section we will refer to this information as “Personal Information.”

The CCPA’s privacy rights described below do not apply to Personal Information that is collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act. Because we are subject to those laws and regulations, much of the Personal Information that we collect is exempt from the CCPA. Your choices and rights with respect to our use and sharing of that information are subject to our U.S. Consumer Privacy Notice.

The CCPA’s privacy-related rights also do not apply to certain types of Personal Information that is subject to the Federal Credit Reporting Act (FCRA). Some of our services are subject to the FCRA and, therefore, exempt from the CCPA on that basis.

Right to Know About Personal Information Collected, Disclosed, or Sold 

Your Right 

If you are a California resident, you have the right to request that we disclose what Personal Information we have collected about you. This right includes the right to request any or all of the following:

  1. Specific pieces of Personal Information that we have collected about you;
  2. Categories of Personal Information we have collected about you;
  3. Categories of sources from which the Personal Information was collected;
  4. Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;
  5. Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and
  6. The business or commercial purpose for collecting or, if applicable, selling Personal Information.

The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

How to Submit a Request to Know 

You may submit a request to know via a web form available by clicking on this link: “Request to Know” or by calling us toll-free at 1-877-203-6724.

Our Process for Verifying a Request to Know 

If we determine that your request is subject to an exemption, we will notify you of our determination. If we determine that your request is not subject to an exemption, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a password-protected account with us.  

If you maintain a password-protected account, we may verify your identity through existing authentication practices available through your account. Prior to disclosing the requested information, we will ask you to re-authenticate yourself with respect to that account. 

If you do not maintain a password-protected account, or if you are an account-holder but we suspect fraudulent or malicious activity with your account, we will verify your identity as follows:

Request to Know Categories of Personal Information: We will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities. 

Request to Know Specific Pieces of Personal Information: We will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

Collection of Personal Information  

The following table presents the categories of Personal Information that we have collected, the categories of sources from which that information was collected, and the categories of third parties with whom we shared that Personal Information for the 12 months preceding the Effective Date of this Privacy Policy.

Categories of Personal InformationCategories of Sources form which Personal Information was CollectedBusiness or Commercial Purpose for the CollectionCategories of Third Parties with whom We Share Personal Information
Identifiers (name, alias postal address, email address, account name, social security number, driver’s license number, and passport number; other types of state identification cards)Consumer

Credit bureaus

Consumer data resellers (e.g., lead generators
Maintaining or Servicing accounts

Processing or fulfilling orders and transactions

Processing payments

Processing customer service

Providing financing

Verifying customer information
Service providers and vendors (e.g., email, hosting, maintenance, backup, analysis, etc.)

Business partners who provide services to us to facilitate our providing of financial products to consumers

Government agencies
SignatureConsumerSame as aboveSame as above
Credit card number/Debit card numberConsumerSame as above 
Insurance policy number (e.g. homeowners insurance)ConsumerSame as above 
Geolocation dataConsumerSame as aboveData analytics provider
Professional or employment-related information (e.g., occupation and employer name); education informationConsumerSame as aboveBusiness partners who provide services to us to facilitate our providing of financial products to consumers
Bank account numberConsumerSame as above 
Protected classifications (race, color, gender, age (40 years or older), national origin, disability, citizenship status, marital status, military service)ConsumerSame as aboveBusiness partners who provide services to us to facilitate our providing of financial products to consumers
Other financial information (e.g., income)Consumer

Credit Bureau
Same as aboveSame as above
Records of products or services purchased, obtained or consideredConsumer

Credit Bureau
Same as aboveSame as above
Internet or other electronic network activity information (browsing history, search history, and information regarding a consumer’s interaction with an internet website)ConsumerSame as aboveService providers and vendors (e.g., website operators)
Cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology internet protocol address, online identifierConsumerProviding analytic services

Providing advertising or marketing services

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
Data analytics provider

Advertising network

*Please see “Cookies and Other Tracking Technologies” section above for more information as to our use of cookies
Audio (voice recording)ConsumerMaintaining or servicing accounts

Processing or fulfilling orders and transactions

Processing payments

Processing customer service
 

As discussed, many of these categories of Personal Information are exempt from the CCPA. Your choices and rights with respect to our use and sharing of that information are subject to our U.S. Consumer Privacy Notice.

Disclosure or Sale of Personal Information 

The following is a list of categories of Personal Information that we have sold to third parties in the 12 months preceding the Effective Date of this Privacy Policy:

  • Cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology 

The following is a list of categories of Personal Information that we have disclosed to third parties for a business purpose in the 12 months preceding the Effective Date of this Privacy Policy:

  • Identifiers (name, alias postal address, email address, account name, social security number, driver’s license number, and passport number, other types of state identification cards);
  • Signature;
  • Geolocation data;
  • Professional or employment-related information (e.g., occupation and employer name);
  • Education information;
  • Protected classifications (race, color, gender, age (40 years or older), national origin, disability, citizenship status, marital status, military service);
  • Other financial information (e.g., income);
  • Records of products or services purchased, obtained or considered;
  • Marital status;
  • Internet or other electronic network activity information (browsing history, search history, and information regarding a consumer’s interaction with an internet website);
  • Cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology;
  • Internet protocol address and online identifier

We do not sell the Personal Information of minors under 16 years of age without affirmative authorization.

Right to Request Deletion of Personal Information 

Your Right 

If you are a California resident, you have the right to request that we delete the Personal Information about you that we have collected or maintain. However, a business is not required to comply with a request to delete if it is necessary for the business to maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

How to Submit a Request to Delete 

You may submit a request to delete via a web form available by clicking on this link: “Request to Delete” or by calling us toll-free at 1-877-203-6724. 

If you submit a request to delete online, you will be asked to confirm separately that you want your Personal Information deleted.

Our Process for Verifying a Request 

If we determine that your request is subject to an exemption, we will notify you of our determination. If we determine that your request is not subject to an exemption, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a password-protected account with us.  

If you maintain a password-protected account, we may verify your identity through existing authentication practices available through your account. Prior to deleting the Personal Information, we will ask you to re-authenticate yourself with respect to that account. 

If you do not maintain a password-protected account, or if you are an account-holder but we suspect fraudulent or malicious activity with your account, we will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized deletion. 

We will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities. 

We will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

If we are unable to verify your identity to the applicable standard, we will treat your request to delete as a request to opt-out of the sale of the personal information that you provided as part of processing the request to delete. See the following section for a description of the right to opt-out of the sale of personal information.

Notice of Right to Opt-Out of Sale of Personal Information 

Your Right

If you are a California resident, you have the right to direct a business that sells (or may in the future sell) your Personal Information to stop selling your Personal Information and to refrain from doing so in the future.

The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

How to Submit a Request to Opt-Out 

You may submit a request to opt-out of sales via web form by clicking on this link: “Do Not Sell My Personal Information.” You also may submit a request by calling us toll-free at 1-877-203-6724.

How We Process a Request to Opt-Out 

We will act upon your request to opt-out within 15 days from the date that you submit the request. The CCPA does not require that we verify the identity of individuals who submit requests to opt-out of sales. However, we may deny the request if we have a good-faith, reasonable, and documented belief that the request is fraudulent. If we deny the request on this basis, we will notify the requesting party and provide an explanation why we believe the request is fraudulent.

Right to Non-Discrimination for the Exercise of a California Resident’s Privacy Rights 

We will not discriminate against California residents if they exercise any of the rights provided in the CCPA as described in this section “Notice to California Residents.” As such, we will not deny goods or services to that California resident; charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to the California resident; or suggest that the California resident will receive a different price or rate for goods or services or a different level or quality of goods or services. However, we are permitted to charge a California resident a different price or rate, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by the individual’s data.

Authorized Agents  

California residents may use an authorized agent to submit a request to know, delete, or opt-out on your behalf. 

If you use an authorized agent to submit a request to know or request to delete, we may require that (1) the authorized agent provide proof of your written permission and (2) you verify your identity directly with us. These requirements do not apply if you have provided the authorized agent with a power of attorney pursuant to California Probate Code sections 4000 to 4465.

If you use an authorized agent to submit a request to opt-out of sales, you will need to provide that authorized agent with written permission to do so and submit written proof to us that the agent has been authorized to act on your behalf.

ACCESSIBILITY

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below.

HOW TO CONTACT US

To contact us for questions or concerns about our privacy policies or practices please call us toll-free at 1-800-322-3623. 

Instant Answer Center

Answers online. Anytime.

Contact Us

You are leaving the First Midwest website.

Redirecting to