HAWAII NATIONAL TRUST BANK PRIVACY POLICY

We are committed to protecting our members’ privacy. Hawaii National Trust Bank requires any information marked as mandatory for membership to either meet legal obligations or to enable us to perform our contract with you. Where you are not able to provide us with this information, we may not be able to open an account for you. Where we request further information about you not required for these reasons, we will ask you for your consent

How we use your personal information.

Hawaii National Trust Bank may process, transfer and/or share personal information in the following ways:

For legal obligations

• — to confirm your identity.
• — to perform activity for the prevention of money laundering and financial crime.
• — to carry out internal and external auditing.
• — to record basic information about you on a register of members

For performance of our contract with you

• — to deal with your account(s) or run any other services we provide to you;
• — to consider any applications made by you;
• — to carry out credit checks and to obtain and provide credit references
• — to undertake statistical analysis, to help evaluate the future needs of our members and to help manage our business

For legitimate interests

• — to conduct activity for the purposes of debt recovery

With your consent

• — to inform you of products and services by direct marketing (unless you specifically object to this), or to conduct market research.
• — By joining Hawaii National Trust Bank, you agree that we can send you statements, new terms & conditions, information about changes to the way your account(s) operate and notification of our Annual General Meeting.

Sharing your personal information

• — to third parties to help us confirm your identity to comply with anti-money laundering legislation
• — to credit reference agencies and debt recovery agents who may check the information against other databases – private and public – to which they have access
• — to any authorities if compelled to do so by law
• — to fraud prevention agencies to help prevent crime or where we suspect fraud
to any persons, including, but not limited to, insurers, who provide a service or benefits to you or for us in connection with your account(s); To our suppliers in order for them to provide services to us and/or to you on our behalf to anyone in connection with a reorganisation or merger of the credit union’s business other parties for the administration of marketing communications (We will NEVER sell or share your information to other companies for marketing of products and services not provided by Hawaii National Trust Bank or in connection with your credit union account)

Where we send your information

While countries in the Americas all ensure rigorous data protection laws, there are parts of the world that may not be quite so rigorous and do not provide the same quality of legal protection and rights when it comes to your personal information. Hawaii National Trust Bank does not directly send information to any country outside of the Americas, however, any party receiving personal data may also process, transfer and share it for the purposes set out above and in limited circumstances this may involve sending your information to countries where data protection laws do not provide the same level of data protection as the US.

Retaining your information

Hawaii National Trust Bank will need to hold your information for various lengths of time depending on what we use your data for. In many cases we will hold this information for a period of time after you have left Hawaii National Trust Bank

The right to object to processing

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the data is necessary for the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

Rights related to automatic processing

Hawaii National Trust Bank may use automated processes for processing members’ loan or membership applications to make sure that our decisions are quick, fair, efficient, and correct based on what we know. If Hawaii National Trust Bank uses fully automated decision processes then you have the right to have the decision reviewed by a member of staff, express their point of view, and obtain an explanation of the decision and challenge it

Right to withdraw consent

To the extent that the legal basis for our processing of your personal information is your consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.