Rev. June, 2006
Investors Bancorp Privacy Policy
The Board, management and staff of Investors Bancorp, MHC, and its affiliates and/or subsidiaries, Investors Savings Bank and ISB Mortgage Co., L.L.C. (hereafter referred to as Investors, we, us or our) highly value our customer and consumer relationships and are acutely aware of the trust and responsibilities these relationships entail. We are committed to offering our customers an attractive menu of financial products and services to help them meet their financial goals. In so doing, however, we are mindful of our obligation to ensure that the privacy of the sensitive personal and financial information entrusted to us is not compromised. This Privacy Policy is intended to allow the attainment of these objectives. We want you to know that we do not sell customer information, nor do we share customer information with nonaffiliated third parties other than as permitted by law, so there is no need for you to tell us not to.
PRIVACY POLICY PRINCIPLES
Information - Gathering
Investors collects nonpublic personal information about current and former customers from a variety of sources, including:
· Information received from you on applications or other forms including, but not limited to, income and assets;
· Information about your transactions with us, our affiliates/subsidiaries or others including, but not limited to, deposit or loan history;
· Information we receive from consumer reporting agencies including, but not limited to, credit history.
Nonpublic personal information is:
· personally identifiable financial information that you provided to us or that we otherwise obtained in connection with providing you with a product or service; and/or,
· any list, description, or other grouping of consumers that is derived using any personally identifiable financial information that is not publicly available.
Our Web site: isbnj.com - We do not collect personal information from visitors to our Web site without their knowledge. The information you provide to us on our Web site and during your Investors Online internet banking session is done so voluntarily so that we may provide you with a product or service for which you have expressed an interest or to complete a transaction that you have initiated.
Use of “Cookies” - A “cookie” is a small piece of information that may be created when you visit a web site, and may or may not be written to your computer’s hard drive. Depending on the type of information collected, if it is stored on your hard drive it can be retrieved when you revisit the site. Another type of “cookie” is used to enhance performance of a web site. It is written to your browser only (Internet Explorer, Netscape Navigator, etc.) and expires when you terminate your internet session. This is the type of “cookie” we use to monitor the activity of Investors Online during your session. If there is no activity for a predetermined period of time, your session will timeout and you will be automatically logged off. No personal information is collected about you, nor can personal information be retrieved from your computer through the use of the “cookie”.
Information - Use
Although we may disclose all of the information we collect and retain as described above, its use will be limited to what we reasonably believe is appropriate and necessary to administer our business and to provide the quality service you expect and deserve, such as to:
· Conduct business with you and to protect and administer your records, accounts and funds;
· Satisfy regulatory reporting and other legal requirements;
· Administer proper internal operations; and,
· Allow us to better understand your financial needs in order to design or improve our financial products and services.
Types of Information Investors Discloses to Affiliated and Nonaffiliated Companies
Federal laws and regulations govern the range of nonpublic personal information we may divulge to both affiliated and nonaffiliated third parties:
Affiliated Companies
The Fair Credit Reporting Act sets standards that regulate the use and dissemination of consumer reports. This Act permits us to share with our affiliates/subsidiaries information regarding your transactions and experiences with us.
Investors Savings Bank customers -We may also share other information (such as information on applications and other forms or credit reports) with our affiliates/subsidiaries. In addition, we may share information about you with our affiliates/subsidiaries for marketing purposes to make a solicitation to you about its products or services.
Your Right to Opt-Out of Affliate-Sharing
If you prefer that we do not share other information with our affiliates/subsidiaries, or any information for marketing purposes, you may direct us not to by completing the form at the end of this notice.
ISB Mortgage Company L.L.C. customers - We do not share any information with our affiliates or nonaffilated third parties, except as permitted by law.
Nonaffiliated Companies
In the ordinary course of business, there are certain circumstances in which disclosure of customer or former customer nonpublic personal information to nonaffiliated third parties is required and/or permitted by law, including but not limited to:
· To effect, administer or enforce a transaction, product or service that you have requested and/or authorized;
· To maintain or service a customer’s account as part of a private label credit card or other loan extension program;
· In connection with a securitization, secondary market sale (including servicing rights), or similar transaction related to a consumer;
· For disclosures that are necessary to enforce our legal or contractual rights or the rights of any other person who is engaged in the financial transaction;
· For disclosures required in the ordinary course of business, such as the settlement of claims or benefits, the confirmation of information to the consumer or the consumer’s agent, and the billing, processing, or clearing of items in the normal course of business;
· To provide information to insurance rating advisory organizations, guaranty funds or agencies, agencies that are rating us, persons who are assessing our compliance with industry standards, and our attorneys, accountants and auditors;
· To comply with an order, summons, or subpoena of a government agency or a court to the extent permissible under the Right To Financial Privacy Act;
· To a consumer reporting agency under the Fair Credit Reporting Act;
· To comply with federal, state or local laws, rules and other applicable legal requirements.
· With a variety of nonaffiliated third parties which perform marketing services on our behalf, or with other financial institutions with whom we have joint marketing agreements in order to provide financial products or services, including mortgage bankers, insurance agents, broker/dealers and finance companies. We maintain written agreements with these third parties to keep the information we provide confidential and use it only for the purpose intended. This formal agreement obligates the nonaffiliated third party to comply with our privacy policies of confidentiality, and prohibits the sale, dissemination, or reuse of nonpublic personal customer information. This agreement will allow us to audit the nonaffiliated third party for compliance and will provide that if the agreement is violated, we are entitled to seek legal remedies.
Neither Investors Savings Bank, nor its subsidiary ISB Mortgage Co. L.L.C. share information with nonaffiliated third parties, except as required and/or permitted by law.
Safeguarding Customer Information
At Investors, we protect customer privacy by ensuring that only employees who have a business reason for knowing information have access to it. All employees are given a copy of our Privacy Policy and Code of Ethics and will be trained at least annually regarding the importance of safeguarding customer information Disciplinary action will be taken against any employee who violates Investors policies and procedures.
Investors maintains physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.
We continually assess new technology for protecting information. We strive to ensure that our operational and data processing systems are in a secure environment that protects your account information from being accessed by unauthorized parties.
Our Web site: isbnj.com - Our website may provide links to products and services which are offered through nonaffiliated third parties. We have no control over third parties or their web sites. Once you leave our web site, you should review the security and privacy policies of the nonaffiliated third party.
Investors Online and Bill Paying Service - We take every precaution to ensure that your banking sessions are performed in a secure environment through a secure server. Our Web site provides secure communication and has a valid certificate (Verisign). Secure communication means that information you provide and transmit over the Internet, such as your account number or other personal information, is encrypted using the highest level of 128-bit encryption so that it cannot be intercepted and read by other people. The certificate is a statement guaranteeing the security of the Web site and contains information that a specific Web site is authentic. This ensures that no other site can assume the identity of the original site. We also require a User ID, and additional authentication to access Investors Online. To maintain the security of your account information, we ask that you take the following precautions: (1) Do not share your User ID and/or password with anyone. If you do, you are authorizing the Bank to perform transactions for that person, just as if you requested it; (2) Change your password regularly; and, (3) Remember to sign off after your session.
Security Reminder- Our employees will never ask you for your password. We will never use e-mail to ask you for any personal or financial information. If you believe someone has obtained any of your personal or financial information regarding your accounts with us, or your User ID and/or password, contact us immediately at 1-800-252-8119.
Secure Messaging - Our website features a secure message system which allows you to send messages to us using 128-bit encryption to transmit the messages securely over the internet. You may send a secure message to us by selecting the “Contact Us” button available throughout our website. However, since we cannot send an encrypted message back to you, should we need to respond with any non-public personal information, we will use alternate means such as telephone or US Postal Mail.
Regular E-mail - You should know that e-mail is not transmitted through a secure server and could be intercepted by a third party. When you send e-mail to us or others, you should not include personal or confidential information, such as account numbers or social security numbers.
Accuracy of Information
Investors has established procedures to ensure that your financial information is accurate, current and complete, in keeping with reasonable industry standards. We continually strive to maintain complete and accurate information about you and your accounts. Should you ever believe that our records contain inaccurate or incomplete information about you, please notify us. We will investigate your concerns and correct any information we determine to be inaccurate.
This policy may be revised from time to time, and without notice, to reflect current practice. However, should we decide to disclose information to an affiliate or nonaffiliated third party other than as permitted by law, we will provide you with a revised notice and reasonable time for you to tell us that you prefer that we do not disclose your information. If you had previously informed us that you did not want us to share information, there is no need to notify us again.
In addition to all of the above, we will inform you of our commitment to respect your privacy annually, as long as you maintain a continuing relationship with us.
For more information, stop by your local branch office or call us at (800) 252-8119.
