1/2020

American First National Bank is committed to protecting the privacy and security of your personal information. This privacy policy describes the types of information we may collect from you or otherwise receive about you and our practices for collecting, disclosing or selling that information.

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

You have the right to know what personal information we collect, use, disclose and sell. If you wish to submit a verifiable consumer request for the personal information we collect, use, disclose or sell, or wish to exercise your rights under California law, you may submit your request through one of the following ways:

  • You can submit a request at any of our California branch locations;
  • Call the toll free number: (877) 473-1888
  • You can submit your request online
  • Submit a request by mail to:
    American First National Bank
    9999 Bellaire Blvd.
    Houston, Texas 77036

California law requires us to verify your identity before we can process your request. In order to verify your identity we may need to request specific information from you such as your account number, the date or amount of your last deposit or withdrawal that you made and match that information with the information we already maintain on you. If you maintain a password protected account with us we can verify your identity through our existing authentication practices, such as two-factor authentication. This helps us confirm your identity and ensure you can exercise your right to access the information.

We will acknowledge your request within 10 business days, and will provide the requested information within 45 days. If we are not able to respond within 45 days, we will inform you and respond within an additional 45 days. You may request this information up to two times per 12-month period. We reserve the right to verify the legitimacy of all requests, using any information you have given us, or any transactional information we have. We are prevented from providing the following:

  • Your social security number;
  • Driver’s license or other government-issued identification number;
  • Financial account number;
  • Any health insurance or medical identification number (if we have it);
  • Account passwords or security questions and answers

Collection of Personal Information

We do not share or disclose your information except as allowed by law. We share (disclose) information only with those vendors providing servicing of your products and services and require that they not sell, share, or use your information for any other purpose.

Below is a list of categories of personal information we have collected about consumers in the preceding 12-months. For each category identified below, we have also provided (i) the categories of sources from which we collected the personal information, (ii) the business or commercial purpose for collecting the information and (iii) the categories of third parties with whom we share the personal information:

Categories of Personal Information We CollectCategories of Sources from Which We Collect Personal InformationOur Business Purpose for Collecting Personal InformationCategories of Third Parties with Whom We Disclosed the Personal Information
Identifiers such as a real name, alias, postal address, online identifiers, email address or unique personal identifier or other similar identifiers.Directly from you; such as information you provide on our forms, surveys, loan or deposit applications, including applications for employment, or similar online fields or forms or items we collect indirectly from others, such as credit reporting agencies, title companies, appraisers, etc.To approve or decline loan or deposit account applications; To service those products and services you have with us; To consider your job application for hiring; and with consultants and auditing firms, with information shared for institution risk analysis and mitigation.Service providers, sub-contractors, credit reporting agencies, government entities, or companies you authorize us to share your data with. This may include a sub-contractor who inspects real estate, or a vendor that processes check reorders or provides ID theft protection services to you on our behalf, or a company that processes our payroll if you are an employee of American First National Bank.
Any information that identifies, relates to, describes, or is capable of being associated with a particular individual, including, but not limited to, name, signature, Taxpayer I.D. such as a Social Security Number or Employer Identification Number, physical characteristics or description, birthdate, address, telephone number, passport number, driver’s license or state identification card number, employer, bank account number, credit card number, e-mail, or any other financial information, such as tax returnsDirectly from you such as information you provide on our forms, surveys and applications, including applications for employment, or similar online fields or forms or items we collect indirectly from others; such as credit reporting agencies, title companies, appraisers etc.To approve or decline loan or deposit account applications; To service those products and services you have with us; To consider your job application for hiring; and with consultants and auditing firms, with information shared for institution risk analysis and mitigation or comply with a legal or regulatory obligation.Service providers, sub-contractors, credit reporting agencies, government entities, or companies you authorize us to share your data with. This may include a sub-contractor who inspects real estate, or a vendor that processes check reorders or provides ID theft protection services to you on our behalf, or a company that processes our payroll if you are an employee of American First National Bank.
Characteristics of protected classification under California or federal law such as race or gender.Directly or Indirectly from you when you complete a mortgage loan or employment application.To comply with our regulatory obligation.Government agencies to comply with reporting requirements governed by the Home Mortgage Disclosure Act.
Commercial information, including records of personal property, or products or services purchased, obtained, or considered.Directly or Indirectly from you when you establish a deposit or loan account.To approve or decline loan or deposit account applications; To service those products and services you have with us; To provide auditing firms with information shared for institution risk analysis and mitigation or comply with a legal or regulatory obligation. Service providers, sub-contractors, who inspect real estate such as an appraisal company or real estate inspector.
Internet or other electronic network activity information, such as account numbers, Internet Protocol (IP) address.Indirectly from you when you access our products or services, our online and mobile banking applications using your personal computer, cell phone, or other electronic or mobile device.To support internal operations of our debit cards, website, mobile app or to comply with a legal or regulatory obligation.Service providers, sub-contractors or companies you authorize us to share your data with such as a vendor who we contract with to provide services via our mobile app or website.
Geolocation, including electronic network activity information pulled from a device which can be used to identify the precise location of an individual.Indirectly from you when you access our products or services, our online and mobile banking applications using your personal computer, cell phone, or other electronic or mobile device.To determine country and time zone to support the internal operations of our website or offer products or services to you, and not for any other purpose.Service providers, sub-contractors, government entities, or companies you authorize us to share your data with such as a vendor who we contract with to provide online or mobile banking services to you.
Visual or similar information.Security cameras located at our banking centers.To protect, detect, investigate, report and seek to prevent financial crime.Federal, State or local governmental agencies.
Professional or employment-related information.Directly from you; such as information you provide on our forms, surveys, applications for employment, or similar online fields or forms or items we collect indirectly from others, such as credit reporting agencies.To conduct research or to assess job qualifications if you submitted an application for employment; To open an account or to make a loan to you.Service providers or other third parties to comply with law and regulations. We may also share your personal information with credit reporting agencies or a company that processes employment applications for American First National Bank.
Inferences drawn from any of the above.Indirectly from you when you use our products or services to conduct banking transactions.To offer products and services to you, conduct investigations, or comply with our regulatory obligations.Service providers or other third parties to comply with law and regulations. We may also share your personal information with a regulator, governmental agency or otherwise.

Disclosure or Sale of Personal Information

  • We have not sold any personal information about consumers in the preceding 12-months.
  • We have disclosed personal information about consumers to third parties for a business purpose in the preceding 12-months. Below is a list of categories we have disclosed to third parties in the preceding 12-months.

Categories of Personal Information That We Disclose to Third Parties for a Business Purpose

  • Identifiers such as a real name, alias, postal address, online identifiers, email address or unique personal identifier or other similar identifiers.
  • Any information that identifies, relates to, describes, or is capable of being associated with a particular individual, including, but not limited to, name, signature, Taxpayer I.D. such as a Social Security Number or Employer Identification Number, physical characteristics or description, birthdate, address, telephone number, passport number, driver’s license or state identification card number, employer, bank account number, credit card number, e-mail, or any other financial information, such as tax returns
  • Characteristics of protected classification under California or federal law such as race or gender.
  • Commercial information, including records of personal property, or products or services purchased, obtained, or considered.
  • Internet or other electronic network activity information, such as account numbers, Internet Protocol (IP) address.
  • Geolocation, including electronic network activity information pulled from a device which can be used to identify the precise location of an individual.
  • Visual or similar information.
  • Professional or employment-related information.
  • Inferences drawn from any of the above.
  • We do not sell the personal information of minors under 16 years of age without affirmative authorization.

Right to Request Deletion of Personal Information

Federal laws may govern our retention of your information; however, anything we are not required to maintain under those guidelines may be deleted. Exceptions to our deletion responsibilities include information necessary to:

  • Complete the transaction for which the information is collected;
  • Provide a good or service requested by you or reasonably anticipated within the context of our ongoing business relationship with you;
  • Perform a contract between us and you;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or to prosecute those responsible for that activity;
  • Debug to identify and repair errors;
  • To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • Comply with a legal obligation;
  • Otherwise use your information internally in a lawful manner that is compatible with the context in which you provided the information.

To request the deletion of any personal information about you which we have collected or maintained, you may submit a verifiable consumer request to us by following the instructions below:

  • You can submit a request at any of our California branch locations;
  • Call the toll free number: (877) 473-1888
  • You can submit your request online
  • Submit a request by mail to:
    American First National Bank
    9999 Bellaire Blvd.
    Houston, Texas 77036

California law requires us to verify your identity before we can process your request. In order to verify your identity we may need to request specific information from you such as your account number, the date or amount of your last deposit or withdrawal that you made and match that information with the information we already maintain on you. If you maintain a password protected account with us we can verify your identity through our existing authentication practices, such as two-factor authentication. This helps us confirm your identity and ensure you can exercise your right to access the information.

Right to Opt-Out of the Sale of Personal Information

You have the right to opt-out of the sale of your personal information; however, we do not and will not sell your personal information.

Right to Non-Discrimination for the Exercise of Your Privacy Rights

You have a right not to receive discriminatory treatment by American First National Bank for the exercise of the privacy rights conferred by the California Consumer Privacy Act (California Civil Code § 1798.100 et seq.).

Authorized Agent

You may designate an authorized agent to make a request under the California Consumer Privacy Act on your behalf. If you wish to authorize another person to act as authorized agent on your behalf, you must provide the authorized agent permission to do so; in which case, we will request specific information to help us identify their identity. We may also require you to verify your own identity directly with us. We reserve the right to deny a request from an agent that does not submit proof they have been authorized by you to act on their behalf.