BBVA Compass Bank

BBVA Compass Mobile Application Privacy Policy

Effective date: November 22, 2013

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 Mobile Banking Service through our Mobile Application. We reserve the right to modify this Privacy Policy at any time and without prior notice. The privacy policy link within the Mobile Application 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 BBVA Compass Mobile Banking Terms of Use shall have the same meaning in this Privacy Policy, unless otherwise stated below.

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

What information does the Mobile Application obtain and how is it used?

User Provided Information - The Mobile Application obtains the information you provide when you download and register the Mobile Application. Registration with us is mandatory in order to be able to use the basic features of the Mobile Application. You can use the Mobile Application after registering for Online Banking or registering for Mobile Banking from within the Mobile Application. During registration, you generally provide: your check card number and PIN, 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 Mobile Banking 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 Mobile Application.

When using the Mobile Application, you generally provide information we must use to complete requested transactions. Such transaction-related information may include: account information, transfer amounts, dates, frequency, recipient name and contact information, and check images.

Automatically Collected Information and Device Access - In addition, the Mobile Application may collect certain device information automatically, such as the type of mobile device you use, your mobile device’s unique device ID, the IP address of your mobile device, the geographic location of your mobile device, your mobile operating system, and certain information about the way you use the Mobile Application. The Mobile Application 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; 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 within the Mobile Application that you choose to use. The Mobile Application will activate your camera if you choose to take a picture of a check or a bill payment coupon. If you choose, the Mobile Application can access your contacts stored on the device when you are selecting the recipient of a transfer or transaction notice.

Does the Mobile Application collect precise real time location information of the device?

Unless you have opted-out through your device settings, the Mobile Application 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 Mobile Application to have access to your location data through your device settings. We do not control your location information preferences from within the Mobile Application. 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 Mobile Application?

Yes. Subject to applicable law and regulation, we may share information collected by the Mobile Application with third parties only in the ways that are described in this privacy statement.

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.

How is information collected by the Mobile Application used?

We use the information collected about you and your device to maintain and provide you with the Mobile Banking 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 Mobile Banking Service.

What are my opt-out rights?

You may at any time opt-out from allowing the Mobile Application’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 Mobile Application from performing location-based services, such as finding nearby ATMs and branches.

You may also refrain from using Mobile Application features that collect specific types of information.

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

How does the Mobile Application respond to 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.

The Mobile Application does not operate within your web browser and does not receive or respond to DNT signals. Whether you have turned on DNT or not, the Mobile Application 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 Mobile Application to collect PII about your online activities over time and across third party websites.

Data Retention

Our operational systems will store user-provided data for as long as you use the related feature of the Mobile Application, unless you choose to delete it. Please note that some or all of the user-provided data may be required in order for the Mobile Application 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.

Children

We do not use the Mobile Application to knowingly collect data from or market to children under the age of 13. If a child under 13 has provided us with personal information without parental or guardian consent, the parent or guardian may contact us at 1-800-273-1057. We will delete such information from our files within a reasonable time and unsubscribe the child from any promotional contact opportunities.

Security

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 Mobile Application. 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.

Changes

This Privacy Policy may be updated from time to time, as new versions of the Mobile Application are released and the Mobile Banking Services is modified or expanded. The Privacy Policy link within the Mobile Application will direct your device to the most recent version of this Privacy Policy. You may also visit http://www.bbvacompass.com/compass/policy/privacy.jsp to view the current copy of this Privacy Policy. We will notify you electronically of any material changes to our Privacy Policy in accordance with the BBVA Compass Mobile Banking Terms of Use. Your use of the Mobile Application following an update to this Privacy Policy means that you accept the updated Policy.

Your Consent

By using the Mobile Application, 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 Mobile Banking Service to you.

Contact us - If you have any questions regarding privacy while using the Mobile Application, or have questions about our practices, please contact us at 1-800-273-1057.