Privacy and Security Disclosure
Notice of Your Financial Privacy Rights
Association Capital Bank, a Division of Texas Capital Bank is committed to protecting your financial privacy, just as we protect your financial assets. This notice describes our Privacy Policy and the measures we take to protect the privacy of your non-public personal information. We do not disclose non-public personal information about you to anyone except as permitted by law.
Definitions
"You" and "your" means Consumer Deposit Account, Consumer Loan Account, Safe Deposit Box Customers, Residential Mortgage Consumers and all persons who use our trust department.
"We", "our" and "us" means Association Capital Bank, a Division of Texas Capital Bank.
"Non-public personal information" means information about you that we collect in connection with providing a financial product or service to you. Non-public personal information does not include information that is available from public sources, such as telephone directories or government records.
An "affiliate" is a company we own or control, a company that owns or controls us, or a company that is owned or controlled by the same company that owns or controls us. Ownership does not mean complete ownership, but means owning enough to have control.
A "non-affiliated third party" is a company that is not affiliated with ours.
The Information We Collect
We collect non-public personal information about you from the following sources:
• Information we receive from you for products and services on applications, forms or other means (for example, assets, income and debt)
• Information about your transactions and experiences with us (for example, account balances, account activity and usage and payment history)
• Information about your transactions with non-affiliated third parties
• Information from consumer or credit reporting agencies and other outside sources (for example, creditworthiness, credit history and employment verification)
Non-public Personal Information and Non-affiliated Third Parties
Since we value our customer relationship with you, we will not disclose your non-public personal information to outside marketers or other companies to allow them to independently solicit you for their products or services. In addition, we will not disclose your non-public personal information with non-affiliated third parties except as permitted by law. Examples may include a disclosure in connection with a subpoena or similar legal process, a fraud investigation, recording of deeds of trust and mortgages in public records, credit reporting, an audit or examination. We may also disclose customer information to companies that perform services on our behalf, such as account processing, statement processing and check printing. We require outside companies and independent contractors to whom we provide customer information for servicing or processing purposes enter into a confidentiality agreement that restricts the use of any non-public personal information to their agreed upon purposes and prohibits the independent use of that information.
The Confidentiality, Security and Integrity of Your Non-public Personal Information
We restrict access to non-public personal information about you to those employees who need to know that information to provide products or services to you. Our employees are bound by a code of conduct requiring confidential treatment of customer information. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your non-public personal information.
Non-public Personal Information and Former Customers
Our policy for the collection and disclosure of information about customers contained in this Privacy Disclosure applies to both current and former customers.
Non-public Personal Information and Our Affiliates
We may disclose information about you to our affiliates. Here are the kinds of information and the source of that information: Information about your transactions and experience with us, such as name, address, account balances, account activity, types of accounts, transaction history and payment history. Federal law allows us to disclose the information listed above with our affiliates. You do not have a right to opt out of the disclosure of this information.
Types of Affiliates
We may disclose information about you to the following types of affiliates: financial service providers, such as insurance agents, life insurers and property and casualty insurers.
Reasons for Disclosure
We may disclose information about you to our affiliates to: provide you with information about additional products and services; better serve you; help us save you time and money; and to understand your specific needs.
Who to Contact
If you have questions concerning our privacy policy or believe that your right to financial privacy has been compromised, please contact:
Compliance Officer
2000 McKinney Avenue, Suite 900
Dallas, Texas 75201
214.932.6600
or
Office of the Comptroller of Currency
Customer Assistance Unit
1301 McKinney Street, Suite 3710
Houston, Texas 77010
800.613.6743
Corporate Security
Association Capital Bank, a Division of Texas Capital Bank, (“Bank”) strives to provide a safe environment for employees, customers, vendors and visitors. Association Capital Bank continues to maintain and update effective security programs to protect against a variety of operational and transactional risks, including crime, fraud and natural disaster. Many laws and regulations intensify regulatory attention on the Bank’s risk management program and controls in place to guard against threats. As threats to security change and technology improves, it becomes necessary and essential for our systems to be upgraded to maintain a secure operating environment.
Our physical facilities, both branch and office locations, are an integral part of our security protocol to ensure maximum safety for employees and customers. Corporate Security has an experienced Chief Fraud Investigator. Fraud issues occasionally contain a criminal component and it is our procedure to investigate and prepare documentation for potential prosecution and/or asset recovery.
Association Capital Bank is committed to protect customer assets and the assets of the “Bank.” We take pride in our security culture and management support to provide the utmost assistance to our customers and employees in this endeavor.
Neal Baker
Chief Fraud Investigator
214.932.6833
Mike Secor
Director Physical Security
214.932.6809