Privacy Policy

This Privacy Policy governs the use by any user (“User,” “you,” “yours”) of the Chello website located at www.chello.bank, and all associated sites and mobile applications linked or provided by Chello, (collectively, the “Site”). Chello (“we,” “us,” “our”) is a division of Oriental Bank.

Information We Collect

We may collect and store the following information when you use our Site:

Contact and Content Upload Information. When you contact us using our online or other contact forms available via the Site from time to time, we collect the messages you send as well as the personal or company information you provide, such as your name, phone number, and email address. If you upload a digital photo or customer testimonial for use on our Site, we also collect the personal information you submit at the time.

Application and Services Information. We require certain personal and company information when you apply via the Site for an account, loan, or other service, or when you subscribe to an online or mobile service. In addition to basic details such as your name, email address, company name, and phone number, we may require information to verify your identity, which may include, but is not limited to, your social security number, driver's license number, your place of employment and your company’s federal tax ID number. We may also require that you use “Additional Authentication Information” (“AAI”), such as tokens, one-time access codes, or other such similar mechanisms that we may require in our sole discretion in order to authenticate your use of the services.

Financial and Transactional Information. Our use of financial and transactional information is limited to provided products and services to you or your company and in keeping with applicable law. We generate and collect information for our customers as necessary in order to run the day-to-day operations of the financial services that we provide and as required by applicable federal, state, provincial and local laws, rules, regulations, directives, and governmental requirements.  For example, in connection with online or other types of services, as available from time to time, we generate and collect details pertaining to your account with us, including payment and balance information, as well as instructions and other communications from you, such as instructions regarding payments and funds transfers. Further details and disclosures pertaining to our financial services may be found in the Chello Digital Services Agreement and any other agreements or disclosures that may be presented for your or your company’s agreement or acknowledgement in connection with the services that you or your company may choose to obtain from us from time to time.

Log Data. When you access and use our Site, we automatically record information concerning the device you are using and your activity on the Site. This may include your device’s Internet Protocol (“IP”) address, your browser type, the types of information you search for and view on our Site, locale preferences, location, identification numbers associated with your device, and your mobile carrier. If you arrived at one of our Sites by clicking on an advertisement, promotion, or search result on another website or mobile site or application, we also take note of the page you visited before you came to our Site.

Geo-Location Information. Many mobile devices permit applications to access real-time location-based information. Our mobile application may collect such information, with your permission, in order to enhance the features and functionality of our Sites and financial service offerings. In addition, some of the information we already collect, such as IP addresses, may be used to estimate an approximate location of the device you are using to access our Sites.

Our Use of Information

We use your information to verify your identity, provide you with quality customer service, evaluate your request for products and services, and improve our Site and service offerings. We may be obligated by law to retain certain communications and other information concerning you or your company. In addition, we may retain and use communications, transaction details, and identifying information (such as IP addresses) in order to maintain audit trails for security and anti-fraud purposes.

Chello may share information concerning you or your company with third parties for marketing purposes. We may use some of the information that we collect concerning you or your company in order to present you or your company with information concerning Chello services that may be of interest, and we may share that information with our related entities and third-party service providers involved in delivering the services. For example, we may tailor our marketing efforts based on the types of financial services you or your company uses, the services in which you or your company demonstrates an interest, and your and your company’s use of our Site.

Disclosure of Information

We disclose information concerning you and your company as necessary to run our everyday business, such as in connection with processing transactions. We also may disclose information concerning you or your company if required to do so by applicable law, or if we believe that such action is necessary to comply with a legal obligation or to protect and defend our rights or property, or those of our customers.

Online Tracking and Advertising

Like many Site operators, we use services offered by third parties (including, but not limited to, Google, Twitter, and Facebook) to advertise on third party websites based on search terms used by you and your visits to our Site. We also receive relevant history and Site usage information and information about your receipt and use of marketing emails from us collected by those third parties, including search terms that direct visitors to our Site, and we use that information to improve our Site and for our own marketing purposes. Those third parties use cookies, web beacons, pixels, or similar technology to provide these services to us and to serve ads and customize search results based in part on your or your company’s visits to our Site. You can set preferences for Google services using the Google Ad Settings page, and you can opt-out of Google Analytics’ use of data by installing a browser ad-on available here. You can find information concerning personalized ads delivered by Twitter, as well as an opt-out from interest-based advertising, here. Other tools for opting out of targeted advertising are the Network Advertising Initiative (NAI) Opt-Out Page and the Digital Advertising Alliance (DAA) Consumer Choice Tool. Note that if you opt-out on the NAI page, or using the DAA tool, you will still see advertisements when you browse the Internet, but those advertisements may be less tailored to you and your interests.

Currently, various Internet browsers offer a “do not track” or “DNT” option that uses a DNT header to indicate the DNT preference setting on the browser. Because standards for DNT continue to evolve, we do not currently respond to browsers’ DNT signals with respect to the Site. We do not track your activity over time and across different websites or online services. The third parties that collect data through our Site and marketing emails may combine the data with other information they collect about your or your company’s online or mobile activities over time, on other devices, and on other websites or apps, if those websites and apps also use the same third parties. We do not permit third-parties to collect information from the Site for other websites or for their own purposes, except on a limited basis in connection with the analytics and advertising discussed in the preceding paragraph.

Security

Chello is committed to maintaining the security of your information, which is consistent with our core values and commitment to customer service. When you send information to us using the Internet, we use TLS (Transport Layer Security) or SSL (Secure Socket Layer) protocols to secure the transmission of information that you send to us over the Internet. Once we receive information, we store and protect it using industry-standard firewalls and other technology. Please remember, though, that no method of electronic transmission or storage is 100% secure.

Privacy of Children

The Site is intended only for commercial purposes, and not intended for use by any individual for personal, family or household purposes or for use by children under the age of 13.

How to Contact us

Should you have any questions or concerns regarding your information or privacy-related issues, please send a message to us via the Site’s “Talk to Us” feature. Upon your verifiable request, we will do our best to correct inaccurate information that we have concerning you or your company.

Changes to this Privacy Policy

We may need to make changes to this Privacy Policy from time to time, in order to reflect changes to our Site or services, or to accommodate new technology or legal requirements and guidelines. Please check the links on our Site to this Privacy Policy for any updates periodically. Information collected in connection with your use of our Site after any changes to this Privacy Policy become effective will be handled in accordance with the revised Privacy Policy.