Privacy Policy

Digital Privacy Policy

This policy describes First Federal Bank’s (“we” or “our”) collection, processing, transfer, and storage of data from digital banking application users or visitors to our website(s) at www.firstfederalbanknc.com, www.ffbnc.com, or www.ffbmtg.com (our “Website”). This Digital Privacy Policy applies to the data collected by digital banking applications (the “App”) or on the Website and not to other data collected or processed by First Federal Bank.

This Digital Privacy Policy, in combination with other relevant privacy notices that we provide to you (e.g., pursuant to financial privacy laws), inform you of the policies and practices regarding the collection, use and disclosure of any personal information that we and our service providers collect from or about users in connection with the Website, the App’s website, and mobile application (the “Services”).

If you are a First Federal Bank customer, please see our Consumer Privacy Notice, which we provide to all our individual customers, for a comprehensive explanation of how we collect, use, and share personal information and your choices for limiting the use and sharing of your information as our customer.

1. OUR COMMITMENT TO YOUR PRIVACY

This Digital Privacy Policy describes:

• How information about you is collected;
• How we use and with whom we share this information;
• How you can access and update this information; and
• The choices you can make about how we collect, use and share your information.

If you have any questions regarding this Digital Privacy Policy or our information collection and use practices, please contact us using the information in the “Contact Us” section below.

2. INFORMATION COLLECTED THROUGH OUR WEBSITE

First Federal Bank collects information from Website visitors and also obtains information from third parties (including from service providers) in the course of providing our deposit, loan, and mortgage origination services (our “Services”), which we may add to the data we obtain through the Website. The information collected through our website includes:

• Personal and Account-related Information. You may provide us information about you, which may include personal information and information relating to or necessary for the initiation, processing, or completion of certain financial transactions, including the issuance of deposit accounts or loans.
• Transactional Information. We may also create transactional records of each of the transactions or other events occurring through our Website. This transactional information is generally collected (i) to enable our Services, including document creation, origination, management, and distribution, (ii) to enable the services provided by third parties (including determinations regarding qualification for deposit accounts or loans or the interest rates to be applied to deposit accounts or loans), and (iii) to enable First Federal Bank to comply with various legal obligations.
• Device and Usage Information. Like most online services, our Website collects standard technical, non-personal information when you use it, including internet protocol (IP) addresses, browser types, internet service providers (ISPs), the pages and content you view or interact with on our Website, the information you search for, and the dates and times that you visit our Website.
• Cookies and Other Technologies. Our Website collects certain information through the use of “cookies” and other tracking technologies. Cookies are small files that your browser places on your computer. We may use session cookies, persistent cookies, and other tracking technologies to better understand how you interact with our Website, to monitor usage by our users and web traffic routing on our services, and to improve and personalize our Website. Many Internet browsers automatically accept cookies. You may be able to instruct your browser to stop accepting cookies or to prompt you before accepting cookies from the websites you visit. Google provides some additional privacy options relating to Google analytics, described at www.google.com/policies/privacy/partners/. We do not respond to “do not track” browser signals at this time. We may also use web beacons, which are transparent graphic images on a webpage or within the body of one of our marketing emails, to allow us to measure visitor actions and assess the effectiveness of our email marketing campaigns. For example, we use web beacons in our email marketing to track instances where a user clicks through a link in the email.

3. INFORMATION COLLECTED THROUGH DIGITAL BANKING APPLICATIONS

(FFB CARD CONTROL, FFBNC MOBILE, FFBNC BUSINESS MOBILE)

Through your use of the Services, we may collect personal information from you in the following ways:

• Personal Information You Provide to Us. We may collect personal information from you, such as your first and last name, address, e-mail, telephone number, and social security number when you create an account. We will collect the financial and transaction information necessary to provide you with the Services, including account numbers, payment card expiration date, payment card identification, verification numbers, and transaction and payment history. If you provide feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply. We also collect other types of personal information that you provide voluntarily, such as any information requested by us if you contact us via email regarding support for the Services.
• Personal Information Collected from Third Parties. We may collect certain information from identity verification services and consumer reporting agencies, including credit bureaus, in order to provide some of our Services.
• Personal Information Collected Via Technology. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our Services, our communications, and other online services, such as:

• Device data, such as your computers or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
• Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns.
• Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
• Location Information. If you have enabled location services on your phone and agree to the collection of your location when prompted by the Services, we will collect location data when you use the Services even when the app is closed or not in use; for example, to provide our fraud detection services. If you do not want us to collect this information, you may decline the collection of your location when prompted or adjust the location services settings on your device.

Additionally, we may collect Personal Information about you, which may include: name, postal address, zip code, e-mail address, telephone number, account numbers, payment card expiration date, payment card identification or verification numbers, social security number, mobile device location, and other information that we can use to contact you, verify your identity, provide the functionality available through use of the App and the Service, and manage risks, such as information maintained about you by identity verification services and consumer reporting agencies, including credit bureaus, and payment and other transaction information, and history for payments and other transactions in which you participate through the Service, and any Personal Information that you may enter into information blocks present in the App interface or made available through the Service. We may collect information regarding your mobile device such as device settings, unique device identifiers, information about your location, and analytical information that may assist with diagnostics and performance. For your convenience, you may be asked to grant permission for access to your mobile device’s geolocation data. This information may be collected when you use certain services that are dependent on your mobile device’s location
(such as the location of an ATM or in store transactions).

First Federal Bank may collect Personal Information about you by the following methods:

• Information that you input to the App or that the App collects automatically;
• Your use of the App and the Service, and your interactions with customer care, including information you enter or speak, and information transmitted by your computer or mobile device or other devices you use as part of your receipt of the Service; and
• We may also collect Personal Information about you from others, such as Affiliates, or other companies (such as for fraud detection).

4. HOW WE USE INFORMATION

We and service providers working on our behalf use information collected in a variety of ways intended to provide our Website, Applications, and Services and to operate our business, including the following:

• To Provide our Services. We use the information that we collect (i) to operate, maintain, enhance and provide our Website and our Services, (ii) to provide other services and information that you request, (iii) to provide customer support to you and other parties, and (iv) to complete transactions and render services authorized by you.
• To Improve, Analyze, and Personalize our Website and Services. We use the information that we collect to understand and analyze usage trends and preferences; to monitor and analyze the effectiveness of our Website and Services; to improve our Website and Services and develop new products, services, features, and functionality; and to personalize our Website and Services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you use our Website, or providing customized content and information.
• To Provide Access to Digital Banking Applications. We use the information that we collect for Other everyday business purposes, such as to maintain your ability to access the Service, to send you information about the Service, to effect, administer and enforce transactions, to perform fraud screening, to prevent actual or potential fraud and unauthorized transactions, to verify your identity, to determine your credit history, to verify the information you provide to the Service, to perform collections, to report to credit bureaus (including furnishing delinquent account information), to comply with laws, regulations, court orders and lawful instructions from government agencies, to protect the personal safety of users of the Service or the public, to prevent and defend claims, to resolve disputes, to troubleshoot problems, to enforce our Terms of Use, to protect our rights and property, and to customize, measure, and improve the Service and the App, including pattern recognition, modeling, enhancement and improvement, system analysis, and Service performance analysis;
• To Contact You. We may use your email address or other information we collect to contact you for administrative purposes such as customer service or to send communications, including marketing or promotional communications, relating to our Website and Services. Generally, you have the ability to opt out of receiving promotional communications as described below.
• Aggregate Data. We aggregate data collected through our Website and use it for purposes such as creating and sharing reports about the use of our products and services, including users’ interests, usage patterns, and trends.
• Advertising. We may use non-identifiable information that you provide or that we collect to improve or tailor the effectiveness of advertising on our Website or other Services o provide advertisements and other content that is tailored to you.

5. HOW WE SHARE INFORMATION

We may share, transfer, or disclose your information if you consent to us doing so, as well as in the following circumstances:

• To Service Providers. We work with third party service providers to provide services including account or transaction processing or administration; Website hosting and other similar services, development and maintenance; advertising and marketing services; and other services related to our Website and Services for us. These third parties may have access to or process your information as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information. These service providers are not permitted to use information we share that might identify you for any purpose other than to provide services to First Federal Bank or to you.
• In Aggregate Form. We may make certain aggregated non-personal information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business purposes; or (iii) to assist such parties in understanding our users’ interests, usage patterns, deposit origination, and borrowing and loan origination trends.
• Compliance with Laws and Law Enforcement; Protection of Our Rights. We may disclose your information (including your personal information) to a third party if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce our agreements, policies and terms of service, (c) to protect the security or integrity of our Website or Services, (d) to protect the property, rights, and safety of First Federal Bank, our users or the public from harm or illegal activities, (e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person, or (f) to investigate and defend ourselves against any third-party claims or allegations.
• In Significant Business Transactions. Your information, including personal information, may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

6. DISCLOSURE OF YOUR PERSONAL INFORMATION

We disclose your personal information collected through your use of the Services as described below.

• In Accordance with Our Other Privacy Notices. Other than as described in this Privacy Policy in connection with the App, this Privacy Policy does not apply to the processing of your information by us or third parties with whom we share information.
• Third Party Service Providers. We may share your personal information with third party or affiliated service providers that perform services for or on behalf of us in providing the App, for the purposes described in this Privacy Policy, including: to provide you with the Services; to conduct quality assurance testing; to facilitate the creation of accounts; to optimize the performance of the Services; to provide technical support; and/or to provide other services to the App.
• Authorities and Others. Regardless of any choices you make regarding your personal information, The App may disclose your personal information to law enforcement, government authorities, and private parties, for the compliance and protection services described above.

7. YOUR CHOICES REGARDING YOUR INFORMATION

You have several choices regarding use of information on the Services.

• How We Respond to Do Not Track Signals. Some web browsers transmit “do not track” signals to the websites and other online services with which your web browser communicates. There is currently no standard that governs what, if anything, websites should do when they receive these signals. We currently do not act in response to these signals. If and when a standard is established, we may revise its policy on responding to these signals.
• Access, Update, or Correct Your Information. You can access, update, or correct your information by changing preferences in your account. For additional requests, please contact us.
• Opting Out of Email or SMS Communications. If you receive our email communications, you can unsubscribe any time by clicking the “unsubscribe” link included at the bottom of the email or other electronic communication. Alternatively, you can opt out of receiving marketing communications by contacting us at the contact information under “Contact Us” below. If you provide your phone number through the Services, we may send you notifications by SMS, such as provide a fraud alert. You may opt out of SMS communications by unlinking your mobile phone number through the Services.
• Opting Out of Location Tracking. If you initially consented to the collection of geo-location information through the Services, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. Please note, however, that if you withdraw consent to our collection of location information, you may no longer be able to use some features of the App.

8. HOW TO ACCESS AND UPDATE YOUR INFORMATION

You can access and update the information that you have provided to us as follows:

• If you are a First Federal Bank customer, you can access and update certain personal information in connection with your account or application by logging into your account online.
• You may contact us at customer.service@firstfederalbanknc.com and request to review, amend or delete certain personal information collected by us.
• Please note that we may not be able to delete all information we collect.
• You may opt-out of receiving marketing emails at any time by following the steps to “unsubscribe” described in the footer of our marketing emails. Your opt-out will become effective in 10 days or less.

9. OUR POLICY CONCERNING CHILDREN

Our website is not directed to children under 13, and we do not knowingly collect any personal information from children under the age of 13 through our website. If we become aware that a child under 13 has provided us with personal information through our website, we will take steps to delete such information.

10. PRIVACY POLICIES OF LINKED SITES

Our Website may contain links to other sites. We are not responsible for the privacy practices or the content of such sites. The App’s provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents.  We have no control over, do not review, and cannot be responsible for, these outside websites or their content.  Please be aware that the terms of this Privacy Policy do not apply to these outside websites. If you have any questions about how these other sites use your information, you should contact them directly.

11. SECURITY

First Federal Bank has certain measures in place to maintain the security, confidentiality and integrity of the information we gather , and to help protect against the loss, misuse and alteration of such information. While we take measures to protect your personal information against security breaches and unauthorized access, we cannot guarantee that our safeguards will be effective all of the time against all security threats.

12. CHANGES TO OUR DIGITAL PRIVACY POLICY

This Digital Privacy Policy may be revised from time to time. If we decide to make material changes to our Digital Privacy Policy, we will make reasonable efforts to notify you of the changes by sending a notice to the primary email address provided to us and/or by placing a notice on our Website.

113. CONTACT US

If you have any questions, comments or concerns regarding our Digital Privacy Policy and/or practices, please send an email to: customer.service@firstfederalbanknc.com.

First Federal Bank
200 East Divine Street
Dunn, NC 28334
910-892-7187