PRIVACY AND INFORMATION SECURITY POLICY
1. General
The terms “we,” “our,” and “us” in this Privacy and Information Security Policy (this “Website Privacy Policy”) refer to Rockland Trust Company and/or its affiliates, divisions, or subsidiaries (collectively, “Rockland”).
We respect and value your privacy. This Website Privacy Policy describes and applies to the information we collect from you when you visit this Website. This Website Privacy Policy generally describes the information we collect, and how we collect, share, use, and protect your information. This Website Privacy Policy does not apply to off-line activities. If you are a customer, who has opened an account or obtained a financial product or service from us for personal, family, or household purposes, our general Privacy Policy, may apply to you as well and further explains how we may use your information. By visiting or using this Website you are accepting the practices described in this Website Privacy Policy and consent to our use of cookies and similar technologies as described in this Website Privacy Policy.
2. Types of Information We Collect
When you visit this Website, we and our service provider receive and collect certain information about you. The information that is received and collected depends in part on what you do when you visit this Website. You may be able to improve your experience on this Website when you provide us information – for example, by using certain products or services, conducting transactions online, making inquiries, or requesting further information about a product or service or an account.
Information takes many forms and includes records stored on computers and magnetic or optical media and data transmitted across networks. Some of the information you may submit is personally identifiable information or “Nonpublic Personal Information,” but much of it is not. Specifically, Rockland may obtain personally identifiable information and Nonpublic Personal Information about you in connection with providing a financial product or service to you for personal, family or household purposes. Personally identifiable information and Nonpublic Personal Information may include, but is not limited to, name, address, social security number, phone number, account number or balance, debit card usage, and insurance policy coverage and may be provided to Rockland directly by you or obtained from transactions with Rockland or others.
When you use this Website, we also automatically collect information on the type of computer or other devices (including mobile devices) you use to access this Website (collectively, a “Computer”) and your Computer's operating system version. We collect this information to detect security threats, to analyze web traffic, to better understand how our customized Website interacts with you, and to simply understand how this Website is being used. We, with our vendors and other third parties (such as ad networks), may automatically collect certain information about the computer or devices you use to access this Website, even if you are not logged into your account.
The information that is automatically collected may (but does not necessarily) include: (a) with respect to your Computer, information regarding the IP Address, browser types, operating system, and Internet service provider; and (b) clickstream information regarding the way you interact with this Website, including, but not limited to, pages you visit, the number of “clicks,” material viewed and downloaded, time spent on each page, the information you enter, the dates and times you visit or use this Website, and certain performance data.
Please note that this Website may not respond to “Do Not Track” browser settings, however, this Website does not monitor your online activities after you leave this Website.
3. Use of Information Collected
We may use the information collected for a number of purposes, for example, to better service your requests and/or inquiries, monitor usage and/or performance of this Website, improve the customer experience of this Website, ensure technological compatibility with your Computer, protect against fraud or identity theft, protect against or investigate suspected online criminal activity, or conduct aggregate analyses on usage patterns.
Rockland uses the Nonpublic Personal Information it collects in a variety of ways depending on the nature of the customer’s relationship including, but not limited to, delivering various financial services; processing, servicing and maintaining accounts and transactions; responding to customer requests; resolving disputes; and generally fulfilling Rockland’s obligations to the customer. In addition, the information may be used to verify a customer’s identity as required by the USA PATRIOT Act.
4. Disclosure of Personally Identifiable Information and Nonpublic Personal Information
Rockland does not disclose any Nonpublic Personal Information to third parties, except as permitted or required by law, rules or regulations. Rockland may disclose Nonpublic Personal Information to other financial institutions with which it has a joint marketing agreement or similar arrangement. Nonpublic Personal Information may be disclosed to affiliated and nonaffiliated third parties to enable them to provide business services for Rockland, including marketing services, which help to evaluate requests for products or services, perform general administrative activities and/or assist in processing transactions. The affiliated and nonaffiliated third parties are required to protect the confidentiality and security of this information and to use it only in accordance with Rockland’s instructions.
In the event that a customer decides to close an account or otherwise becomes an inactive customer, Rockland will continue to follow its privacy and information security practices.
5. Cookies
This Website uses cookies, messages given to a Web browser by a Web server. The browser then stores the cookie in a text file. The use of cookies is a standard practice among websites to collect or track information about your activities while using the website. Rockland and/or our third party advertising service providers may place cookies or similar files on your hard drive for many of the reasons listed in this Website Privacy Policy while visiting this Website. Most people do not know that cookies are being placed on their Computers when they visit websites, because browsers are typically set to accept cookies. You can choose to have your browser warn you every time a cookie is being sent to you or you can choose not to accept cookies.
You can also delete cookies from your Computer at any time. If you refuse cookies, the functionality of this Website may be impacted or become non-functional. Since every browser and Computer is different, you will need to follow your browser’s instructions for disabling or deleting cookies.
This Website uses two types of cookies:
Session cookies which are temporary cookies that are automatically deleted whenever you close all open Web browser windows. Session cookies are used to ensure that you are recognized when you move from page to page within the site and that any information you have entered is remembered. Session Cookies do not collect information from the user’s computer. They typically will store information in the form of a session identification that does not personally identify the user.
Persistent cookies that remain permanently on the cookie file of your computer. These persistent cookies contain the user id used to access the site along with encrypted identification values associated with the User ID in conjunction with the particular device (e.g. the PC, mobile device or other computer from which you accessed this Website). These persistent cookies are used to provide enhanced security measures, personalize your experience on the site, monitor overall web site performance and provide overall site usage reporting. Cookies placed on your device do not contain any personal information, such as an email address or name.
Although your browser may permit you to reject cookies, cookies are required to login and navigate within this Website. If you should choose to disallow cookies you will be required to respond to challenge questions each time you log on.
We protect your account information from unauthorized access, to the best of our ability, by placing it on the most secure portion of this Website. That’s why you have to enter a unique user name and password, as well as either registering your device with us or answering at least two (2) additional personal knowledge based questions each time you want to access this secure Website. We also utilize a site authentication feature (personalized image and description), which allows you to verify you are visiting this Website. Your password should never be shared with anyone.
None of our other clients can access your data, and only a restricted set of our employees can access your data in order to provide service to you. When you access password protected portions of our site using a Web Browser, Secure Sockets Layer (SSL) technology is used to protect your communications through server authentication and data encryption. We upgrade and maintain our technology on an ongoing basis.
6. You Also Have a Role in Protecting Your Information
You also play a critical role in protecting your information by maintaining up to date Computer security protections and by reviewing your statements promptly. You have several other options when deciding how you can best protect your personally identifiable information. One option is simply not to volunteer it. For more information on how to protect your personal information, the Federal Trade Commission’s websites, located at www.ftc.gov, www.ftc.gov/idtheft, http://www.business.ftc.gov/, and www.onguardonline.gov, offer useful information about how to protect your personally identifiable information and for more information on protecting your electronic information, please visit www.staysafeonline.org.
We understand that some of our customers choose to share their log-in credentials with other service providers which offer services such as account aggregation (consolidating all their financial information from various providers in one place), tax preparation, and investment advice. If you choose to share your log-in credentials, such third parties will have full access to your account and your personal information, including Nonpublic Person Information. You will remain responsible and liable for any and all use of your log-in credentials by such third parties and will be deemed to have authorized all actions and transactions by any such third party even if you are unaware of such actions or transactions. If you determine to revoke the access of any such third party, we suggest you immediately change your log-in credentials.
Rockland will never e-mail you or send you electronic communications to request sensitive personal information or account information over the Internet or by any other means. To help protect yourself against online fraud – if you suspect that an unsolicited e-mail or other electronic communication is fraudulent, please contact us toll-free at 1-508-732-7032 or by e-mail at (customer.service@rocklandtrust.com).
7. Information Security
Rockland and its third party providers maintain physical, electronic and procedural safeguards to protect Information. Rockland and its third party providers are committed to the following principles to ensure the confidentiality and protection of Information: maintaining Information security; taking into consideration business requirements, risk mitigation, industry practice, and legal and regulatory requirements; protecting all forms of Information; implementing security measures that are effective, consistent and cost justified; effective implementation by management and staff for adherence to policies and procedures; monitoring advances in security technology to ensure that Rockland and its third party providers are providing an appropriate level of privacy and safety; and appropriate reporting of deviations from Rockland policies and procedures or security breaches.
Rockland and its third party providers’ employees are required to protect the confidentiality of Information and observe policies and procedures in accordance with their job function. Employees may only access Information when there is an appropriate reason to do so, such as to administer or offer Rockland products and services and may be subject to disciplinary rules for noncompliance with policies and procedures.
For security and other purposes, Rockland and our third party providers reserve the right to block or disable access to any account at any time without notice.
8. Children’s Privacy
We do not knowingly collect personal information from individuals under the age of 18 who may visit this Website.
9. Changes.
We may periodically make changes or modify this Website Privacy Policy, so please review it periodically for changes. Your use of this Website after we have modified this Website Privacy Policy indicates your agreement to the modified terms.