Privacy Policy

Consumer Privacy Policy

Our Privacy Pledge…
Protecting your privacy and safeguarding the information you provide us is a priority at Rabo AgriFinance.

 

I. Our Privacy Statement
At Rabo AgriFinance LLC and applicable affiliates  (collectively referred to herein as ‘Rabobank’), protecting your privacy and safeguarding the personal information  or other information that you provide us is a priority.  Whether you are a website visitor, loan applicant and/or consumer of our services, we respect your privacy and your trust is important to us. 

II. Our Privacy Policy
The following sets forth Rabobank’s Privacy Policy (“Policy”) applicable to the collection and processing  of personal or other information that share with us or when you visit our website:  www.raboag.com, or that you provide to Rabobank as part of a product or service that you request and we provide to you.    
It describes the personal and other information that Rabobank may collect, process, store, use and/or disclose, as well as the safeguard measures that we have in place to protect it.  The Policy also applies to the operations performed on behalf of Rabobank by our affiliates and/or external service providers that may be involved in the collection and/or processing of your personal or other information.

III. Your Personal and Other Information We Collect and the Purpose
Rabobank collects personal and other information that you voluntary provide in order to enable us to deliver the products or services that you have requested, which may come from the following sources:

a) Information we receive directly from you, including but not limited to information on applications or other forms;
b) Information about your transactions with us;
c) Information about your transactions with our affiliates; and
d) Information from a consumer reporting agency.

Additionally, the following are the general categories of personal information that we may collect:
a) Name(s)
b) USPS Mailing Address and Physical Address
c) Location Device – Internet Provider (IP) Address information: city, region, country internet service provider
d) Email address
e) Account Name
f) Government-Issued (Federal or State) Identification and Numbers
g) Phone number(s)
h) Banking Information
i) Credit Information
j) Financial and Identity Verification Information from Credit Reporting Agencies 
k) Loan Details/Business Needs and Operational Information
l) Business Entity Information
m) Financial Information
n) Military Status
o) Citizenship
p) Marital Status
q) Date of Birth
r) Personal Information from U.S. and Foreign Government Registries, as necessary
i. In order to satisfy our legal and regulatory obligations under anti-money laundering, terrorist financing or similar laws.
s) Browser type and/or operating system
t) User login/authentication data
u) Functionality settings that recall user preferences 

IV. Processing Your Personal Information
We process personal and other information of individuals or of entities (“Subject Entity) with whom we have, wish to have, or previously had, a direct or indirect relationship.  We also provide personal and other information to third parties, to allow us to provide products or services which you seek.  This may include:

a) clients and their representatives;
b) persons who show an interest in our products and services; or
c) persons who are associated with a business or organization with which we have, wish to have, or previously had, a relationship. Please note: if your business or organization provides us with personal information of employees, you are under the obligation to inform your employees thereof. You may provide your employees with this privacy policy so that they may see how Rabobank treats their personal information.

We require personal and other information to understand your interests and business needs, and in order to provide you with a better consumer experience related to the products and/or services that you seek. In particular, we process personal and other information to:
a) enable you to select the business interest and financial needs you seek;
b) enable you to engage with business partners that help serve your mission and business goals;
c) potentially improve our products and services or inform you about new services or other information that we believe you may find applicable; or, 
d) enable you to register with our website and subsequently, to receive an email notification that confirms the user’s website account was successfully established.

The activities in which we may require personal or other information from an individual or from an individual associated with a Subject Entity to perform a service or deliver a product include, but are not limited to: 
a) responding to an inquiry for the purposes of describing, marketing or selling goods and/or services to you.
b) entering into a relationship to become a Rabobank client, or if you, as an individual are associated with an entity that wishes to purchase a new product or a new service.  This may include carrying out an investigation to review whether we can accept the individual or Subject Entity as a client or whether we can provide a loan.
c) receiving a loan or business credit application submitted by an individual.
d) enabling the establishment of loan account completed by an individual.
e) providing access to an account established by an individual.
f) maintaining a relationship with you and to execute payment orders received.
g) concluding and executing agreements with suppliers and corporate clients in order to ascertain for example, that you are authorized to represent your company or to grant you access to our offices.
h) developing and improving of our products and services.
i) engaging in promotional and marketing activities that may be of interest to you, or to better anticipate your needs.
j) compiling statistics for analysis of visits and use of our websites.
k) complying with legal requirements or the lawful basis of a contract or to protect your personal interests or that of our organization (such as combating or investigating fraud).
l) complying with national and international laws and regulations for example, to initiate a (further) investigation if you have certain assets, collaboration with other parties that may pose a risk, or in the event of an unusual transaction in your account or to disclose data about you to a government or regulatory body inside or outside of the United States. 
m) Archiving data only for the potential use in legal proceedings, or for historic, statistical or scientific purposes. 
We have collected information such as that described above in the last twelve months.   We may disclose personal information our affiliates insofar as reasonably necessary for the purposes, and on the legal bases, set out in this notice to include the processing and delivery of a product or service.  We may also disclose your personal information to third parties that are not related by common ownership or control, such as service providers, credit bureaus and other nonaffiliated third parties when required and permitted by law.  We do not collect more personal information than is necessary for the purposes set forth above. 

We require that you do not supply any other person's personal information to us, unless we prompt you to do so.

V. Exercising Your Individual Rights 

Subject to Rabobank’s verification of a consumer’s identity per statutory laws and regulations, you/consumers may exercise any one of the following consumer right(s) with Rabobank listed below. When communicating your request, please select one of the following 2 options:

Option 1
Submit your request to the following email address: (RaboPrivacyOffice@rabobank.com)
– OR – 
Option 2
Submit your request by using the following toll free phone number to reach a Customer Connect Service Representative to assist you: (855-722-7766)

In order for Rabobank to respond to a request, you will be asked to provide, over the phone, personal information that will assist us in verifying your identity. This step is for your protection and to ensure Rabobank’s due diligence to demonstrate our commitment to preventing identify theft or fraudulent activities of individuals who may attempt to claim the identity of an individual for which they are not. Information which you might be asked to provide includes, but is not limited to, Tax ID information, address, date of birth, loan information such as account number, loan date, and transactional information.  If you authorize someone else, such as an authorized agent, to request information on your behalf, Rabobank will require that you provide evidence of this authorization, prior to executing any actions on your behalf.  Rabobank reserves the right to determine in its sole discretion, information/documentation that is appropriate to evidence a consumer’s authorization of an agent.  


1. Right to Know About Personal Information Collected, Disclosed or Sold

You have the right to know about the personal and other information which we collect, use, disclose and sell.  More specifically, you may request information regarding the following:

a) the categories of personal information that we have collected about you;
b) the categories of sources from which the personal information was collected;
c) the business purpose or commercial purpose for collecting the personal information; 
d) the categories of third parties with whom or which the personal information is disclosed; and,
e) the specific pieces of personal information we have collected about you.  

Rabobank is obligated to respond to no more than two right-to-access requests in a 12-month period. 
If you believe that your personal information has been processed incorrectly or incompletely, or if you believe that such processing was unnecessary, then you may file a request for editing, supplementation or removal of your personal information with the Rabobank using the one of the two methods and guidance provided earlier in this section titled “Exercising your Individual Rights”.

2. Right to Data Deletion

With certain exceptions, you have the right to request deletion of your personal information which we maintain.  A verifiable consumer request, as described above, for deletion of any personal information collected will be honored by Rabobank, insofar that the request does not conflict with legal and regulatory data retention and record keeping requirements to which Rabobank must adhere.  Rabobank will also request and make reasonable efforts to ensure that our service providers delete your personal information as well.
The deletion right does not apply when the business needs the personal information for any of the following:

a) to complete the transaction or provide a good or service requested by the consumer for which the business collected the personal information or otherwise perform a contract between the business and the consumer;
b) to detect or prevent security incidents or illegal activity;
c) to identify and correct errors that impair existing functionality;
d) for the exercise of a legal right or to ensure another consumer can exercise his or her legal right;
e) to comply with the California Electronic Communications Privacy Act;
f) to engage in public or peer-reviewed scientific, historical, or statistical research in the public interest if deletion of the personal information is likely to make the research impossible or seriously impair it;
g) solely for internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business;
h) to comply with a legal obligation; or
i) for lawful internal uses that are compatible with the context in which the consumer provided the personal information to the business.

3. Right to Opt-Out of Personal Information Sold

An individual has the right instruct a business that sells personal information not to sell the consumer’s personal information – also known as the Right to Opt-Out. Once a consumer opts out, the business must honor the opt-out request for at least 12 months, but subsequently may sell the consumer’s personal information if the consumer provides his or her “express authorization”.  At Rabobank, we do not sell your personal information to any person or to third parties.  This also includes the sale of information of minors.    

4. Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights (Equal Service and Price)

You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the California Consumer Privacy Act.  However, Rabobank is permitted to offer different products or services if the difference is reasonably related to the value of the consumer’s data.  At this time, Rabobank does not offer different products or services based upon the value of a consumer’s data.  Should our data practices change, we will update this Policy as provided later in this section titled “Changes to this Privacy Policy”.

5. Right to Notification of Personal Information to be Collected

When Rabobank collects a consumer’s personal or other information, we must disclose through a notice at or before the time of collection:

a) a list of categories of your personal information collected.
b) for the categories of personal information collected, the business or commercial purpose for which it is to be used.
c) if the business sells personal information, a link to opt-out of the sale of information, or a statement that no sale or disclosure was made; and
d) a link to this privacy policy.  

As noted above, Rabobank does not sell any personal information to any person or to third parties.

6. Right to Data Portability

As part of your options for receiving a copy of the specific personal information we retain about you, it includes an electronic format that is in a readily usable format.  

7. Opt-Out of Sharing Your Personal Information

We may also disclose the following information provided below to our affiliates that are financial service providers:

Transaction and experience information from our account records, such as:

Name
Address
Types of accounts you hold

Personal information we receive from you on applications or other forms, such as:

Social security number
Assets and liabilities
Income

Our affiliates may use this information to make marketing solicitations to you about their products and services. You may opt-out of the disclosure to our affiliates of personal information, excluding information required for our transactions and experiences with you (i.e. information we receive from you on applications or other forms). You may also elect not to receive marketing solicitations from our affiliates. Please note that if you make this election, we will still call you and send you mail in order to service your existing relationship with us or to provide account related information (and when doing so, our mailings may include pre-printed marketing materials).   If you opt out, it is effective within thirty days of receipt and will remain effective until you tell us to change your choice.  When you are no longer a customer, we continue to share your information as disclosed in this notice, unless otherwise advised by an opt-out action you have exercised.  You may contact us using option 1 or option 2 to request to opt-out status as describe above in Section V Exercising Your Individual Rights. 

VI. Data Retention of Your Personal Information
Our data retention policies and procedure are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.  Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. 

In some cases it is not possible for us to specify in advance the periods for which your personal information will be retained. Notwithstanding the other provisions of this Policy, we may retain your personal information where such retention is necessary for compliance with a legal obligation and in accordance with banking regulations to which we are subject, or in order to protect your vital interests or the vital interests of another person.

VII. Security and Safeguarding Personal Information
We are committed to ensuring that your information is secure.  In order to prevent unauthorized access or disclosure, we have put in place the appropriate physical, administrative and technical controls and procedures in place in order to safeguard and secure the information that you provide to Rabobank online.  Rabobank uses many advanced security measures to protect you while you are using our websites.  Below are just a few of the measures we use: 

Unique login IDs and passwords - You select your own login ID and password. 
Firewalls - Blocks unauthorized access to the Rabobank computer system, where your information is kept. 
128-bit Encryption - Scrambles information being transmitted between Rabobank and online banking into a code that is virtually impossible for outsiders to decipher. 
Monitoring - We monitor for unusual activity on your accounts. However, this is not fool-proof and does not take the place of you regularly monitoring your accounts.

VIII. Technology
We protect our computer system with backup files, virus detection software, firewalls, and other computer software and hardware. By taking these measures to protect the integrity of our computer system, we are also helping ensure the safety of your personal information.

IX. Limited Employee Access
Access to account information is restricted to only those employees who are required to have access to it in order to assist you. Rabobank employees are required to keep customer information confidential, and are subject to disciplinary action or termination if they fail to do so.

X. Physical Security
Strict policies and procedures are used at all Rabobank locations to protect the physical security of you, our staff and any sensitive information. These procedures are regularly reviewed and updated to account for changing threats and ensure compliance with federal laws.

XI. Confidentiality and Security
We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with Federal regulations to guard such information. For additional information, please visit the website at: www.raboag.com

XII. How We Use Cookies
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. 
 
Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Rabobank or our third-party service providers may place cookies on your hard drive to keep track of your preferences and to recognize returning visitors. When you return to one of our websites, your browser gives this data back to the server to improve your experience while using the site(s). Cookies allow us to:

Offer you more relevant products and services;
Collect technical and navigational information, such as browser type, time spent on our website(s) and pages visited;
Monitor viewing and responses to advertisements.
If you have an account with us and access the account(s) online, we will maintain information about your visits. These per-session cookies are for online banking functions and system security. When you close your online banking session, the per-session cookie is deleted. We do not use cookies to record information that will enable anyone to contact you via telephone, e-mail, or regular mail.
Cookies and other technologies provide us the capability to monitor the use of our website(s) so we can continually improve the design and functionality of our websites. Cookies we use do not contain or capture unencrypted personal information. If you choose not to accept cookies from our website(s), then you may not be able to access and use all or part of the website(s) or benefit from the information and services offered. By not choosing to accept cookies, you will still receive advertisements on our website(s), but they will not be tailored to your interests or needs.

XIII. Changes to this Privacy Policy
We may choose to make changes to this Policy at any time. If we decide to change this Policy, we will post the changes on one or more our websites and/or other places where we deem appropriate. We may, but are not obligated, to send you an email or other notification of such change; but you should review this Policy from time to time for significant changes that may affect you. If you agree to the changes, you do not need to do anything. But if you do not agree to the changes, you must discontinue use of our sites and services. If you continue to use our sites and services after the effective date of any change, you are deemed to have accepted the change.

XIV. Exceptions
Except as stated below, we will use information in accordance with this Policy as it may be changed from time to time as set forth above. Notwithstanding anything else in this Policy to the contrary, we may collect personal information and use and disclose such information in ways other than those described above if we are required to do so by any applicable law or if we deem it advisable and lawful in the course of (i) assisting law enforcement activities, or (ii) investigating and resolving disputes between users; and (iii) protecting our site(s) or other property, including, without limitation, investigating, preventing or taking action with respect to illegal activities, suspected fraud, situations involving the potential safety of any person, violations of Rabobank’s terms of use, or as otherwise required by law. Without limiting the foregoing, we reserve the right to use and disclose any information that you provide to us if we deem it advisable in the prosecution or defense of any litigation involving your use of Rabobank’s website.

XV. Contact Information
If you have questions regarding this Policy, you may contact us using the following information:

Rabobank
P.O. Box 411995
Chesterfield, Missouri 63017
Attn: Customer Connect
(855) 722-7766
RaboPrivacyOffice@rabobank.com

You may also contact our Regional Privacy Officer as identified below:

Rabobank
P.O. Box 411995
Chesterfield, Missouri 63017
Attn: Regional Privacy Officer
(855) 722-7766
RaboPrivacyOffice@rabobank.com

XVI. Policy Effective Date


January 1, 2020

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