Privacy Policy

1. Introduction

Concierge Bank, a Richemont Company ("Concierge Bank," "we," "us," or "our"), is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you use our banking services, visit our website, or interact with our mobile applications (collectively, the "Services").

This policy applies to all customers, prospective customers, and visitors to our Services. By using our Services, you consent to the data practices described in this policy. If you do not agree with this Privacy Policy, please do not access or use our Services.

2. Information We Collect

2.1 Personal Information You Provide

We collect information that you voluntarily provide to us when you:

• Open an account or apply for banking products (checking, savings, credit cards, loans)
• Conduct transactions or use our Services
• Contact customer service or submit inquiries
• Subscribe to marketing communications
• Participate in surveys, promotions, or contests

This information may include:

• Identity Information: Full name, date of birth, Social Security number, government-issued ID, passport details
• Contact Information: Email address, phone number, mailing address, billing address
• Financial Information: Income, employment details, account numbers, transaction history, credit history
• Authentication Information: Username, password, security questions and answers, biometric data
• Preferences: Communication preferences, preferred Richemont brands, language, currency

2.2 Information Collected Automatically

When you access our Services, we automatically collect certain information, including:

• Device Information: IP address, browser type, operating system, device identifiers, mobile network information
• Usage Data: Pages visited, time spent on pages, links clicked, features used, search queries
• Location Data: Geolocation information (with your consent) for fraud prevention and service enhancement
• Cookies and Tracking: We use cookies, web beacons, and similar technologies to track activity and store preferences

2.3 Information from Third Parties

We may receive information about you from third parties, including:

• Credit bureaus and reporting agencies (for creditworthiness assessment)
• Identity verification services (to prevent fraud and comply with regulations)
• Marketing partners and analytics providers
• Richemont affiliated companies and luxury brand partners
• Public databases and government agencies (as required by law)

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 Providing Banking Services

• Opening and maintaining your accounts
• Processing transactions, transfers, and bill payments
• Issuing credit and debit cards
• Processing loan applications and managing credit facilities
• Providing customer support and responding to inquiries
• Sending account statements, confirmations, and notifications

3.2 Legal and Regulatory Compliance

• Verifying your identity and preventing fraud
• Complying with anti-money laundering (AML) and Know Your Customer (KYC) requirements
• Meeting regulatory reporting obligations
• Responding to legal requests and preventing illegal activities
• Enforcing our Terms of Service and other agreements

3.3 Service Improvement and Analytics

• Analyzing usage patterns to improve our Services
• Developing new products and features
• Conducting research and analytics
• Personalizing your experience
• Testing and troubleshooting technical issues

3.4 Marketing and Communications

• Sending promotional offers and product recommendations
• Providing information about Richemont luxury brand partnerships and exclusive benefits
• Conducting surveys and gathering feedback
• Inviting you to special events and experiences

You may opt out of marketing communications at any time through your account settings or by clicking "unsubscribe" in our emails.

4. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

4.1 Service Providers

We engage third-party service providers to perform functions on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, fraud prevention, and identity verification. These providers have access to your information only to perform specific tasks and are obligated to protect your information.

4.2 Richemont Affiliates

We may share information with Richemont affiliated companies (including Cartier, Van Cleef & Arpels, Montblanc, and other luxury brands) to provide you with exclusive benefits, personalized offers, and integrated luxury experiences. You may opt out of such sharing for marketing purposes.

4.3 Legal Requirements

We may disclose your information if required by law, regulation, legal process, or governmental request, including to:

• Comply with subpoenas, court orders, or legal obligations
• Enforce our Terms of Service or other agreements
• Protect our rights, property, or safety, or that of our customers or others
• Prevent fraud, security breaches, or illegal activities
• Cooperate with law enforcement or regulatory authorities

4.4 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your information may be transferred to the successor entity. We will notify you of any such change and provide choices regarding your information.

4.5 With Your Consent

We may share your information for other purposes with your explicit consent or at your direction.

5. Data Security

We implement robust security measures to protect your information from unauthorized access, alteration, disclosure, or destruction. Our security practices include:

• Encryption: We use industry-standard SSL/TLS encryption for data transmission and AES-256 encryption for data at rest
• Access Controls: Strict access controls limit employee access to your information on a need-to-know basis
• Authentication: Multi-factor authentication (MFA) and secure password requirements protect your account
• Monitoring: Continuous monitoring and intrusion detection systems identify suspicious activity
• Regular Audits: We conduct regular security audits and vulnerability assessments
• Compliance: We adhere to PCI DSS standards for payment card data and comply with applicable banking regulations

While we strive to protect your information, no method of transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and notifying us immediately of any unauthorized access.

6. Your Privacy Rights

Depending on your location, you may have the following rights regarding your personal information:

6.1 Access and Portability

You have the right to request a copy of the personal information we hold about you and to receive it in a structured, commonly used format.

6.2 Correction

You may request correction of inaccurate or incomplete information through your account settings or by contacting us.

6.3 Deletion

You may request deletion of your personal information, subject to legal and regulatory retention requirements. Note that we may need to retain certain information for compliance, fraud prevention, and legitimate business purposes.

6.4 Opt-Out

You may opt out of marketing communications, data sharing with affiliates for marketing purposes, and certain data processing activities. You can manage your preferences in your account settings.

6.5 Do Not Track

Our Services do not currently respond to "Do Not Track" signals. You may disable cookies through your browser settings, though this may affect functionality.

To exercise your rights, please contact us at privacy@conciergebank.com or call 1-800-CONCIERGE. We will respond to your request within 30 days.

7. Cookies and Tracking Technologies

We use cookies, web beacons, pixels, and similar technologies to enhance your experience, analyze usage, and deliver personalized content. Types of cookies we use include:

• Essential Cookies: Required for basic functionality, authentication, and security
• Performance Cookies: Collect anonymous usage data to improve our Services
• Functional Cookies: Remember your preferences and settings
• Marketing Cookies: Track your activity for targeted advertising and analytics

You can control cookies through your browser settings. Disabling certain cookies may limit functionality. For more information, see our Cookie Policy.

8. International Data Transfers

Concierge Bank is headquartered in Switzerland. Your information may be transferred to, stored, and processed in Switzerland, the United States, or other countries where we or our service providers operate. These countries may have data protection laws different from your jurisdiction.

We implement appropriate safeguards, including Standard Contractual Clauses approved by the European Commission, to ensure your information receives adequate protection regardless of where it is processed.

9. Children's Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a child, please contact us immediately, and we will take steps to delete such information.

10. Data Retention

We retain your personal information for as long as necessary to provide our Services, comply with legal obligations, resolve disputes, and enforce our agreements. Retention periods vary based on:

• The nature of the information and purpose for which it was collected
• Legal, regulatory, tax, and accounting requirements (typically 7-10 years for financial records)
• Fraud prevention and security needs
• Legitimate business purposes

When information is no longer needed, we securely delete or anonymize it in accordance with our data retention policies.

11. Third-Party Links

Our Services may contain links to third-party websites, including Richemont luxury brand partners. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any information.

12. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by:

• Posting the updated policy on our website with a new "Last Updated" date
• Sending an email notification to your registered email address
• Displaying a prominent notice on our Services

Your continued use of our Services after the effective date constitutes acceptance of the updated policy. We encourage you to review this policy periodically.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

14. Regulatory Information

Concierge Bank is regulated by:

• Swiss Financial Market Supervisory Authority (FINMA)
• Federal Deposit Insurance Corporation (FDIC) - Member Institution
• Office of the Comptroller of the Currency (OCC)

We comply with the Gramm-Leach-Bliley Act (GLBA), the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other applicable privacy and banking regulations.