FundsXpress Financial Network, Inc. ("FundsXpress")
takes great pride in enabling its financial institution clients
to provide secure online financial transactions. We enjoy
a high level of trust and confidence from our clients and
their customers, and we strive daily to justify and maintain
that trust and confidence.
The employees of FundsXpress use the Internet everyday, and
we too are sensitive to the privacy of our personal information.
Since we are Internet users, like you, it’s only natural
that we would assume that you might feel the same way about
the privacy of your personal information. With that in mind,
we have developed the following Privacy Policy to describe
the type information that we collect on the Internet. This
Policy also explains how FundsXpress uses and protects this
information.
Our Privacy Policy is directed to FundsXpress financial institution
clients and Website visitors. Section (1) describes our policy
for visitors to the FundsXpress Website and Section (2) describes
our policy for protecting the consumer information of our
clients (the end-users of FundsXpress products). These policies
are in addition to the extensive security measures that FundsXpress
takes to protect end-user financial transactions on the Internet.
Section (4) includes a discussion of these security measures.
Visitors to the FundsXpress Website
FundsXpress collects general information on its Website visitors
simply for statistical and security purposes. Such information
may include:
- The Internet address (referral site) which brought you
to our Website;
- The date and time you access our site;
- The name and version of your Web browser;
- The Internet service provider you used when you accessed
our site;
- Your Internet Protocol (IP) address; and
- The pages visited in our Website.
FundsXpress uses a cookie to collect this general information
on all Website visitors. We may use this information in a
consolidated, non-personally identifiable, format to assist
us in offering the services and features that are of particular
interest to our clients. We may also use this information
to monitor the security and performance of our site.
You may elect to provide us with more specific or personal
information, such as when you give us feedback or send us
an email requesting additional information from our sales
department. If you provide personal information to us, it
is only used internally and in furtherance of the purpose
for which it was provided. Please note that all visitors and
clients also have the option of contacting us by telephone.
FundsXpress provides a “Client Site” to provide
additional information and support to our financial institution
clients. For security purposes, this section of our Website
requires authentication with an Access ID and Passcode.
FundsXpress does not share or sell information collected
from Website visitors. Also, FundsXpress will not send unsolicited
email (spam) to our Website visitors.
FundsXpress reserves the right to monitor and make records
of transactions and interchanges made over its networks, this
includes failed log-on attempts in the "Client Site".
You will not necessarily be told (unless the notification
is required by law) that a transaction or interchange in which
you are participating is being monitored or recorded. Monitoring
and recording transactions or interchanges may be initiated,
for example, if we suspect a possible breach in security or
some other problem that would make it appropriate to monitor
or maintain these records. We do not use this information
for any improper purposes or distribute it to third parties,
except as required or permitted by law.
Financial Institution Customer Information (End-Users)
As an Application Service Provider (ASP), non-public personal
information of end-users may be housed or transmitted through
our data center in order to provide our clients financial
services such as: fxeBankingSM, fxBusiness BankingSM, fxLendingSM,
fxPortanaSM, and fxFinance CenterSM.
End-users have high expectations for the confidentiality
and privacy of their personal information. We recognize these
expectations and strive to ensure that we protect the confidentiality
of this information to the same extent that our client financial
institutions must do.
The information provided below describes the practices that
FundsXpress takes to safeguard the personal and confidential
information of its end-users.
Collection and Use of End-User Information
FundsXpress only collects and maintains information on the
end-users of FundXpress’ services in order to be responsive
to user needs, provide contracted services to our clients,
manage our lawful business, and maintain appropriate records.
Generally speaking the information collected falls into two
broad categories: (1) Information that is generated when a
user contacts FundsXpress electronically, simply by virtue
of the manner in which Internet communications are initiated
and handled; and (2) Information that is expressly or incidentally
created in connection with a transaction or providing a service.
An example of the information collected under (1) may include
the user’s IP address and referral Website, which would
be logged when a consumer visits a financial institution Website
hosted by FundsXpress or when a consumer or end-user visits
the fx eBankingSM gateway page. An example of the
information collected under (2) might include specific customer
account information, such as an account number, account balance,
access identification information, account statements, and/or
bill payment activity.
FundsXpress may extract from and compile non-personally identifiable
end-user information collected via (1) and/or (2) in a consolidated
format for statistical and research purposes. Such information
might detail the number of bill pay customers, the most typical
payees, the number of registered users on fxPortanaSM and/or
fxFinance CenterSM, and the time users most frequently use
our services. With respect to former end-users we only retain
this information as necessary to meet our legal obligations
and record retention requirements.
Similar to our policy for Website visitors, FundsXpress reserves
the right to collect and monitor all transactions on our networks
and applications. End-users will not necessarily be told (unless
the notification is required by law) that a transaction or
interchange in which they are participating is being monitored
or recorded. Monitoring and recording transactions or interchanges
may be initiated, for example, if we suspected a possible
breach in security or some other problem that would make it
appropriate to monitor or maintain these records. FundsXpress
also reserves the right to disclose such information to regulatory
and governmental authorities if required.
Third Party Disclosure
FundsXpress understands that end users of FundsXpress products
expect that their financial information and transactions will
be handled in a confidential manner. We do not use confidential
consumer information for any improper purposes or distribute
it to third parties, except as required or permitted by law,
or as necessary to provide a contracted service.
It is the policy of FundsXpress that non-public, personally
identifiable consumer information may only be disclosed to
third parties when:
- The user, either directly or through our client financial
institution, is believed to have requested or authorized
the disclosure;
- It is necessary to administer the service or complete
a transaction, such as bill pay; or
- It is required or allowed by law (such as, but not limited
to, responding to a subpoena or court order, reporting information
to legal authorities, regulatory agencies, or other appropriate
investigators in connection with a legal investigation or
similar matter).
FundsXpress contractually requires its third party service providers
to protect the confidentiality of the non-public consumer information
received from FundsXpress. Third party service providers are
only permitted to use such information for the purpose for which
it was provided, such as for bill payments.
FundsXpress does provide marketing services and support to
its clients in order to promote online financial products
to end-users. We may provide aggregate and/or consolidated
end-user information to our clients to assist in marketing
financial institution products and services. This service
is part of the financial services package that we offer each
client. Our marketing efforts are coordinated with each client
financial institution and because of this, our clients are
aware of and involved with any joint marketing ventures. FundsXpress
does not disclose any nonpublic, personally identifiable end-user
information with any third party advertising firms.
Security Features
End-User Security
FundsXpress utilizes a comprehensive security strategy to
protect user accounts and transactions conducted over the
Internet. We use the Secure Socket Layer (SSL) encryption
technology for all communications with the end-user. The communication
is encrypted every time an end-user enters an access ID, passcode,
or personal information during an online application or registration
process. All financial transactions conducted by end-users
are also SSL encrypted. FundsXpress servers use digital certificates
to assure the end-user that they are actually talking to FundsXpress
servers instead of someone pretending to be FundsXpress.
Internal Security
The architectural design of the system, the data center,
policies, procedures, staff, hardware, and software selected
for the FundsXpress systems are chosen with security in mind
so that all transactions and customer information will be
safe and secure. Internal security features include authentication
software, encryption, VPN technologies, firewalls, anti-virus
protection, network and host intrusion detection devices.
The secure FundsXpress data center is designed to protect
our equipment, software, and confidential information assets.
FundsXpress has established policies and access controls which
restrict employee access to sensitive and confidential information
only as necessary for their job responsibilities. FundsXpress
performs background checks on its employees and requires all
employees to sign confidentiality agreements.
FundsXpress maintains physical, electronic, and procedural
safeguards that comply with federal standards to guard customer
information. Technology relating to Internet security is evolving
rapidly, as are ways to circumvent security. Thus FundsXpress
continually strives to stay abreast of developments in Internet
security to thwart any potential threats to our security.
FundsXpress clients are encouraged to contact the FundsXpress
customer service department immediately if an unauthorized
activity is suspected. It is the policy of FundsXpress to
investigate all such matters promptly and report to the proper
authorities.
A Word About Cookies
A cookie is a very small text file sent by a Web server and
stored in your computer’s or browser's memory so that
it can be read back later. Cookies are a basic way for a server
to identify the computer you happen to be using at the time,
not you personally. Cookies are used for many things from
personalizing start up pages to facilitating online purchases.
Cookies do perform a very important function when you engage
in secure Internet banking.
FundsXpress uses cookies in its products for security, statistics,
and enhanced functionality. For example, with fxeBankingSM,
we use an encrypted cookie to identify the end-user’s
computer while they are logged on. This cookie enables us
to process multiple transactions during the session without
having to provide an access ID and passcode for each individual
transaction. Users must accept this cookie to use fxeBankingSM.
When the user logs off, or after ten minutes of inactivity,
the cookie is no longer accepted and must be renewed by requiring
the passcode to be reentered. A new cookie is used for each
session. That way, no one can use the prior cookie to access
the user’s account.
fxPortanaSM cookies are also used for security purposes and
to collect general statistical information on all visitors.
These cookies enable registered users to customize certain
features, such as their stock portfolio and local weather.
They also enable the user to bypass the login process each
time they revisit. These cookies only contain a unique user
identification number and do not contain or collect any personally
identifiable information.
When FundsXpress hosts financial institution Websites, we
may also use a cookie to collect the same type of general
information that we collect on this Website. This information
is collected for security and statistical purposes.
We do not disclose any information collected through cookies
with third parties. However, we may provide consolidated,
non-personally identifiable information to our clients, such
as the most frequently accessed pages within a Website or
the most frequently used browsers.
Links
The FundsXpress Website may have links to other third party
sites. These are offered as a courtesy and a convenience to
our Website visitors and clients. FundsXpress assumes no responsibility
for the content, reliability, safety, security, or privacy
practices of any such site or any transactions with respect
thereto. If you have questions or concerns about any other
site’s policy regarding these matters, you should contact
that site or its sponsor.
Amendments and changes
FundsXpress reserves the right to amend or change this policy
at anytime. The most current version of this policy will always
be posted on our Website. The effective date will always be
clearly displayed. This policy is for our Internet audience
and our clients and does not constitute a contract nor does
it modify or amend any agreement we have with our clients.
The examples provided within this policy are not exclusive.
Effective: July 1, 2004
FundsXpress subsidiaries
FundsXpress Financial Network, Inc., a Texas Corporation,
is an operating subsidiary of FundsXpress, Inc., a Delaware
Corporation.
Questions
If you have any questions about this policy, please contact
our customer support staff at:
1.800.419.8804
FundsXpress Financial Network, Inc.
11950 Jollyville Rd.
Austin, Texas 78759-2309
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