Smart Rewards Mobile Policy

This Privacy Policy describes our practices related to the use, storage and disclosure of information we collect from or about you in the course of providing the Smart Rewards Service. We reserve the right to modify this Privacy Policy at any time and without prior notice. The privacy policy links within the online and mobile channels will direct your device to the most recent version of this Privacy Policy. This Privacy Policy is not a contract and does not create any legal rights or obligations. Terms defined in the Smart Rewards Mobile Application Terms of Use shall have the same meaning in this Privacy Policy, unless otherwise stated below.

Through both the Mobile and online services, you may use your Eligible Device to (i) view balances and recent transactions for each Account; (ii) make immediate, one-time transfers of funds between your Accounts; and (iii) access additional services that may be available through the Smart Rewards Service.

Automatically Collected Information and Device Access - In addition, when using the Smart Rewards Service, we may collect certain device information automatically, such as the type of device you use, your device’s unique device ID, the IP address of your device, the geographic location of your device, your operating system, and certain information about the way you use the Smart Rewards Service. The Smart Rewards Service may also access the following information when needed to perform services that you request: access to location information based on cellular network database and GPS; access to phone operations to call phone numbers without user’s intervention, access to phone information (e.g. phone number and serial number of device, whether a call is active, the phone number being called); internet access to create network sockets; access to contact (address) data stored on the phone or computer; access to information about the state of Wi-Fi and all networks; access extra location provider commands; access to device storage to write, modify, or delete content. This information is only accessed to provide the services necessary within the Smart Rewards Service that you choose to use.

User Provided Information – The Smart Rewards Service obtains the information you provide when you download the Mobile App and register either on the Mobile App or online . Registration with us is mandatory in order to be able to use the basic features of the Smart Rewards Service. During registration, you generally provide: name, email address, phone number, user name, password and other registration information. We use this registration information to create a unique user profile for you, which is required to access and use the Smart Rewards Service. We may also use the contact information you provide us to notify you from time to time of important information and updates related to the Smart Rewards Service or other banking services.

When using the Smart Rewards Service, you generally provide information we must use to complete requested transactions. Such transaction-related information may include: account information, transfer amounts, dates, and frequency.

Unless you have opted-out through your device settings, the Smart Rewards Service may collect precise information about the location of your device. Location information is accessed when you choose to use location-based services. Location information is obtained from technologies like GPS, Wi-Fi, or cell tower proximity. You may at any time opt-out from allowing the Smart Rewards Service to have access to your location data through your device settings. We do not control your location information preferences from within the Smart Rewards Service. For more information, please see the section below regarding “opt-out rights.”

We use your location information to provide requested location-based services, such as finding ATMs and branches nearest to you and displaying them on a map in relation to your location.

Do third parties see and/or have access to information obtained by the Smart Rewards Service?

Yes. Subject to applicable law and regulation, we may share information collected by the Smart Rewards Service with third parties only in the ways that are described in this Privacy Policy.

We may disclose user-provided and automatically collected Information:

  • as required by law, such as to comply with a subpoena, or similar legal process;

    when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; and

    with our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this Privacy Policy.

We use the information collected about you and your device to maintain and provide you with the Smart Rewards Service, to respond to your questions and instructions, to maintain the integrity of our network and address security issues, to detect fraud, to investigate or take action regarding violations or suspected violations of law or our terms, and to improve the Smart Rewards Service.

Opt-out rights

You may at any time opt-out from allowing the Smart Rewards Service’s access to your location information by disabling location tracking features in your device settings. Turning off your device’s location tracking features will prevent the Smart Rewards Service from performing location-based services, such as finding nearby ATMs and branches. You may also refrain from using Smart Rewards Service features that collect specific types of information.

You can stop all collection of information by uninstalling the Smart Rewards Service. You may use the standard uninstall processes available as part of your device or via the removal features provided in your Smart Rewards Service store or network. Once you have uninstalled the Smart Rewards Service, any preferences that you previously set within the Smart Rewards Service are deleted, such as location permissions and whether you allowed us to send you push notifications.

Do Not Track signals

Do Not Track (DNT) is a privacy preference that users can set in recent versions of most major web browsers, including Firefox 5+, Internet Explorer 9+, Safari 5.1+, and Chrome. DNT allows users to inform web services that they do not want certain information about their webpage visits collected across websites.

Whether you have turned on DNT or not, the Smart Rewards Service does not collect personally identifiable information (PII) about your online activities over time and across third party websites or online services. Nor do third parties use the Smart Rewards Service to collect PII about your online activities over time and across third party websites. For these reasons, the Smart Rewards Service does not respond to DNT signals.

Data Retention

Our operational systems will store user-provided data for as long as you use the related feature of the Smart Rewards Service, unless you choose to delete it. Please note that some or all of the user-provided data may be required in order for the Smart Rewards Service to function properly, and we may be required to retain certain information by law. If you close your profile established for Online and Mobile Banking, we will retain certain account data, such as transaction history and account balances, for a reasonable time to facilitate any request to reopen your profile.


Protecting the confidentiality of your information is very important to us. We have established appropriate physical, electronic, and procedural safeguards to protect information we collect from or about our users. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Smart Rewards Service. These safeguards are regularly reviewed to protect against unauthorized access, disclosure and improper use of your information and to maintain the accuracy and integrity of that information.


This Privacy Policy may be updated from time to time, as new versions of the Smart Rewards Service are released, modified or expanded. The Privacy Policy link within the Smart Rewards Service will direct your device to the most recent version of this Privacy Policy. We will notify you electronically of any material changes to our Privacy Policy in accordance with the Smart Rewards Mobile Application Terms of Use. Your use of the Smart Rewards Service following an update to this Privacy Policy means that you accept the updated Policy.

Your Consent

By using the Smart Rewards Service, you are consenting to our processing of user-provided and automatically collected information as set forth in this Privacy Policy, now and as amended by us. "Processing,” means using cookies on a computer/hand held device or using information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, as necessary to provide the Smart Rewards to you.

Contact us - If you have any questions regarding privacy while using the Smart Rewards Service, or have questions about our practices, please contact us at 1-833-736-5441.