Privacy Policy for BMO Harris Liberty Bank

Last updated: [Insert Date]

1. Introduction

This Privacy Policy explains how BMO Harris Liberty Bank ("BMO Harris Liberty Bank", "we", "us", or "our") collects, uses, discloses, and protects your personal information when you use our banking services, including our websites, online banking platforms, and mobile applications (collectively, the "Services").

We operate as a bank in US and are committed to protecting your privacy and handling your information in a transparent, secure, and lawful manner.

By using our Services, including any access to or use of our online services such as bmo, bmo login, bmo harris, bmo harris login, bmo bank, bmo bank login, bmo harris bank login, and bmo bank online, you acknowledge that you have read and understood this Privacy Policy.

2. Who We Are and How to Contact Us

BMO Harris Liberty Bank is a banking institution established and operating in US.

If you have any questions about this Privacy Policy or the way we process your personal information, you can contact us at:

Privacy Officer BMO Harris Liberty Bank [Insert Postal Address] Email: [Insert Email Address] Telephone: [Insert Telephone Number]

3. Information We Collect

We collect and process various types of personal information depending on how you interact with us and which Services you use. The categories of personal information we may collect include:

3.1 Information You Provide Directly

• Identification details: name, date of birth, nationality, government-issued identification numbers, and other identification documents.
• Contact details: residential and mailing address, email address, telephone number.
• Account information: account numbers, customer IDs, user names, and similar identifiers.
• Authentication data: security questions and answers, passwords, PINs, and other credentials.
• Financial information: income, employment details, tax information, credit history, transaction history, card numbers (where applicable), and related financial data.
• Communications: information contained in your communications with us by phone, email, post, secure message, or through our online and mobile platforms.

3.2 Information Collected Automatically When you access or use our websites, online platforms, or mobile applications (including for bmo bank login, bmo harris bank login, and bmo bank online), we may automatically collect:

• Technical data: IP address, browser type and version, device identifiers, operating system, time zone setting, and other technical information.
• Usage data: pages visited, features used, links clicked, login timestamps, and other activity on our Services.
• Location data: approximate location derived from your IP address or, when enabled, more precise location from your device.

3.3 Information from Third Parties We may receive personal information about you from:

• Credit reference agencies and fraud prevention agencies.
• Publicly available sources and databases.
• Other financial institutions.
• Our service providers and business partners, where permitted by law.

4. Legal Basis for Processing (For Users in US)

We process your personal information only where we have a lawful basis to do so. Depending on the context, we may rely on the following legal grounds:

• Performance of a contract: to provide you with banking services and manage your accounts.
• Legal and regulatory obligations: to comply with banking, anti-money laundering, fraud prevention, and other regulatory requirements.
• Legitimate interests: to manage our business, improve our Services, prevent and investigate fraud or misuse, and ensure network and information security, where such interests are not overridden by your rights.
• Consent: where you have given us explicit consent, for example, for certain marketing activities. You can withdraw your consent at any time as described in this Policy.

5. How We Use Your Information

We use personal information for the following purposes:

• To open, administer, and manage your accounts and banking relationships with us.
• To provide and operate our Services, including bmo login, bmo harris login, bmo bank login, bmo harris bank login, and bmo bank online.
• To process transactions, payments, deposits, withdrawals, transfers, and other banking operations.
• To authenticate your identity and verify your eligibility for certain products and services.
• To respond to your enquiries, requests, and complaints, and to provide customer support.
• To manage our relationship with you, including notifying you about changes to our terms, conditions, or policies.
• To monitor, detect, and prevent fraud, financial crime, and unauthorised or illegal activities.
• To comply with applicable laws and regulatory requirements, including know-your-customer, anti-money laundering, and sanctions screening obligations.
• To improve, test, and enhance our Services, including our online platforms and mobile apps.
• To conduct internal reporting, analytics, and business planning.
• To send you marketing communications about products and services that may be of interest to you, where permitted by law and in accordance with your preferences.

6. Cookies and Similar Technologies

We use cookies and similar tracking technologies on our websites and online platforms to:

• Enable essential site functionality, including secure login and session management.
• Understand how you use our online Services, including interactions with bmo bank online features.
• Improve performance, security, and user experience.
• Provide personalised content and, where permitted, tailored marketing.

You can manage cookies through your browser settings and, where applicable, through our cookie management tool. Certain cookies are essential for the operation of our online Services; disabling them may affect the functioning of bmo login, bmo harris login, bmo bank login, and similar features.

7. How We Share Your Information

We may share your personal information with:

• Our group companies and affiliates, where necessary for providing our Services and managing our business.
• Service providers who perform services on our behalf, such as IT hosting, payment processing, customer support, analytics, printing, and mailing.
• Credit reference agencies, fraud prevention agencies, and similar organisations to help prevent fraud and financial crime.
• Other financial institutions and payment networks involved in processing your transactions.
• Professional advisers, such as lawyers, auditors, and consultants, where necessary for legitimate business purposes.
• Regulators, law enforcement agencies, courts, and other authorities when required by law or to protect our rights or the rights of others.
• Third parties in connection with a business transaction, such as a merger, acquisition, sale of assets, or reorganisation, subject to appropriate safeguards.

We will not sell your personal information for monetary consideration. Where we share information with third parties, we require them to handle your data in accordance with applicable data protection laws and appropriate contractual safeguards.

8. International Transfers

Given the global nature of financial services and technology infrastructures, your personal information may be transferred to, and processed in, countries outside US, including countries that may have different data protection standards.

When we transfer personal information to other countries, we will ensure that appropriate safeguards are in place, such as:

• Adequacy decisions by relevant authorities.
• Standard contractual clauses or equivalent contractual protections.
• Other lawful transfer mechanisms under applicable data protection laws.

9. Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes described in this Privacy Policy, including to:

• Provide you with banking services and manage your accounts.
• Comply with legal, regulatory, and accounting requirements.
• Resolve disputes and enforce our agreements.

The exact retention period depends on the nature of the information and the legal and regulatory requirements that apply to us. After the retention period has expired, we will securely delete or anonymise your personal information.

10. Security of Your Information

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, loss, misuse, alteration, or destruction. These measures include:

• Encryption and secure transmission protocols for online banking sessions, including bmo bank online and related login pages.
• Access controls, authentication procedures, and role-based permissions.
• Physical and logical security measures for our facilities and systems.
• Regular monitoring, testing, and security assessments.

While we take reasonable steps to protect your information, no system or transmission of data over the internet can be guaranteed to be completely secure. You are responsible for maintaining the confidentiality of your login details, passwords, and PINs and for notifying us promptly of any suspected unauthorised access to your accounts.

11. Your Rights

Subject to applicable law, you may have the following rights regarding your personal information:

• Access: to obtain confirmation of whether we process your personal information and to request a copy of the information we hold about you.
• Rectification: to request correction of inaccurate or incomplete personal information.
• Erasure: to request deletion of your personal information in certain circumstances.
• Restriction: to request restriction of processing in certain circumstances.
• Objection: to object to processing based on our legitimate interests or for direct marketing purposes.
• Data portability: to receive certain personal information in a structured, commonly used, and machine-readable format and to transmit it to another controller where technically feasible.
• Withdraw consent: where we rely on your consent for processing, to withdraw that consent at any time.

To exercise your rights, please contact us using the details provided in the "Who We Are and How to Contact Us" section. We may need to verify your identity before responding to your request.

12. Marketing Communications

We may use your personal information to send you marketing communications about our products, services, and offers, including those relating to our online services such as bmo login, bmo harris login, bmo bank login, bmo harris bank login, and bmo bank online, where permitted by law and in line with your preferences.

You can opt out of receiving marketing communications at any time by following the unsubscribe instructions in our emails or by contacting us directly. Even if you opt out of marketing communications, we may still send you non-marketing messages related to your accounts, transactions, or our ongoing business relationship with you.

13. Children’s Privacy

Our Services are not directed at children under the age of 18, and we do not knowingly collect personal information from children under 18 without appropriate consent or authorisation as required by law. If we learn that we have inadvertently collected such information, we will take steps to delete it as soon as reasonably practicable.

14. Third-Party Websites and Services

Our Services may contain links to third-party websites, applications, or services that are not operated or controlled by BMO Harris Liberty Bank. This Privacy Policy does not apply to those third parties, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party services you access through our links.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons. When we make changes, we will revise the "Last updated" date at the top of this Policy. In some cases, we may provide additional notice (such as by email or through our online banking platforms).

Your continued use of our Services, including bmo bank online and related login services, after any updates to this Privacy Policy constitutes your acceptance of the revised Policy.

16. How to Complain

If you have concerns about how we handle your personal information, please contact us first so we can try to resolve the issue. You also have the right to lodge a complaint with the relevant data protection authority in US or in your place of residence or work, where applicable.

[Insert Details of Relevant Supervisory Authority]

By using our Services, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and disclosure of your personal information as described herein.