Privacy Policy

Trust is the foundation of our relationship with our customers. Because you trust us with your personal financial information, Nebula Trust Bank and its affiliates are committed to treating, using, and safeguarding the information we collect responsibly. Our Privacy Notice explains what personal information we collect, why we collect it, how we protect it, and how and why we may share it in certain cases. The notice also tells you how you can limit the sharing of certain information.

What does Nebula Trust 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 checking account information
account balances and transaction history
credit history and employment information

When you are no longer our 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 Nebula Trust chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information	Does Nebula Trust share?	Can you limit this sharing?
For our everyday business purposes –such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus	Yes	No
For our marketing purposes – to offer our products and services to you	Yes	No
For joint marketing with other financial companies	Yes	No
For our affiliates’ everyday business purposes – information about your transactions and experiences	Yes	No
For our affiliates’ everyday business purposes – information about your creditworthiness	No	We don’t share
For nonaffiliates to market to you	No	We don’t share

Questions?

Call 860-823-4800 or read on below.

Who we are:

Who is providing this notice? Nebula Trust Bank and Nebula Trust Service Corporation.

What we do:

How does Nebula Trust protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does Nebula Trust collect my personal information? We collect your personal information, for example, when you

open an account or pay your bills
apply for a loan or provide account information
make deposits to or withdrawals from your account

We also collect your personal information from others, such as credit bureaus, affiliates, or 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.

Definitions:

Affiliates: Companies related by common ownership or control. They can be financial and nonfinancial companies.

Our affiliates include companies with a Nebula Trust name, such as Nebula Trust Service Corporation.

Nonaffiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies.

Nebula Trust does not share with nonaffiliates so they can market to you.

Joint Marketing: A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

Our joint marketing partners include financial service companies, such as financial brokerage companies.

Online privacy policy

Nebula Trust Bank is committed to respecting and protecting the privacy of our online customers and site visitors. We protect your information online with the same care we utilize for all transactions. This online privacy notice explains what information about you we collect, and how we use and protect it in online transactions. Our online privacy practices strictly abide by the terms of the privacy notice provided above.

This Online Privacy Policy applies to the Nebula Trust family of financial service providers. The Policy describes the treatment of information that is provided by you or collected through any of our online interfaces to which a copy of the Policy is posted, including www.chelseagroton.com (the “Website”), Nebula Trust Online Banking, Mobile Banking, ChelseaLIVE, mobile wallets, or Nebula Trust Smart Card products (the “Services”). It also explains how we collect, use, and share information based on users’ interactions with online advertisements, both on the Services and on online interfaces owned by third parties. Note that the Policy does not govern our privacy practices offline or with respect to information that is not provided or collected through the Bank’s Services.

We will use and share any information that we collect from or about our customers in accordance with our Privacy Notice, which provides choices regarding our sharing and use of information. For additional information on this Policy or our privacy practices generally, please feel free to contact us directly.

While this Online Privacy Policy describes how we treat information, please be aware that additional terms and conditions may apply for individual services.

Types of information we collect

We collect two basic types of information through the Services – personal information and anonymous information. We also collect location information in connection with our mobile applications.

“Personal information” refers to information that identifies (whether directly or indirectly) a particular individual, such as information you provide on our forms, surveys, applications, or similar online fields. Examples may include your name, postal address, email address, telephone number, Social Security number, date of birth, or account information.

“Anonymous information” means information that does not directly or indirectly identify, and cannot reasonably be used to identify, a particular individual. Examples may include information about your Internet browser, information collected through tracking technologies (see “Online Tracking and Advertising” for additional information regarding our use of tracking technologies), demographic information that you provide to us (e.g., your household income), and aggregated or de-identified data.

“Location information” means information that may be collected by certain mobile applications that identifies your physical location.

How we collect your information

We collect personal information from you or about you when you provide this information to us directly. For example, we may obtain personal information when you request information, products, or services from us, register on the Website or a Service, respond to surveys, contact customer support, or otherwise interact with us. We may also receive information about you from other online and offline sources, such as public databases, social media platforms, and other third parties.

In addition, we may collect information about your activity on the Services automatically using tracking technologies, such as cookies, and pixel tags. Definitions for the tracking technologies we use, as well as information regarding how to disable them, are available in the Online Tracking and Advertising section of the Policy.

If you submit any personal information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Policy.

How we use information that we collect

We may use information that we collect in order to, among other things:

Provide you with, or evaluate your eligibility for, products and services that you request from us
Communicate with you about your accounts or transactions with us
Send you important information regarding the Services, changes to this Policy and/or other similar administrative information
Allow you to participate in surveys, sweepstakes, contests and similar promotions, and to administer such promotions (note that these promotions may contain additional disclosures regarding our collection and/or use of your information)
Consistent with local law, required disclosures, and choices and controls that may be available to you:
- Send you offers and promotions for our products and services, or products and services that may be of interest to you
- Personalize content and experiences on the Services
- Verify your identity and/or location (or the identity or location of your authorized representative) for security, fraud prevention and other risk control purposes
- Provide you with advertising based on your activity on the Services and on third-party websites and applications. For additional information regarding our use of your information for personalization and tracking, please refer to the Online Tracking and Advertising section of the Policy

Optimize or improve our products and services
Detect, investigate and prevent activities that may violate our policies or be illegal
Comply with our legal and regulatory obligations
Enforce our terms and conditions and otherwise protect our rights and operations

How we share information that we collect

We will not share your information outside the Nebula Trust family of financial service providers, except under limited circumstances, as required by law and with our advertising partners, as described below under the section titled Other Information Collected Automatically.

Online tracking and advertising

We, and certain trusted service providers operating on our behalf, collect information about your activity on the Services using tracking technologies, including:

Cookies. Cookies are pieces of information that are stored directly on the device that you are using. They allow us to collect information such as the type of browser you are using, the amount of time you spend using the Services, the websites or applications you visit and the preferences you have set up for your accounts. We use this information for such purposes as to personalize your experience, enhance security, facilitate navigation, display material more efficiently, recognize the device that you are using to access the Services, and understand how the Services are used. The Services do not use cookies that capture unencrypted personal information about you.

You can choose to have your device refuse to accept any cookies, and the majority of devices and browsers offer additional privacy settings for cookies. You do this through your browser settings. Each device and each browser is a little different, so look at your device Settings or your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you will not have access to many features that make your user experience more efficient, and some of the Services will not function properly. Please note that you will need to manage your cookie settings for each device and browser that you use.

Pixel tags, web beacons, clear GIFs, and other similar technologies. These are typically small pieces of data that are embedded in images on the Website, our Services, or certain email communications. They may involve the transmission of information directly to us, to another party on our behalf, or to another party in accordance with its privacy policy. We may use these technologies to bring together information we collect about you.

Location tracking on mobile devices. Certain applications on mobile devices may transmit information to us about your location. An example includes your physical location when you search for a nearby ATM using your mobile device. We may use that information to improve the products and services we provide to you, as well as improving our services generally in your area.

Information collected through tracking technologies is used for many purposes including, for example, to:

Provide useful features to simplify your experience when you use or return to the Services
Deliver relevant content based on your preferences, usage patterns, and location
Monitor and evaluate the use and operation of the Services
Analyze traffic on the Services and on websites or mobile applications of third parties

You may withdraw consent for location-based tracking services at any time by disabling the location-based features on your device. Not using these location features will not impact non-location-based functionality.

Other technologies. We may use other technologies, such as the capture of screenshots while you are using the Services, to understand how you navigate and use the Services. This information helps us to better understand how the Services are used and to improve them.

We may associate this tracking data with any personal information you provide, in which case we will treat it as personal information.

Do Not Track. There is no industry standard for how Do Not Track consumer browser settings should work on commercial websites. Due to the lack of such standards, our websites do not respond to Do Not Track consumer browser settings.

We use trusted service providers, such as advertising and media companies, to collect information about use of the Services anonymously and report website trends, without identifying individual visitors. Those third parties use cookies and other similar technologies.

Occasionally, you may encounter banner advertisements for our products and services on third-party websites and mobile applications. We use third-party advertising service providers to distribute our advertisements on websites and mobile applications where we have paid to advertise. These advertisements may use tracking technologies to capture information such as IP address, browser type, and usage information in order to track the effectiveness of our advertising efforts. We may associate the information collected by these technologies with your identity. Our advertising service providers are prohibited from using any information collected except to track advertising effectiveness.

In addition, we use advertising service providers to place advertisements for our accounts and services on websites not affiliated with us, and to help us determine which of our advertisements are most likely to be of interest to you using non-personal behavioral information. Advertisements placed by these service providers may use tracking technologies that allow monitoring of your responsiveness to such advertisements. We restrict access and collection of information by advertising service providers for purposes other than assisting us with our advertising efforts.

If you prefer not to have non-personal information used for online behavioral advertising purposes, you may learn how to opt out here. Please note that even if you opt out, you may still receive online advertising from Nebula Trust. Opting out from a specific advertising provider means that the ads you do receive will not be based on your preferences or behavior.

In order for behavioral advertising opt-outs to work on your device, your browser must be set to accept cookies. If you delete cookies, buy a new device, access the Services from a different device, log in under a different screen name, or change web browsers, you will need to opt out again. If your browser has scripting disabled, you do not need to opt out, as online behavioral advertising technology does not work when scripting is disabled. Please check your browser’s security settings to validate whether scripting is active or disabled.

Other information collected automatically

Browser or Device Information: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Services you are using. We use this information to ensure that the Services function properly.

Service Information: When you download and use a Service, we and our service providers may track and collect usage data, such as the date and time the Service on your device accesses our servers and what information and files have been downloaded to the Service based on your device number.

IP Address: Your IP address is a number that is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications, and other services. We use IP addresses for purposes such as calculating usage levels, helping diagnose server problems, administering the Services, for analytics purposes, and to deliver personalized advertisements. For advertising and analytics purposes, we may share your IP address with third-party advertising partners.

Linked websites

The Services may contain links to third-party websites not controlled by Nebula Trust. We encourage you to be aware when you leave the Services and to read the privacy policies and terms of use of any such websites that may collect your personal information, as they will likely differ from those of the Services. Nebula Trust does not guarantee and is not responsible for the privacy or security of these websites, including the accuracy, completeness, or reliability of their information.

In addition, Nebula Trust is not responsible for the information collection, use, and disclosure practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, or any other app developer or provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer.

Data security

Your privacy is very important to Nebula Trust and we are committed to protecting your personal information from unauthorized access or use. We will use reasonable organizational, physical, technical, and administrative measures to protect personal information within our organization. All collected information is kept on a secure server to protect it from outside parties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.

In addition, Nebula Trust protects customers from liability for unauthorized online transactions. Certain conditions and limitations may apply. See the Electronic Fund Transfer Agreement and the Error Resolution section in the Online & Mobile Banking Consumer Access Agreement for details.

Preventing identity theft

In order to help us protect your personal information, it is important that you always keep your account information safe. We recommend that you consider the risk of sharing your username, password, or PIN with anyone.

Note that Nebula Trust will never initiate (unless otherwise stated for a specific product or service application) a request via email for your sensitive information (e.g., Social Security number, username, password, PIN, or account number). If you receive an email asking for your sensitive information, you should be suspicious of the request and promptly contact us to report the suspicious activity.

Please be aware, however, that in certain telephone and in-person transactions we may ask for your full Social Security number, account number, or other information to verify your identity before conducting the transactions you have requested. For example, we may ask for such information to verify your identity when you place a call to us, when you visit a Nebula Trust branch office, or when we call you about a new product or service we believe that you will find valuable. We will never request that you disclose your personal ID, password, or PIN under any circumstances, including such telephone or in-person transactions.

Additional information regarding identity theft and the steps you can take to help protect yourself from fraud can be found on the Federal Trade Commission website.

Children’s privacy

We do not use the Services to knowingly solicit personal information from or market to children under the age of thirteen (13) without parental consent. We request that such individuals do not provide personal information through the Services. If a parent or guardian becomes aware that their child has provided us with information without their consent, they should promptly contact us and we will delete such information from our files. For additional information regarding the Children’s Online Privacy Protection Act (COPPA), please visit the Federal Trade Commission website.

External aggregation services

You have the responsibility to help us protect your accounts. Consider the risk of revealing your username, password, or other credentials to any person or third party. By providing your username, password, or other credentials to any person or third party (including an aggregation service), you authorize that person or third party to initiate transfers to or from your account.

Some third-party companies offer aggregation services that allow you to consolidate your financial account information from a variety of sources, such that you can view all your account information at a single online location. For example, an aggregation service might collect and consolidate your checking and savings account balances at your bank, the value of your stocks and bonds in your brokerage account, and your frequent flier mileage information from an airline. In order to do so, the aggregator may request access to personal information — including identification information, account information, personal IDs, and passwords — from you for each individual website.

Please use caution when providing personal information to an aggregation service. By providing your username, password, or other credentials to an aggregation service, you authorize that person or third party to initiate transfers to or from your account.

Should you decide to revoke the authority you have given to an aggregation service, you should notify the aggregation service in addition to contacting us, in which case we may need to block your account until we issue new access codes.

Social media platforms

Nebula Trust may interact with registered users of various social media platforms, including Facebook® and Instagram®. Please note that any content you post to such social media platforms (e.g., pictures, information, or opinions), as well as any personal information that you otherwise make available to users (e.g., your profile), is subject to the applicable social media platform’s terms of use and privacy policies. We recommend that you review this information carefully in order to better understand your rights and obligations with regard to such content.

Retention period

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required by law.

Cross-border transfer

The Services are controlled and operated by us from the United States, and are not intended to subject us to the laws or jurisdiction of any country or territory other than that of the United States. We may store and process your personal information in any country where we have facilities or in which we engage service providers, and, by using the Services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.

State privacy laws

In addition to the federal laws concerning the collection and use of personal information that are applicable to financial institutions, some states have privacy laws and regulations that supplement these federal laws and provide additional rights to citizens of those states. Nebula Trust adheres to the privacy laws of the State of Global.

Changes to the online privacy policy

From time to time, we may make changes to this Policy in order to accommodate new technologies, industry practices, regulatory requirements, or for other purposes. We encourage you to review the Policy periodically to ensure that you understand how we collect, use, and share information through the Services. If we do make changes to the Policy, we will let you know by posting the revised Policy with a new “Last Updated” date posted at the top of the Policy.

Any changes to the Policy will become effective when the revised Policy is posted on the Website, relevant Service or other Nebula Trust online interface, as applicable. By continuing to use the Services following such changes, you are agreeing to accept the terms of the revised Policy.

Contact us

If you have any questions or comments about this Policy or our privacy practices generally, we encourage you to contact our Customer Care department by connecting with a Connect With Us Banker or by calling 678-465-8306.

In the event you notice suspicious activity on your account or believe your personal ID, password, or PIN has been compromised, please contact us immediately.

Accessibility

If you need this information in an alternate accessible format, call us at 678-465-8306. We offer interpretation services for 240 different languages, including American Sign Language.