Online Privacy Policy

Technology Privacy Policy

Smart Financial recognizes that a key concern of our Members is the use of their information once it has been collected through technology/digital channels and the original transaction completed. Our Technology Privacy Policy is a separate policy from our Consumer Privacy Policy, and it describes how we can collect, use, share and protect information about members who interact with us through our online websites, mobile application, or social media accounts.

Smart Financial uses the information only to the extent necessary to carry out our daily business activities and to provide services and other opportunities of interest to our Members.

Smart Financial may also periodically collect, transmit, use, and share geolocation information to enable feature(s) that may prevent fraudulent card use and send alerts, but only if the End User expressly authorizes collection of such information. Geolocation information can be monitored on a continuous basis in the background, only while the Solution is being used, or not at all depending on the End User’s selection. The End User can change his/her location permissions at any time in their device settings.

Under these arrangements, we may disclose some, or all the information we collect, as described below, to companies that perform marketing and other services on our behalf. To protect our Members' privacy, we will only work with companies that follow strict confidentiality requirements and limit the use of information we provide. We do not permit these companies to sell to other third parties the information we provide to them.

We highly value the privacy of your financial and personal information. If you have any questions, please contact us at (713) 850-1600 or (800) 392-5084.

Information We Collect

We may collect the following nonpublic information about you from a variety of sources and may disclose all the information we collect to companies that perform marketing services on our behalf:

From Membership and loan applications and other forms, we obtain information such as your name, address, social security number and income.
From information obtained in transactions between Smart Financial and other companies because of providing you products and services. This includes transaction information from share drafts (checks), debit cards, credit cards, automated teller machine (ATM) cards, and electronic transfers (for example, automated clearinghouse (ACH) transactions).
From photo or images captured when you perform a remote deposit transaction to facilitate the processing of each deposit item (check) captured and transmitted electronically by you for deposit into any of your accounts with us.
From consumer reporting agencies, we obtain information such as your credit worthiness and credit history.
From verifications of information you provide on applications and other forms, we obtain information from current or past employers, other financial institutions and other sources listed on the application.

We Use Tracking Pixels

Tracking pixels are pieces of code embedded in a website, video, email, or advertisement that send information about your use to a server. Pixels are small graphic images. When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or another party to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels to allow us to track conversions, bring you advertising both on and off the Web Sites and Applications, and provide you with additional functionality.

How Collected Information is Used

We may disclose all the nonpublic information we collect to:

Companies that perform marketing services on our behalf.
Financial service providers such as mortgage brokers, security brokers/dealers, and insurance agents.
Process the check deposit images you submit through other financial institutions or service companies.
We may also disclose information about you under other circumstances as permitted or required by law. These disclosures typically include information to process transactions on your behalf, conduct the operations of Smart Financial, follow your instructions as you provide authorizations, or protect the security of our financial records.
If you terminate your Membership with Smart Financial, we will not share information we have collected about you, except as permitted or required by law.

How We Protect Your Information

We protect your personal information through encryption.

We restrict access to nonpublic personal information about you to those employees who have a specific business purpose in using your data.

We restrict access to check [deposit] images you submit for processing to those employees who have a specific business purpose in using the image(s).

Our employees are trained on the importance of maintaining confidentiality and Member privacy. We maintain physical, electronic, and procedural safeguards that comply with federal regulations and leading industry practices to safeguard your nonpublic personal information.

Online Banking User Profile Deletion

Smart Financial is required to provide all users the option to request the deletion of their account(s) and associated data.

To request removal of your online/mobile banking account(s) and data, consumers can:

From within our application, navigate to Settings > Delete Account

Click on the following link to complete our Account Deletion request form. You will need to provide identifying information so we can locate your account.

Smart Financial Online Banking Account Deletion Request Form

Upon execution of this request, Smart Financial will permanently delete all associated data held in our digital and internet banking application(s), except for any information required to be retained by law or regulation. This data will no longer be accessible or available to any party.

Your Smart Financial account(s) will remain active, and your account transaction history will remain in our banking system to comply with our retention policies, but all Internet and Mobile Banking application data will be deleted.

Looking Out for Children

We do not knowingly market to or solicit information from children under 13 without parental consent. We recognize that protecting children's identities and privacy online is important, and that the responsibility to do so rests with both the online industry and with parents. Smart Financial’ s website and online services are not directed to children under the age of 13, nor is information knowingly collected from children under the age of 13.

Should we receive information (name, address, email, account number, telephone, social security number) from a child known to be under 13, the information will only be used to respond directly to the child, seek parental consent, or provide parental notice.

While Smart Financial works to protect your personal information, you also have responsibility.

We recommend that minors ask their parents for permission before sending any information about themselves to anyone over the Internet.

For more information about the Children’s Online Privacy Protection Act (COPPA), visit the FTC website at https://www.ftc.gov/business-guidance/privacy-security/childrens-privacy.

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