Introduction and Scope of Privacy Policy

This Privacy Policy applies to your interaction with Ponce Bank or any of its subsidiaries: (1) at any online or mobile site or application that we own and control, unless a different online and/or mobile or other privacy policy is posted relating to a particular site, application, product, or service, or is made available to you and by its terms supplants this Privacy Policy: or (2) via a Ponce Bank advertisement, page, or account on a third party site.

We may collect, retain, use, and disclose personal and other information about you in accordance with this Privacy Policy.

Other privacy policies may also apply in addition to the terms of this Privacy Policy.

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Agreement to Privacy Policy

To the extent permitted by applicable law, by using the Site or interacting with a Ponce Bank advertisement or page or account on a third party site, you consent to this Privacy Policy, including your consent to our use and disclosure of information about you in the manner described below.

Information You Provide

We collect information about you and your use of our Site, some of which may not or may not be personally identifiable. Personal information includes “personal information” as defined by the California Consumer Privacy Act (“CCPA”). This includes, but is not limited to:

• Real name, alias, unique personal identifier, online identifier, Internet Protocol address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers;
• Signature, physical characteristics or description, state identification card number, insurance policy number, education, employment, employment history, credit card number, or any other financial information, medical information, or health insurance information;
• Characteristics of protected classifications under California or federal law (sex, race, ethnicity, age);
• Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with the Site or advertisement;
• Audio, electronic, visual, or similar information;
• Professional (or employment) related information;
• Education information; and
• Any other information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.

Keeping your personal information accurate and up to date is very important. If your personal information is incomplete, inaccurate or not current, please use the Contact Us option on our Site, or call or write to us at the telephone numbers or appropriate address for changes listed on your account statements, records, online or other account materials.

Information Uses

We collect personal information about you through your computer or mobile devices by the use of cookies and similar tracking technologies as well as personal information you provide when you visit or use our Site or mobile app. We may use the information that we collect from you to:

• Process applications and transactions;
• Verify your identify (such as when you access your account information);
• Provide you with the services or products that we offer on the Site;
• Respond to your inquiries, requests, or other service-related purposes;
• Communicate with you to administer the Site, including notifying you about any updates, changes, or additions to this Privacy Policy;
• Enhance your experience with us, such as tailoring the Site content to your preferences or developing new products or services based on your interactions with the Site;
• Send you information about products or services that we think may be of interest to you;
• Carry out any specific purposes for which we have obtained your prior consent; or
• Conduct any other legitimate business activities not otherwise prohibited by law.

We may also use your information for business purposes such as:

• Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Debugging to identify and repair errors that impair existing intended functionality;
• Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services; or
• Any commercial purposes, including any purpose to advance your commercial or economic interests, such as by inducing you to buy, join, subscribe to, provide, or exchange products, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.

Information Sharing

We may share information about you with relevant and appropriate third parties in the following situations:

• To our service providers that perform functions on our behalf;
• To protect or enforce our rights or property, to protect your safety or the safety of others, or to investigate, prevent, or take action against fraud or other illegal activities;
• In response to legal process or as otherwise required by law;
• In the event that we experience a business transition or conduct a corporate transaction requiring due diligence, such as a merger, capital investment, acquisition by another company, or sale of all or a portion of its assets; or
• To conduct any other legitimate business activities not otherwise prohibited by law.

Not withstanding anything else in the Privacy Policy, we may share aggregate or non-personally identifying information about the users of the Site with third parties for marketing, advertising, research, or other business purposes.

We retain all information in-house except when required to share it with our partners as a necessary function of the lending process. Such partners include title and escrow companies and appraisal services.

To learn more about our privacy practices relating to your personal financial information, please see our  Gramm-Leach-Bliley Act Privacy Notice.

Information Security

The security of your personal information is a top priority. While we strive to use commercially reasonable means to protect your personal information, we cannot guarantee its absolute security as no method of transmission over the Internet, or method of electronic storage, is 100% secure.

Web Technologies

We use online tracking technologies, including cookies, web beacons, tags, pixels and embedded Web links, to help us personalize and improve your Site experience as well as provide you with relevant online advertising.

Cookies

Cookies are small text files that websites store on your computer. They are managed by your particular web browser and are typically used to store bits of text.

Website Usage

When you browse or visit our Site, we may collect information about your use of our Site through cookies. This information could include your browser type and language, access times, and the address of the Site from which you arrived. They may also collect information about your Internet Protocol (IP) address, click stream behavior (i.e., the pages you view, the links you click, and other actions you take in connection with websites or “powered by” websites or mobile apps), and product information.

We may collect personal information about your online activities over time when you use our Site.

Web Personalization

Cookies help us to personalize your experience with our Site and improve your navigation within the Site by tailoring our Site to your individual preferences. Cookies help you save time if you visit the Site again. For example, if specific programs associated with our Site require a user ID and password, you have the option of requesting that we save that information so that you will not have to re-enter it the next time you access the Site. You can disallow cookies or prevent them from being set by making the appropriate selection from your browser options. However, if you set your browser options to disallow cookies, it may limit the functionality of the Site.

Behavioral Targeting

Third party advertisers, including Google, may also use cookies to collect non-personally identifiable information from your browser, such as pages you visited, tools you have interacted with, the channel or method in which you arrived on our Site, etc., so that they can tailor the ads you see to your preferences and behaviors. Third party cookies may also track the number of ad impressions, other uses of ad services, and interactions with these ads.

By continuing to browse on our Site, you are consenting to the use of cookies for personalization and advertising purposes.

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Disallowing Cookies

For instructions on disallowing cookies within your particular web browser, click the link with the name of your web browser below:

• Google Chrome
• Internet Explorer
• Mozilla Firefox
• Safari

Even if you disable tracking, please note that you may still receive interest-based advertising, including from third parties with whom your information had been previously disclosed or advertising from third parties that is not based on your behavior, interests, and preferences.

Links to Third Party Sites or Content

The Site may contain links to websites controlled or offered by third parties (non-affiliates of Ponce Bank). Ponce Bank hereby disclaims all liability for any other company's website content, products, privacy policies, or security. In the event you choose to use the products and services available at a linked site, you agree to read and adhere to the policies and terms of use applicable to that site. In addition, any advice, opinions, services, products, or recommendations provided by the linked site providers are those of the providers and not of Ponce Bank. Your participation in any linked site, including payment for and the delivery of goods or services, is based solely on the agreement, if any, between you and the linked site provider.

Age Restrictions

This Site is not intended for use by children or minors. We do not knowingly solicit information from children, and we do not knowingly market to children. Please notify us immediately if you believe that we may have collected personal information from a child under the age of 13 years, so that we can delete such information.

California Privacy Rights

Under the CCPA, to the extent we are subject to the CCPA, California residents have the right to:

• Request that a business delete any personal information about the consumer which the business has collected from the consumer.
• Request that a business that collects personal information about the consumer disclose to the consumer, free of charge, the following:
• The categories of personal information that it has collected about that consumer.
• The categories of sources from which the personal information is collected.
• The business or commercial purpose for collecting or selling personal information.
• The categories of third parties with whom the business shares personal information.
• The specific pieces of personal information it has collected about that consumer.
• Request that a business that sells the consumer’s personal information, or that discloses it for a business purpose disclose, free of charge, to the consumer:
• The categories of personal information that the business collected about the consumer.
• The categories of personal information that the business sold about the consumer and the categories of third parties to whom the personal was sold, by category or categories of personal information for each third party to whom the personal information was sold.
• Direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal information.

If the CCPA is applicable, you may submit a request under the CCPA through the following methods:

• You may call us at (718) 931-9000.
• You may submit a request through contact.center@poncebank.net.

To submit a request, we are required to verify your identity. Please be prepared to provide us with your first and last name, primary telephone number, e-mail address, and current address. We will match the personal information that you provide to us with personal information that we already maintain about you in order to verify your identity. We may also need to contact you to confirm your request.

You may also designate an authorized agent to make such requests on your behalf. You have two ways to accomplish that. First, you may provide your authorized agent with written and signed permission to make such requests. Second, you may provide your authorized agent with power of attorney pursuant to California Probate Code Sections 4000 to 4465. Regardless of which option you choose, (1) you must (a) verify your identity directly with us and (b) confirm directly with us that you have given permission to the authorized agent to make such requests and (2) your authorized agent must submit proof that you have authorized him/her/them to make such requests on your behalf. If the authorized agent is unable or unwilling to submit such proof, we may deny such requests.

We may not be able to honor each request that we receive, but if we are unable to do so, we will respond to let you know our reasons. We will not discriminate against you if you choose to exercise any of your rights as described in this section.

Privacy Policy Changes

We reserve the right to change, modify, add or remove portions of this Privacy Policy at any time. Unless otherwise stated, any modifications to this Privacy Policy will go into immediate effect after they have been posted. Your continued use of this Site indicates your consent to the Privacy Policy posted at the time of use.

Contact Us

If you have any questions about this Privacy Policy, please contact us at (718) 931-9000.

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