California Consumer Privacy Policy

This Privacy Policy for California Residents supplements the information contained in our Consumer Privacy Policy and applies solely to those on whom First Electronic Bank collects information and who reside in the State of California (“consumer(s)” or “you”). This policy describes the types of information First Electronic Bank (“FEB” or “we”) may collect about you and FEB’s practices for collecting, using, maintaining, protecting, and disclosing that information.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.

Information We Collect

 FEB collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, FEB has collected the following categories of personal information from its consumers within the last twelve (12) months:

A. IdentifiersReal name, postal address, IP address, email address, account name, SSN, driver’s license number, passport number
B. Personal Information listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e))Name, signature, SSN, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
C. Protected Classification Characteristics under California or Federal LawAge (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial InformationRecords of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.
E. Professional or Employment-Related InformationCurrent or past job history, income, performance evaluations

We obtain the categories of personal information listed above from the following sources:

• Directly from you. For example, when you submit a loan application in connection with loans we make or arrange.
• From third parties, for example, our business partners.

We will not collect additional categories of personal information without first providing you notice.

For purposes of this policy, personal information does not include:

• Publicly available information from government records
• Deidentified consumer information

Children Under the Age of 16

FEB does not knowingly collect personal information from children under 16. If you are under 16, do not provide any information to us through this or any other website. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at the email address below.

How We Use Your Information

We use information that we collect about you, or that you provide to FEB:

• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve FEB’s responses
• To respond to law enforcement requests and, as required by applicable law, courts orders or governmental regulations
• To audit FEB’s related current interactions with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
• To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
• To debug in order to identify and repair errors that impair existing intended functionality
• For short-term, transient uses, but your personal information will not be disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction
• To perform services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services
• To undertake internal research for technological development and demonstration
• To undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by FEB, and to improve, upgrade, or enhance FEB’s services or devices
• For any commercial purposes, including any purpose to advance your commercial or economic interests, such as by inducing you to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.

We will not use the personal information we collect for materially different, unrelated, or incompatible purposes without first providing you notice.

How We Disclose Your Information

We may disclose your personal information to a third party for a business purpose. We share your personal information with the following categories of third parties:

• Service Providers such as consumer reporting agencies, non-CRA data vendors, and payment processors
• Unaffiliated Lenders who arrange consumer loans that are originated by us, and in some cases then service those loans

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose to the following categories of third parties:

Category AService Providers and Unaffiliated Lenders
Category BService Providers and Unaffiliated Lenders
Category CService Providers and Unaffiliated Lenders
Category DService Providers and Unaffiliated Lenders
Category EService Providers and Unaffiliated Lenders

Sale of Your Information

FEB does not sell your personal information.

Your Rights and Choices

Access to Information

You have the right to request that we disclose certain information to you about FEB’s collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose information to you, unless an exception applies. You may request any or all of the following:

• The categories of personal information we collected about you
• The categories of sources for the personal information we collected about you
• Our business or commercial purpose for collecting that personal information 
• The categories of third parties with whom we share that personal information
• Specific pieces of personal information we collected about you

Deletion of Information

You have the right to request that we delete any of your personal information that we collected and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from FEB’s records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction or provide a good or service you requested and for which we collected the personal information
• Take actions reasonably anticipated within the context of your ongoing business relationship with FEB or to otherwise perform FEB’s contract with you
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities
• Debut products to identify and repair errors that impair existing intended functionality
• Exercise our free speech rights, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with FEB
• Comply with any and all legal and regulatory obligations
• Make other internal and lawful uses of that information that are compatible within the context in which you provided it.

Exercising Your Rights and Choices

To exercise your rights as described above, please submit a verifiable consumer request to us by any communication method listed below:

Webform: CCPA Form

Toll Free: 1-888-816-2571             

Only you or someone legally authorized to act on your behalf may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access to your information twice within a 12-month period.

The verifiable request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe with sufficient detail what the request is to ensure we properly understand and can evaluate and respond to it.

We cannot respond to your requests if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  If you are making the request on behalf of someone else, you must provide:

• Written evidence that you are the authorized agent acting on behalf of the consumer
• Evidence of your own identity

You can submit such evidence before or at the time of submitting your verifiable request to the following email address:

Making a verifiable request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.


We will not discriminate against you for exercising any of your rights under this policy, including:

• Denying you goods or services
• Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
• Providing you a different level or quality of goods or services
• Suggesting that you receive a different price or rate for goods or services or a different level or quality of goods or services

Contact Information

Please do not hesitate to contact us by a communication method listed below if you have questions or comments about the ways in which we collect and use your personal information, as described in this policy.

                Phone:                  1-888-816-2571


                Postal Address: First Electronic Bank

                                                Attn: Privacy

                                                2150 S 1300 E, Suite 400

                                                Salt Lake City, UT 84106

To exercise your rights described herein and submit a verifiable request online, click here.