The California Consumer Privacy Act of 2018 (“CCPA”) (Cal. Civ. Code §1798.100 et seq.) grants certain privacy rights to consumer who reside in California. These rights, along with how California consumer residents may contact us to exercise their rights, are outlined in this disclosure. For purposes of this disclosure, “Park” consists of Park National Bank, its parent company Park National Corporation, and other companies held by Park National Corporation, including Scope Leasing, LLC (dba Scope Aircraft Finance) and SE Property Holdings.
Because Park is a financial institution subject to the Gramm-Leach-Bliley Act (“GLBA”) (15 U.S. Code §6801), part of the information Park collects, uses, and shares from California consumers is exempted from coverage under the CCPA. For example, the CCPA does not apply to personal information collected or disclosed in connection with financial products or services that are used primarily for personal, family, or household purposes. For more information about Park’s general privacy policies, which apply to all consumers, please read our privacy policy or ask a Park representative for a current copy of our Privacy Notice.
Collection, Disclosure, and Purposes of Personal Information
Financial institutions routinely collect personal information necessary to offer and provide financial products and services, as well as permitted by federal, state, and local law. Relevant to its use herein, the term ‘personal information’ means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household of a California resident.
The categories of personal information Park may collect from or about you include:
- Identifiers, such as name and government-issued identifier (e.g., Social Security number)
- Contact information, such as address or email address, and financial information, such as credit reporting information or credit score
- Characteristics of protected classifications such as sex, race, national origin, military or veteran status, and marital status
- Commercial information, such as transaction information and purchase history
- Internet or network activity information, such as browsing history and interactions with our website
- Geolocation data, such as device location and Internet Protocol address
- Audio, electronic, visual and similar information, such as call and video recordings
- Professional or employment-related information, such as work history and prior employer
- Inferences we use to build a profile about you; includes profiles, preferences, and behaviors drawn from collection and analytics of the other categories of personal information collected.
The categories of sources from which Park may collect personal information include:
- An individual or the individual’s representative
- Service providers, consumer data resellers, credit bureaus, and other third parties
- Public record sources, including Federal, State, local government bureaus, agencies, and departments
- Website, mobile application, and social media sites and applications, including through use of cookies
- Transactional counterparties and referral sources, such as other professionals
- Client directed third parties or institutions representing a client or prospect
- Corporate clients, about individuals associated with the clients such as an employee or board member
The categories of third parties to whom Park may disclose personal information include:
- Third parties that provide operational services such as payment processing, banking, communication and information technology infrastructure and storage, legal or tax expertise, auditors, and that enable customers to conduct transactions and review accounts and account information online and through mobile devices
- Third parties that provide marketing services, such as to promote Park and its financial services and products to customers and prospective customers, including through website hosting, data analysis, and to support other marketing and marketing research activities
- Third parties that provide security services, including physical, electronic, and fraud related services
- Third parties that provide employment and employee benefit services
- Government bureaus, agencies, and departments as required by laws and regulations
The purposes for which Park collects personal information include:
- Operational purposes, such as to offer and provide financial products and services, process and fulfill payments and other transactions, and to service existing or perspective accounts, products, and services
- Marketing and data analytics, such as for advertising and marketing initiatives and services, to facilitate these communications to you, and to evaluate potential product and service offerings to you and others
- Research, including conducting market or customer satisfaction research, engaging with you for the purposes of obtaining your views on our products and services, identifying issues with existing products and services, and planning improvements to existing products and services
- Internet and web interactions, such as to facilitate your view of our website, communications, and advertising focused to a particular market or market segment
- Information technology functions, such as to manage our communications systems, operation of information technology security, and information technology security audits
- Security, including for physical security of our premises (records of visits to our premises and CCTV recordings), electronic security (login records and access details, where you access our electronic systems), and fraud prevention (electronic resources to detect, prevent, and investigate fraud)
- Employment purposes, including to collect, disclose, and store information necessary for job application and recruitment purposes, employment, termination, and benefits.
- Legal and regulatory obligations, including to collect, store, and disclose information to comply with statutory and regulatory requirements
Sale of Personal Information
Park does not currently sell, and in the past 12 months, Park has not sold personal information subject to the CCPA, including personal information of minors under the age of 16. In the future, if Park seeks to sell the personal information of California residents, it will provide notice and opportunity to opt-out. By default, California residents Park knows to be under the age of 16 will be opted out of the sale of their personal information.
Your Rights Under California Consumer Privacy Act
If you are a California resident, you have the right to:
- Request that Park disclose to you, free of a charge, the following information covering the 12 months preceding your request:
- Categories of personal information about you that we have collected
- Categories of sources from which the personal information was collected
- The purpose for which personal information about you was collected
- Categories of third parties to whom we disclosed personal information about you, the categories of personal information that was disclosed (if applicable), and the purpose for disclosing the personal information about you
- Specific pieces of personal information we collected about you
- Request we delete personal information we collected from you, unless the CCPA recognizes an exception
- Be free from unlawful discrimination for exercising your rights under CCPA
How to Exercise Your Rights
If you are a California resident, you may submit a request by:
- Completing an online form
- Calling Customer Care Center at 888-474-7275
- Writing to us at the following address:
Park National Bank
PO Box 3500
Newark, Ohio 43058
Attn: Compliance
Upon the receipt of a verifiable request, Park will disclose and deliver the requested information, either electronically or by U.S. mail, no later than 45 days from the receipt of your request, unless additional time is required. Park will notify you if additional time is required to complete your request. The information provided will cover the 12 month period preceding the date of your request. If you submit a request on behalf of another person, we will require proof of authorization and verification of identity directly from the person for whom you are submitting a request.
In some instances, we may not be able to honor your request. For example, we will not honor a request if we are unable to verify your identity or are unable to verify that you have the authority to make a request on the behalf of another person. Additionally, we will not honor your request where an exception applies, such as when the personal information that we maintain is not subject to the CCPA’s access or deletion rights. We will advise you if we are not able to honor your request and the reason(s) why. We will not honor request from individuals who are not residents of California.
Park is not required to honor a request for information more than twice in a 12 month period.
Changes to this Disclosure
We may change this disclosure from time to time. When we do, we will let you know by appropriate means, such as by posting the revised disclosure on our website with a new “Last Revised” date. Any changes to this disclosure will become effective when posted unless indicated otherwise.
Last Revised June 2020