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USA PATRIOT Act Customer Identification Program Notice

Important Information You Need to Know About Opening A New Account


To help the government fight the funding of terrorism and money laundering activities, federal law requires
financial institutions to obtain, verify, and record information that identifies each person who opens an account.

Types of Information You Will Need to Provide


When you open an account, we are required to collect information such as the following from you:
• Your name
• Date of birth
• Address
• Identification number
US Citizen: taxpayer identification number (Social Security Number)
Non-US Citizen: taxpayer identification number, passport number and country of issuance, alien
identification card number, or government-issued identification showing nationality, residence and a
photograph of you.

You may also need to show your driver’s license or other identifying documents.

If Your Identity Cannot Be Verified


We may not be able to open an account for you.

We thank you for your patience and hope that you will support the financial industry’s efforts to deny terrorists and
money launderers access to America’s financial system.

© 2021 Austin Capital Bank SSB All Rights Reserved.


WHAT DOES Credit Strong, a division of Austin Capital Rev. 09/2020
FACTS Bank SSB DO WITH YOUR PERSONAL
INFORMATION?
Why? Financial companies choose how they share your personal information.
Federal law gives consumers the right to limit some but not all sharing.
Federal law also requires us to tell you how we collect, share, and protect your
personal information. Please read this notice carefully to understand what we
do.
What? The types of personal information we collect and share depend on the product or
service you have with us. This information can include:
• Social Security number and Payment History
• Account balances and Transaction history
• Credit history and Overdraft history
When you are no longer a customer, we continue to share your information as
described in this notice.
How? All financial companies need to share customers' personal information to run
their everyday business. In the section below, we list the reasons financial
companies can share their customers' personal information; the reasons
Austin Capital Bank SSB chooses to share; and whether you can limit this
sharing.
Reasons we can share your personal information Does Austin Capital Can you limit this
sharing?
Bank SSB share?

For our everyday business purposes- Yes No


such as to process your transactions, maintain your
account(s), respond to court orders and legal
investigations, or report to credit bureaus
For our marketing purposes- Yes No
to offer our products and services to you
For joint marketing with other financial companies No We don’t share
For our affiliates' everyday business purposes- No We don’t share
information about your transactions and experiences
For our affiliates' everyday business purposes- No We don’t share
information about your creditworthiness
For nonaffiliates to market to you No We don’t share
Questions? Call 833-850-0850 or go to www.creditstrong.com/contact-us/
Who we are
Who is providing this notice? Austin Capital Bank SSB
What we do
How does Austin To protect your personal information from unauthorized access
Capital Bank SSB and use, we use security measures that comply with federal
protect my personal
information? law. These measures include computer safeguards and
secured files and buildings.
How does Austin Capital We collect your personal information, for example, when you
Bank SSB collect my • Open an account or Use your credit or debit card
personal information?
• Pay your bills or Apply for a loan
• Make deposits or withdrawals from your account
We also collect your personal information from other
companies.
Why can't I limit all sharing? Federal law gives you the right to limit only
• sharing for affiliates' everyday business purposes –
information about your creditworthiness
• affiliates from using your information to market to you
• sharing for nonaffiliates to market to you
State laws and individual companies may give you additional
rights to limit sharing. See below for more on your rights under
state law.

Definitions
Affiliates Companies related by common ownership or control. They can be financial and
nonfinancial companies.
• Austin Capital Bank SSB has no affiliates
Nonaffiliates Companies not related by common ownership or control. They can be financial
and nonfinancial companies.
• Austin Capital Bank SSB does not share with nonaffiliates so they can
market to you.
Joint A formal agreement between nonaffiliated financial companies that together
marketing market financial products or services to you.
• Austin Capital Bank SSB does not jointly market.
Other Important Information
Special Notice for Texas State Residents: HOW TO FILE A COMPLAINT. Austin Capital
Bank SSB is chartered under the laws of the State of Texas and by state law is subject to
regulatory oversight by the Texas Department of Savings and Mortgage Lending. Any consumer
wishing to file a complaint against Austin Capital Bank SSB should contact the Texas
Department of Savings and Mortgage Lending through one of the means indicated below:
In person or by U.S. Mail: 2601 North Lamar Boulevard, Suite 201 Austin, Texas 78705-4294
Telephone Number: (877) 276-5550 Fax Number: (512) 475-1360 or via electronic submission
via the Department’s website:
http://www.sml.texas.gov/consumerinformation/tdsml_consumer_complaints.html
Special Notice for Nevada Residents: We may contact our existing customers by telephone to
offer additional financial products that we believe may be of interest to you. You have the right
to opt out of these calls by adding your name to our internal do-not-call list. To opt out of these
calls, or for more information about your opt out rights, please contact our customer service
department. You may reach us by calling 512-693-3600, clicking the “contact us” link at
www.austincapitalbank.com, or writing to Austin Capital Bank, 8100 Shoal Creek Blvd, Austin,
TX 78757. You are being provided this notice under Nevada state law. In addition to contacting
Austin Capital Bank, Nevada residents can contact the Nevada Attorney General for more
information about your opt out rights by calling 775-684-1100, emailing bcpinfo@ag.state.nv.us,
or by writing to: Office of the Attorney General, Nevada, Department of Justice, Bureau of
Consumer Protection, 100 North Carson St, Carson City, NV 89701-4717

PRIVACY STATEMENT – CALIFORNIA

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy
Statement of Austin Capital Bank, SSB {“we”, “us”, or “our”} and applies solely to visitors, users, and others who
reside in the State of California {“consumers” or “you”}. We adopt this notice to comply with the California
Consumer Privacy Act of 2018 {“CCPA”} and other California privacy laws. Any terms defined in the CCPA have
the same meaning when used in this notice.

Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could
be reasonably linked, directly or indirectly, with a particular consumer or device {“personal information”}. In
particular, we have collected the following categories of personal information from consumers within the past
twelve {12} months:

CATEGORY EXAMPLES COLLECTED


A real name, alias, postal address, unique personal
identifier, online identifier, Internet Protocol address,
A. Identifiers email address, account name, Social Security number, Yes
driver’s license number, passport number, or other
similar identifiers.
A name, signature, Social Security number, physical
characteristics or description, address, telephone
number, passport number, driver’s license or state
identification card number, insurance policy number,
B. Personal education, employment, employment history, bank
Yes
information categories account number, credit card number, debit card number,
or any other financial information, medical information, or
health insurance information. Some personal
information in this category may overlap with other
categories.
Age (40 years or older), race, color, ancestry, national
origin, citizenship, religion or creed, marital status,
C. Protected medical condition, physical or mental disability, sex
classification (including gender, gender identity, gender expression, Yes
characteristics pregnancy or childbirth and related medical conditions),
sexual orientation, veteran or military status, genetic
information (including familial genetic information).
Records of personal property, products or services
D. Commercial purchased, obtained, or considered, or other personal Yes
information purchasing or consuming histories or tendencies.
Genetic, physiological, behavioral, and biological
characteristics, or activity patterns used to extract a
E. Biometric template or other identifier or identifying information,
Yes
information such as, fingerprints, faceprints, and voiceprints, iris or
retina scans, keystroke, gait, or other physical patterns,
and sleep, health, or exercise data.
Browsing history, search history, information on a
F. Internet or other consumer’s interaction with a website, application, or Yes
similar network activity advertisement.

G. Geolocation data Physical location or movements. Yes


Audio, electronic, visual, thermal, olfactory, or similar
H. Sensory data No
information.
I. Professional or
employment-related Current or past job history or performance evaluations. Yes
information
J. Non-public Education records directly related to a student No
education information maintained by an educational institution or party acting
on its behalf, such as grades, transcripts, class lists,
student schedules, student identification codes, student
financial information, or student disciplinary records.

K. Inferences drawn Profile reflecting a person’s preferences, characteristics,


from other personal psychological trends, predispositions, behavior, attitudes, No
information. intelligence, abilities, and aptitudes.

Personal information does not include:


• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope, such as:
○ Health or medical information covered by the Health Insurance Portability and Accountability Act of
1996 {HIPAA} and the California Confidentiality of Medical Information Act {CMIA} or clinical trial
data;
○ Personal information covered by certain sector-specific privacy laws, including the Fair Credit
Reporting Act {FCRA}, the Gramm-Leach-Bliley Act {GLBA} or California Financial Information
Privacy Act {FIPA}, and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:
• Directly from our clients or their agents. For example, from documents that our clients provide to us
related to the services for which they engage us.
• Indirectly from our clients or their agents. For example, through information we collect from our clients in
the course of providing services to them.
• Directly and indirectly from activity on our website www.austincapitalbank.com. For example, from
submissions through our website portal or website usage details collected automatically.
• From third parties that interact with us in connection with the services we perform. For example, from
credit reporting agencies when obtaining consumer reports in connection with an account/loan application
or review.

Use of Personal Information


We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with
personal information in order for us to complete, evaluate, and decision a credit application, we will use
that information to do so.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services,
or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and
us, including for billing and collections.
• To improve our website and present its contents to you.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our clients, or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental
regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or
transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or
similar proceeding, in which personal information held by us is among the assets transferred.

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

Sharing Personal Information


We may disclose your personal information to a third party for a business purpose. When we disclose personal
information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both
keep that information confidential and not to use if for any purpose except performing the contract.

In the preceding twelve {12} months, we have disclosed the following categories of personal information for a
business purpose:
Category A: Identifiers
Category B: Personal information categories
Category C: Protected classification characteristics
Category D: Commercial information
Category I: Professional or employment-related information

We disclose your personal information for a business purpose to the following categories of third parties:
Service providers.
Third parties to whom you or your agents authorize us to disclose your personal information in connection
with products or services we provide to you.

In the preceding twelve {12} months, we have not sold any personal information.

Your Rights and Choices


The CCPA provides consumers {California residents} with specific rights regarding their personal information.
This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights


You have the right to request that we disclose certain information to you about our collection and use of your
personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we
will disclose to you:
• The categories of personal information we collected about you.
• The categories of sources for the information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
○ Sales, identifying the personal information categories that each category of recipient purchased; and
○ Disclosures for a business purpose, identifying the personal information categories that each category
of recipient obtained.

Deletion Request Rights


You have the right to request that we delete any of your personal information that we collected from you 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 our records, unless an exception
applies.

We may deny your deletion request if retaining the information is necessary for us or one of our service providers
to:
1. Complete the transaction for which we collected the personal information, provide a good or service that
you requested, take actions reasonably anticipated within the context of our ongoing business relationship
with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute
those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech ensure the right of another consumer to exercise their free speech rights, or exercise
another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act.
6. 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 have previously provided informed
consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your
relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you
provided it.

Exercising Access, Data Portability, and Deletion Rights


To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer
request to us by either:
Calling us at (833) 850-0850
Visiting www.creditstrong.com
Only you or a person registered with the California Secretary of State that you authorize 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 or data portability twice within a 12-month period.
The verifiable consumer 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 your request with sufficient detail that allows us to properly understand, evaluate, and respond to
it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or
authority to make the request and confirm the personal information relates to you. Making a verifiable consumer
request does not require you to create an account with us. We will only personal information provided in a
verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format


We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time {up
to 90 days}, we will inform you of the reason and extension period in writing. If you have an account with us, we
will deliver our written response to that account. If you do not have an account with us, we will deliver our written
response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period
preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we
cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your
personal information that is readily useable and should allow you to transmit the information from one entity to
another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or
manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision
and provide you with a cost estimate before completing your request.

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we
will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other
benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of
goods or services.

Changes to Our Privacy Notice


We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this
privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and
use your personal information, your choices and rights regarding such use, or wish to exercise your rights under
California law, please do not hesitate to contact us at:

Phone: (833) 850-0850


Website: www.creditstrong.com
Postal Address: 8100 Shoal Creek Blvd, Austin, TX 78757
FEE SCHEDULE

Service Per Item Fee


Cashier's Check $4.00
Collection Item (Domestic) $20.00
Copy of bank statement $3.00
Copy of paid check or other item $2.00
Debit Card Re-Order $5.00
Deposit Item Return Charge $10.00
Hourly account reconciliation and research $50.00
Money Order $0.49
Notary Services (Account Holders Only) Free
Overdraft Charge $30.00 1
Photocopy $1.00
Returned Item Charge $30.00 2
Stop Payment Fee $30.00
Telephone Transfer Free
Temporary Checks (9 checks) $2.00
Incoming Wire Transfer-Domestic $10.00
Outgoing Wire Transfer-Domestic $20.00
Incoming Wire Transfer-International $10.00 *
Outgoing Wire Transfer-International $50.00 *
Check printing fees vary by the style of check ordered.

1. Overdraft may be created by check, in-person withdrawal, ATM withdrawal, or other electronic means. An
overdraft charge will not be assessed on ATM or one-time debit card transactions.
2. Return Item Charge is $14.00 for the Credit Strong account.

ATM FEES. When you use an ATM not owned by us, you may be charged a fee by the ATM operator or any
network used, and you may be charged a fee for a balance inquiry even if you do not complete a fund transfer.

*Plus correspondent bank charges.

Other fees or restrictions may apply to specific account product types.


Please ask us to receive a complete truth in savings disclosure.

8100 Shoal Creek Blvd Austin, Texas 78757 Tel: (512) 693-3600 Fax: (512) 693-3614 www.AustinCapitalBank.com
Credit Strong, Division of Austin Capital Bank Tel: (833) 850-0850 www.CreditStrong.com

© 2021 Austin Capital Bank SSB All Rights Reserved.


FURNISHING NEGATIVE INFORMATION NOTICE

We may report information about your account to credit bureaus. Late payments, missed payments, or other
defaults on your account may be reflected in your credit report.

© 2021 Austin Capital Bank SSB All Rights Reserved.


Electronic Disclosure Consent

This statement asks for your consent so that we can provide communications and information to you in an electronic
format rather than in paper format. Before you decide whether or not you wish to provide your consent to receiving
electronic disclosures, you should read and consider the following information. Then, if you decide to consent, you
can check the “I agree” box after closing this statement. For your consent to be effective, your computer and
browser will need to meet the hardware and software requirements discussed below.
This statement contains important information that we are required by law to provide to you. You should keep a
copy for your records. If you have any questions about E-disclosures that are not answered, feel free to communicate
with us using any of the following contacts:
• Call us at (833) 850-0850, or
• Inform us in person at any one of our offices, or
• Send us a letter via U.S. mail to: Credit Strong, a Division of Austin Capital Bank SSB, 8100 Shoal Creek
Blvd., Austin, TX 78757.
If you write us a letter, please be sure to identify yourself and the applicable accounts.
1. Scope of Communications to Be Provided in Electronic Form
Your consent is voluntary, but we cannot process your application, maintain an account for you, or make a loan to
you if you do not consent. If you are unwilling to receive these disclosures and notices electronically, do not check
the “I agree” box after closing this statement. If you consent, we may also provide other disclosures in an electronic
format. These disclosures may include but are not limited to the following:
• All legal and regulatory disclosures and communications associated with your account;
• Applications and agreements for loan products or services;
• Account terms and conditions;
• Account statements;
• Notice of change in account terms;
• Notice of fee changes;
• Responses to any questions you may have about electronic funds transfers;
• Privacy and security notices.
You acknowledge and agree that:
• We may send you any Communication electronically Your consent to receive electronic Communications
will automatically enroll you in Paperless Statements and allow us to electronically send you all
Communications by the methods set forth below in Section 2.
• You and we may sign and execute documents with electronic signatures, which will be just as effective and
binding as a signature on paper. Your agreement to electronic signatures applies to any and all documents
that you have agreed to receive electronically.
2. Method of Providing Communications to You
All Communications (including alerts that Communications have been provided or posted via any of the methods set
forth below) will be provided by one or more of the following methods:
• Through our website, including our mobile websites or, to the extent permitted by law, a website that we
will designate in advance for any such Communications;
• Via the email address you provide us;
• Text messages and push notifications to your mobile device;
• Secure messages via CreditStrong.com; or
• By requesting you download a Hyper Text Markup Language ("HTML") file or a Portable Document
Format ("PDF") containing the electronic Communication.
3. TEXT MESSAGE (SMS) SERVICE
You acknowledge and agree that you may receive periodic text messages. You may opt out of receiving text
messages at any time. To opt out of the CreditStrong.com text message program, send a text message with the word
“STOP” to 850850 from your mobile phone. If you need help with the text message service, please contact us at
help@creditstrong.com or text “HELP” to 850850.
Standard message and data rates apply to all text messages sent to or received from us. For more information
regarding these rates please review your mobile service plan or contact your mobile carrier.
4. How to Obtain Electronic Disclosures (E-Disclosures)
You may download or print electronic notices and disclosures from your computer if you have the hardware and
software described below. You can also save copies to your hard drive or other media for viewing and printing at a
later time.
If you have trouble printing or if you need a paper copy for a special situation, you may request a paper copy from
us by contacting us through any of the methods listed above. If you need a paper copy of any E- disclosure, we will
provide the first copy for free. Charges may apply for additional paper copies.
5. System and Equipment Requirements
Prior to accepting electronic delivery of disclosures, you should verify that you have the required hardware and
software necessary to access and retain documents and disclosures in an electronic format. You will need:
• Internet Access.
• A computer and Internet browser that can support 128-bit encryption.
• You will need Internet access through an Internet service provider (ISP).
• A printer connected to your computer to print or download disclosures.
• Sufficient hard-drive space or other media (e.g. floppy disk or CD) if you plan to save disclosures in an
electronic format.
• An external email address.
We may revise hardware and software requirements, and if there is a material chance that the changes may impact
your ability to access the disclosures we will notify you of these changes thirty (30) days in advance and provide
you an opportunity to change your method of receiving disclosures without the imposition of any fees.
6. Cancellation of E-Disclosures
We will provide statements and agreements for the Credit Builder account in electronic format. If you cancel or
withdraw your consent to electronic disclosures after opening a Credit Builder account with us, your Credit Builder
account will be cancelled. Funds owed on your loan will be set off by amounts in your deposit account, and any
remaining available funds in your deposit account will be distributed to you via ACH or debit card transaction. If
you want to cancel e-disclosures you must:
• Call us at (833) 850-0850, or
• Inform us in person at any one of our offices, or
• Send us a letter via U.S. mail to: Credit Strong, a Division of Austin Capital Bank SSB, 8100 Shoal Creek
Blvd., Austin, TX 78757.
If you write us a letter, please be sure to identify yourself and the applicable accounts.
7. Address Changes
In order to provide electronic disclosures, we must maintain current customer email address at all times. It is your
sole responsibility to provide us with your correct contact information, including your email address. You should
notify this institution of any changes to your personal contact information through any of the methods described
above in section 3.
8. Proceed with Acceptance of E-Disclosures
With your acceptance, you agree to accept account related disclosures in an electronic format. You also agree that
you have the necessary equipment for accessing and viewing the disclosures and you agree to notify us if you
change your email address.
Upon completion of the registration process, we may send you an email and ask you to confirm your email address,
and your ability to access electronic disclosures.
Your consent is voluntary, but we cannot process your application, maintain an account for you, or make a loan to
you if you do not consent. If you are unwilling to receive these disclosures and notices electronically, do not check
the “I agree” box after closing this statement.

© 2021 Austin Capital Bank SSB All Rights Reserved.

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