Privacy Policy
This Millennium Trust Company, LLC (“Millennium Trust” or “we”, “us”, or “our”) Privacy Policy (the “Privacy Policy”) explains what personal information we collect when you interact with us online, including via our websites, platforms, portals, applications or similar (collectively, “Online Services”), how we collect, use, and protect it, and why, in certain cases, we may share it with select third parties. This Privacy Policy also explains your rights in relation to your personal information, including your sharing and use choices.
This Privacy Policy was last updated on January 1, 2022 and may be amended from time to time.
What types of personal information are collected?
The types of personal information we may collect and use will depend on how you interact with us. This information can include:
- Personal identifiers, such as Social Security number, driver’s license, date of birth and other personal information necessary to verify your identity, and access authorization information, such as username, passcode and security questions and answers
- Information you provide on applications or other forms in order to receive our products and services, such as banking information and demographic information
- Account-related and transaction data, such as account number, balance and transactions and information about beneficiaries
- Recordings and transcripts of customer service calls and communications
- Contact information you provide, such as name, email address, and telephone number(s) in order to receive transactional, product and marketing information from us
- Device data, such as device type, web browser type and version, operating system type and version, internet protocol address, mobile network information, general location (e.g., city, state, or country), cookie IDs, device IDs, mobile advertising IDs, and likely connections among different browsers and devices that you use
- Online/mobile activity data, such as login data, search history, language, statistical identifiers, and information about how you use and interact with our Online Services or advertising
- Marketing data, such as marketing preferences, information about products or services we think you might like, and inferences based on your interactions with us or information we learn about you
- Communications data, such as your communication preferences and details or the content of your communications with us
If you disclose any information relating to other people to us when you visit or use our Online Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
We retain personal information for a period of time as required by laws and regulations and the necessary business purpose. We securely delete personal information as soon as legally permitted and in accordance with our internal retention policy.
How does Millennium Trust collect my personal information?
We collect information in a variety of contexts when you use our Online Services. For example, we may collect information:
- Directly from you. We collect information directly from you when you submit information to us, such as when you open an account or deposit money, pay fees or conduct transactions through your account, use your credit or debit card or provide banking information, register for a product or service or request information about a product or service, submit or upload information or input in any free-text boxes or forms through our Online Services, or complete a survey, sweepstakes or other promotion.
- Automatically when you use our Online Services. We, and others on our behalf, may collect the information described in this policy, such as device, online/mobile, or communications data, automatically when you interact with us online. This includes using cookies to collect information such as site visitorship and device data, user navigation and user behavior.
We may also collect information in other contexts, such as from our phone calls, chats and emails with you, or from third-party data sources for fraud prevention, identity verification, or marketing purposes.
How can personal information be used?
We use personal information that is collected about you for many purposes, such as:
- Providing, maintaining and servicing your accounts and delivering products and services, by verifying your identity, processing applications for products or services such as to open an account, and processing transactions
- Determining your financial interests and needs in order to recommend relevant products and services
- Authenticating your identity, preventing fraud, and keeping your information and financial transactions secure
- Advertising and marketing
- Optimizing your online and mobile experience and improving our products and services
- Performing analytics using aggregated and de-identified information regarding your use of our Online Services
- Complying with and enforcing applicable legal requirements, industry standards, contractual obligations and our policies
How does Millennium protect my personal information?
To protect your personal information from unauthorized access, use, or disclosure, we maintain technical and organizational security measures that comply with federal and state laws. These measures include computer safeguards, secured files and restricted access to buildings, as well as training employees to comply with privacy standards and policies which are designed to protect personal information.
When Can Information be Shared?
Below are reasons Millennium Trust may be permitted to share the personal information collected and whether you can limit this sharing:
| Reasons we can share your personal information | Does Millennium share? | Can you limit this sharing? |
|---|---|---|
| For our everyday business purposes – we share with service providers and other third parties, such as executing brokers and subcustodians, to process your transactions and maintain your account(s). We also share with regulators, courts, attorneys, and auditors and similar parties in response to court orders, legal or regulatory inquiries and legal investigations, or report to credit bureaus | Yes | No |
| For our marketing purposes – to offer our products and services to you, we share with service providers, including to analyze and improve our Online Services and to target our marketing | Yes | No |
| For joint marketing with other financial companies | No | We don't share |
| For our affiliates' everyday business purposes—information about your transactions and experiences | No | We don't share |
| For our affiliates' everyday business purposes—information about your creditworthiness | No | We don't share |
| For our affiliates to market to you | No | We don't share |
| For nonaffiliates to market to you | No | We don't share |
Why can't I limit all my sharing?
Federal law gives you the right to limit only
- Sharing for affiliates' everyday business purposes, such as sharing information about your creditworthiness
- Affiliates from using your information to market to you
- Sharing for nonaffiliates to market to you
DEFINITIONS
“Affiliates” means companies related by common ownership or control. They can be financial and nonfinancial companies.
“Nonaffiliates” means companies not related by common ownership or control. They can be financial and nonfinancial companies.
“Joint Marketing” means a formal agreement between nonaffiliated financial companies that together market financial products or services to you.
“Everyday Business Purposes” means the actions necessary by financial companies to run their business and manage client accounts, such as:
- Opening and servicing accounts, processing transactions and payments, and conducting mailings and auditing services
- Verifying your identify, detecting and preventing fraud, and protecting against security risks
- Responding to court orders and legal investigations or similar legal request
- Complying with legal, regulatory or contractual obligations and carrying out legal and business purposes
Notice To Consumers Who Are Residents Of California:
Submitting Requests Relating to Your Personal Information
Under the California Consumer Privacy Act of 2018, a consumer who is a resident of California has the following rights:
- Right to request that we delete personal information collected or maintained by us. Following receipt of a verifiable request to delete, we will let you know what, personal information, if any we are able to delete from our records
- Right to Opt-Out of the Sale and Sharing of Your Personal Information
- Right to Limit the Use of Your Sensitive Personal Information
- Right to Request More Information
- Right to Correct Inaccurate Information
Consumers who are residents of California may exercise the above rights by calling 800.258.7878 or following this link to request information.
Categories of Personal Information Collected
- Personal identifiers such as Social Security number, driver’s license, date of birth and other personal information necessary to verify your identity and access authorization information, such as username, passcode and security questions and answers, demographic information, contact information you provide, such as name, email address, and telephone number(s)
- Commercial information such as banking information, account-related and transaction data, such as account number, balance and transactions and information about beneficiaries, recordings and transcripts of customer service calls and communications, marketing preferences, information about products or services we think you might like, and inferences based on your interactions with us or information we learn about you, and communications data, such as your communication preferences and details or the content of your communications with us
- Internet or other electronic network activity information including device data, such as device type, web browser type and version, operating system type and version, internet protocol address, mobile network information, general location (e.g., city, state, or country), cookie IDs, device IDs, mobile advertising IDs, and likely connections among different browsers and devices that you use, login data, search history, language, statistical identifiers, and information about how you use and interact with our Online Services or advertising
Categories of Sources from which Personal Information Is Collected
- Directly from you
- Data analytics providers
- Operating systems and platforms
- Data brokers
- Cookies
Purpose for Collection or Use of Personal Information
- Providing, maintaining and servicing your accounts and delivering products and services, by verifying your identity, processing applications for products or services such as to open an account, and processing transactions
- Determining your financial interests and needs in order to recommend relevant products and services
- Authenticating your identity, preventing fraud, and keeping your information and financial transactions secure
- Advertising and marketing
- Optimizing your online and mobile experience and improving our products and services
- Performing analytics using aggregated and de-identified information regarding your use of our Online Services
- Complying with and enforcing applicable legal requirements, industry standards, contractual obligations and our policies
Categories of Third Parties to which Personal Information is Disclosed and Business Purpose for Disclosure
- Service providers, such as executing brokers and subcustodians, to process your transactions and maintain your account(s),
- Service providers to send materials either by mail or electronically
- Marketing service providers to analyze and improve our Online Services and to target our marketing
- Regulators, courts attorneys and auditors in response to court orders and legal investigations, or report to credit bureaus
Selling Personal Information
In addition to the business purposes listed above, we may disclose the following categories of personal information to third parties for the following purposes:
|
Category of Personal Information or Sensitive Personal Information |
Sold to Third Parties? |
Shared? |
Purposes for Selling / Sharing |
|
Personal identifiers such as Social Security number, driver’s license, date of birth and other personal information necessary to verify your identity |
No |
Yes |
Cross-context behavioral advertising |
|
Commercial information such as banking information, account-related and transaction data, such as account number |
No |
No |
N/A |
|
Internet or other electronic network activity information including device data, statistical identifiers, and information about how you use and interact with our Online Services or advertising |
No |
Yes |
Cross-context behavioral advertising |
Retention Policy:
We retain personal information for a period of time as required by laws and regulations and the necessary business purpose. We securely delete personal information as soon as legally permitted and in accordance with our internal retention policy.