Privacy Policy

Thank you for visiting the First Finance International Bank Website. It is important to read this privacy policy before submitting any personal data or becoming a User. By using this Website or our services you agree to these terms. First Finance International Bank is referred to in this privacy policy (hereinafter referred to as "Policy") as “FFIBI”, "we", or "us". Federal law requires FFIBI to provide notice to certain consumers to explain what personal information we collect, how we share it, and how consumers may limit FFIBI’s sharing of the information. Our privacy practices are subject to privacy notices, which we strongly suggest you review. 
First Finance International Bank is committed to respecting and protecting your privacy. We value your trust and want you to understand how we protect, collect, use and disclose the personal information you share with us.

First Finance International Bank Inc. is committed to protecting your privacy. This Privacy Policy ("Policy") covers how FFIBI collects and uses the personal information you provide on our website and in conjunction with any of the services hosted at www.firstfinancebank.com and www.ffibi.com ("Service" and "Website"), shall not be limited to, but include Gift Cards, Money Services and Money Transfer accessed by internet-enabled devices.  This Policy also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

The Policy is updated regularly, with January 1, 2021 being the initial date.
This Policy explains what personal information we collect about you, with whom we share it, and how you can elect in certain situations to not share information with third parties. “Personal Information" refers to information such as name and email that can be used to identify you individually.
We may amend this Policy at any time, and whenever we do so, we will notify you by posting a revised version on the Website. If, however, we plan to make a material change in the way we collect, use, or store your personal information, we will provide prior notice on our website, and by email.
You will then have the chance to decide whether or not we will use or disclose your information in that new manner, whether though an "opt-out" procedure or by terminating your relationship with us.  Such changes will become effective, at the earliest, 30 days after the date of the email notifications.
Minors (those under the age of 18 years) are not eligible to use our Service. Therefore, any use by a Minor is Prohibited.
If you have questions or concerns regarding this Policy, you should contact customer service at support@ffibi.com
 
Information We Collect
We will collect the following information about you, which may include non-public personal information:
  1. Personal and financial Information you give us as a result of using the Service, such as your address, e-mail address, date of birth, telephone number, all or part of your Social Security number, bank account online login information, bank account number, and credit/debit card number. Under certain circumstances we will also collect and save information obtained from scanned copies of official identification documents, including your Passport or Drivers' License.
  2. Third party personal information you provide in order for us to facilitate funds transfers such as your recipient's full name, physical address, email address, and phone number.  However, we will not contact your recipients except as instructed by you or as required to complete a transaction. This information is only used for the sole purpose of completing your request or for whatever reason it may have been provided.
  3. Information about your usage of the Service, including your transaction history, and how and to whom you use the Service to send or receive money.
  4. Information that we lawfully obtain from third parties, such as identity verification services, electronic database services, and credit reporting agencies.
  5. Information that we indirectly obtain from you, such as information about the hardware and software you use when accessing the Service, your IP address, and the pages you access on this website, and other websites that you visit prior to accessing the Service.
First Finance International Bank Inc, and our marketing, analytics and risk partners or affiliates use technologies such as cookies and scripts. These technologies are used in analyzing trends, administering the site, tracking users' movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
We use cookies for site functionality, remembering user's settings (e.g., source & destination country), and for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies some features, or areas of our site will be limited.
As is true of most web sites, we gather certain information automatically and store it in log files.
This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you.
We use Local Storage Objects (LSOs) such as HTML5 to store content information and preferences.
Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML 5 or Flash to collect and store information.
Various browsers may offer their own management tools for removing HTML5 LSOs. To manage Flash LSOs, check your browser settings.
We collaborate with a third party to manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish not to have this information used for the purpose of serving you interest-based ads, you may opt-out. Please note this does not opt you out of being served ads. You will continue to receive generic ads.

Why We Collect Information
We collect Personal and Non-Personal information for the following purposes:
  1. To process your transactions
  2. To verify your identity
  3. To collect payment for your use of the service
  4. To track, improve and personalize our services, content, and advertising
  5. To troubleshoot problems with the service
  6. To comply with applicable laws and regulations, such as those relating to "know-your-customer," and anti-money laundering requirements
  7. To detect and prevent fraud and other illegal uses of the service
  8. To send you marketing notices, service updates, and promotional offers
  9. To collect survey information that will be used to monitor or improve the use of our service and overall customer satisfaction
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

How We Share Information with Others
We will share your personal information with third parties only in the ways that are described in this privacy policy. We do not sell or rent the information we collect to third parties for their promotional purposes. These companies are authorized to use your personally identifiable information only as necessary to provide these services to us.
Nevertheless, we may share information about you (including nonpublic, personal information) with:
  1. Third-party service providers under contract with FFIBI that help us with our business operations, such as transaction processing, fraud prevention, marketing, market research, and validation of information provided. These third parties are prohibited from using your information for their own separate business purposes.
  2. In the event of the sale, acquisition or merger of some or all of our assets, your personal information might be a part of the transferred assets. We shall notify you in the event of such an occurrence, as well as any choices you may have regarding your personal information, by placing a notice on our website.
    • Law enforcement, government officials or other third parties, but only in connection with a formal request, subpoena, court order, or similar legal procedure; and,
    • When we believe in good faith that disclosure is necessary to comply with the law, prevent physical harm or financial loss, report suspected illegal activity, or to investigate violations of our User Agreement.
  3. Other third parties that you consent or direct, which may include you authorizing an account linking for a third-party service, account and/or platform.
  4. For the purposes of this privacy policy, an "account linking" with such a third party is a connection you authorize or enable between your FFIBI account and a non-FFIBI account, payment instrument, or platform that you lawfully control or own. When you authorize such a connection, FFIBI and the third party will exchange your personal information and other information directly. Examples of account connections include connecting your FFIBI account to a third-party data aggregation or financial services company, if you provide such company with your account login credentials.
  5. If you connect your FFIBI account to other banking or similar accounts, directly or through a third-party service provider, we may have access to your account balance and account and transactional information, such as purchases and funds transfers.  If you choose to create an account linkage, we may receive information from the third party about you and your use of the third party’s service. We will use all such information that we receive from a third party via an account connection in a manner consistent with this privacy policy.
  6. Information that we share with a third party based on an account connection will be used and disclosed in accordance with the third party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third party that will gain access to your personal information as part of the account connection.
    Access Your Information
    You can access, modify, delete, or update your personal information submitted on our Website by logging into your account and changing your preferences, by emailing our Customer Support at support@ffibi.com or by contacting us by telephone at the contact information listed below.  We will respond to your request to access within a reasonable timeframe.

Research Participants and Compassionate Giving Programs
Personal information we collect: If you participate in any research projects for us (by phone, in-person, electronic survey or otherwise), we will hold your name, contact details and any other personal information you choose to give us when taking part in our research projects.
Using your personal information.  We will use this information for our legitimate interests namely to conduct our research projects which may also help us to improve and/or develop our products and services.
Sharing your personal information. We will share this information with:
  • Our staff (but their use shall be limited to the performance of their duties and in line with the reason for processing)
  • Other companies within our group
  • Our platform, database, and website hosting suppliers to enable them to maintain, protect, support, and host those solutions which are used to store our research
  • Various third parties who provide software and tools which are used to operate our business (including email, instant messaging, document/contract management and file-sharing)
  • Third parties in the event of the sale, acquisition, or merger of some or all of our assets if your personal information is part of the transferred assets (we shall notify you in the event of such an occurrence, as well as any choices you may have regarding your personal information, by placing a notice on our site)
Retaining your personal information. We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal information, we consider (amongst other things):
  • Obligations and/or retention periods imposed on us by applicable laws and/or our regulators
  • The amount, nature, and sensitivity of the personal information
  • The potential risk of harm from unauthorized use or disclosure of your personal information, and
  • The purposes for which we process your personal information and whether we can achieve those purposes through other means
Notice to Customers who reside in California.
The California Consumer Privacy Act (CCPA) exempts certain nonpublic personal information which is covered by the Gramm-Leach Bliley Act (GLBA), a federal privacy law that applies to financial institutions, like First Finance International Bank Inc. What this means is that your nonpublic personal information that you provide to us to obtain our Service, that results from any transaction you make using our Service, or that we otherwise obtain about you in connection with us providing our Service to you (GLBA Personal Information), is not subject to the various requirements set out in the CCPA. We do not collect nonpublic personal information about you that is outside a Transaction or the provision of our Services.
Please be assured that we take the privacy of your GLBA Personal Information very seriously. Your GLBA Personal Information is protected under the GLBA which places certain obligations on us, and affords you certain rights, all of which are set out in this Policy.
The rights you have in the event that your non-encrypted or non-redacted GLBA Personal Information is subject to unauthorized access and exfiltration, theft, or disclosure as a result of our failure to implement and maintain reasonable and appropriate security procedures and practices remain.

Security
We employ industry accepted standards in protecting the information you submit to us on our Website.
We have put in place SSL (Secure Socket Layer) encryption technology to protect your sensitive information such as bank account number, credit card number, date of birth and Social Security Number, transmitted through our Website. We also require a username and password from each user who wants to access their information on our Website. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.
If you have any questions about security related to our website, you can contact us via email at support@ffibi.com

Choices You Can Make About Our Use of Your Information
Federal and State Laws allow you to restrict the sharing of your personal information in certain instances. However, these Laws also recognize the fact that that you cannot restrict all types of sharing. Because we have chosen to refrain from certain types of data sharing, the only type of sharing of your personal information that you may restrict is as follows: You may opt-out from promotional emails to you by selecting the "Unsubscribe" function present in each email we send you.

Links to 3rd Party Sites
Our Site includes links to other web sites whose privacy practices may differ from those of FFIBI. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any web site you visit.


Chat
We use a chat feature to answer questions about our service and assist you with our website's functionality. If our chat feature is offline, we will collect your name and email address so that we may reply to your request.


Social Media Widgets
Our web site includes social media features, such as the Facebook Like button and widgets, such as the share this button or interactive mini programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the company providing it.


Import Contacts
You can import contacts from your Gmail and Yahoo Mail to invite them to become members of our site. We do not collect the username and password for the email account you wish to import your contacts from as you provide it directly to Gmail and Yahoo and after your approval, they send us your email contacts. At your instruction, we will send an email invite and at most one reminder email in addition to the original invite.


Referrals
If you choose to use our referral service to tell a friend about our site, we will ask you for your friend's name and email address. We will automatically send your friend an email and at most one reminder email inviting him or her to visit the site. FFIBI stores this information for the sole purpose of sending this email and tracking the success of your referral.
Your friend may request that we remove this information from our database.


Online Adds Advertising / Google Analytics Services
We may use third-party analytics services on our Services, such as Google Analytics. The information we obtain through the Services may be disclosed to or collected directly by these services. To learn more about Google Analytics, please visit https://www.google.com/policies/privacy/partners/.


Children’s Privacy
Our Services are designed for a general audience and are not directed to children. In connection with the Services, we do not knowingly solicit or collect personal information from children under the age of 16 without parental consent. If you believe that a child under age 13 may have provided us with personal information without parental consent, please contact us as specified in the CONTACT US section of this Privacy Policy.

LINKS TO THIRD PARTY SERVICES ANF FEATURES
For your convenience and information, our Services may provide links to other online services, and may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by FFIBI, we are not responsible for these third parties’ information practices.
If you are a FFIBI Customer and decide to open an account with us, knows that we are using ShuftyPro for our KYC and AML services. ShuftyPro will collect your personal information in order to proceed to your identification. By using the ShuftyPro service, you acknowledge and agree that ShuftyPro will collect and use your personal information in accordance with ShuftyPro’s privacy policy, which is available at https://shuftipro.com/privacy-policy


If you are a FFIBI Customer and decide to use our services, knows that we are using ComplyAdvantage for our AML Monitoring Services. ComplyAdvantage will collect your personal information in order to monitor your activity. By using the FFIBI service, you acknowledge and agree that ComplyAdvantage will collect and use your personal information in accordance with ComplyAdvantage’s privacy policy, which is available at https://complyadvantage.com/terms-and-conditions/#privacy-cookies

If you are a FFIBI Customer and elect to connect your bank account to our services Cash Flow Solutions, Inc. (“Ribbit”) feature in the Services, Ribbit may collect your information from financial institutions. By using the Ribbit service, you acknowledge and agree that Ribbit will collect and use your personal information in accordance with Ribbit’s privacy policy, which is available at https://portal.followthefrog.com/Home/PrivacyPolicy
 
Complaints
If you have a complaint, contact First Finance International Bank Inc. customer service by phone at 1 (888) 363-1895; or by email at support@ffibi.com

Contact
You can contact us with any questions or concerns at: First Finance International Bank Inc., 252 Ponce de León Ave, Suite 1702, Hato Rey, San Juan, PR 00918
 
Email: support@ffibi.com
Phone: 1 (888) 363-1895
Updated March 09, 2021


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