Company Policy

wintrustfultons Privacy Policy

Last Updated: [17th May 2023]

Thank you for choosing wintrustfultons for your financial services needs. Your privacy and the security of your information are of utmost importance to us. This Privacy Policy outlines the purpose, basis, and practices for processing your information when you use our products and services. Please read this policy carefully to understand how we collect, use, and protect your personal information.



1. Purpose and Basis for Processing Your Information

1.1. Purpose for Processing: We process your information to provide our products and services to you effectively. This includes account setup, offering loans and payment services, managing risk, adhering to legal and regulatory requirements, and ensuring the security and integrity of our systems and data.
1.2. Legal Basis: The legal basis for processing your information depends on the specific purpose. We rely on our legitimate interests in enabling our products and services, managing risk, complying with legal and regulatory obligations, and maintaining security for most customer interactions. For certain direct marketing purposes, we may also seek your consent.
1.3. Consent: When we rely on your consent, we will obtain it in a manner that respects your privacy. You can withdraw your consent at any time, but this may affect your access to certain services.



2. How We Use Your Information

2.1. We use your information for various purposes, including:
2.1.1. Managing and setting up your accounts.
2.1.2. Monitoring and preventing fraud.
2.1.3. Responding to customer service requests.
2.1.4. Assessing and managing credit risk.
2.1.5. Enforcing legal and regulatory obligations.
2.1.6. Managing risk through anonymized or pseudonymized data and conducting profiling for fraud prevention and management.

2.2. Direct Marketing: We may use your information for direct marketing purposes with your consent, including informing you about products, services, promotions, and opportunities.
2.3. International Processing: Your information may be used and processed by us and third parties in different jurisdictions for the purposes described in this document.



3. Disclosures of Your Information

3.1. We may disclose your information to third parties, such as:
3.1.1. Service providers and third-party contractors who perform functions on our behalf.
3.1.2. Payment providers and financial institutions for enabling payments.
3.1.3. Governmental and regulatory authorities to comply with legal and regulatory obligations.
3.1.4. Third parties to whom we may be legally required to disclose information for investigations or other proceedings.
3.2. In some cases, we may be required by law to provide information about our customers to authorities.
3.3. Please note that privacy laws may vary across jurisdictions.



4. Sharing Your Information with Third Parties

4.1. We may share your information with third parties for purposes such as:
4.1.1. Enabling the delivery of products and services.
4.1.2. Providing third-party insights for decision-making and business processes.
4.1.3. Assisting in meeting legal and regulatory obligations.



5. Transfers of Your Information Abroad

5.1. In compliance with our data protection policies and relevant laws, we may transfer and store your information in different jurisdictions.



6. Retention and Deletion of Your Information

6.1. We retain your information for as long as necessary to fulfill the purposes and comply with legal and regulatory obligations. We may also retain information for legitimate interests or as required by third parties.
6.2. Aggregated and anonymized data will be retained indefinitely.
6.3. We will take reasonable steps to delete or remove your information when no longer required.



7. Your Rights and Opt-Outs

7.1. You have certain rights under data protection laws, including access, rectification, erasure, and objection to certain uses of your information. However, legal and regulatory obligations may require us to continue processing your information.
7.2. To exercise your rights, contact us using the provided contact details.
7.3. Laws and regulations may vary depending on your location and the specific circumstances of your request.
7.4. You have the right to opt-out of certain types of direct marketing.
7.5. Opting out may apply to future communications but not to those already received or legally required non-promotional communications.



8. Compliance with Children's Privacy Protection Legislation

8.1. We do not knowingly collect, use, or disclose personal information from individuals under the age of 18.
8.2. If we unintentionally collect such information, we will promptly delete it.
8.3. Additional information may be required from parents or legal guardians.



9. Links to Third-Party Websites

9.1. Our website may contain links to third-party websites. We are not responsible for their privacy practices or content. Review their privacy policies before visiting.



10. Updates to this Privacy Policy

10.1. This privacy policy was last updated on [17th May 2023]. We may update it to reflect changes in our practices or to comply with the law. Changes will be effective upon posting on our website. We encourage you to review it periodically.



11.Headings and Sub-Headings

11.1. The headings and sub-headings in this privacy policy are for convenience and do not affect the meaning or interpretation of the policy.