California Consumer Privacy Notice

ARROW BANK NATIONAL ASSOCIATION
California Consumer Privacy Notice

Last Updated: December 31, 2024

This Privacy Notice may be amended or updated from time to time to reflect changes in our Personal Information processing activities, or changes in applicable law. When a change is made, we will post the updated version of this Privacy Notice to the following sites: www.arrowbank.com/disclosures. All changes will become effective as of the Last Updated date listed at the top of the Notice. We encourage you to regularly check these websites to review any changes which we may make, and to review our Arrow Bank National Association (“ABNA”) Digital Privacy Notice [www.arrowbank.com/website-privacy-policy], which covers our collection and use of information when you visit those websites.

This Policy does not apply to any personal information that we collect from you in connection with products or services that you obtain for personal, family, or household purposes. If you have a financial product or service with us primarily for personal, family or household purposes, please review ABNA’s Privacy Notice, which describes how ABNA processes your personal information in connection with these products and services.

To obtain a version of this notice in larger print, please call (518) 793-4121.

Section 1: Categories of Personal Information We Currently Collect and Have Collected Within the Last 12 Months

We obtain the categories of Personal Information listed above from:

• you or your authorized agents directly at account opening;
• documents that you provide to us;
• third parties that interact with us in connection with the services we perform (e.g., credit bureaus);
• during account maintenance from you or your authorized agent on forms as required by law.
• We may also obtain your Personal Information from advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, and social networks.

We retain your Personal Information for the life of your customer relationship with us. Once your customer relationship is terminated, we will continue to retain your Personal Information only for as long as it is needed for the purposes set forth in this Privacy Notice, and for no longer than the maximum time period allowable under applicable law and regulation.

Section 2: Disclosure of Personal Information

We use and disclose for our business purposes the categories of Personal Information, including Sensitive Personal Information, relating to California residents as cited in Section 1 of this Notice to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business or commercial purposes, including the following:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services providing analytic services, facilitating event management and execution, managing our real estate portfolio, or providing similar services reasonably expected by the consumer who requests those services;
• To prevent, detect and investigate security incidents that compromise the availability, authenticity, integrity or confidentiality of stored or transmitted personal information;
• To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions;
• Helping to ensure security and integrity to the extent the use of Personal Information is reasonably necessary and proportionate for these purposes;
• For short-term, transient use such as locating a branch or ATM;
• To ensure the physical safety of natural persons;
• To verify or maintain the quality or safety of a product, service, and to improve, upgrade, or enhance the product or service;
• Debugging to identify and repair errors that impair existing intended functionality;
• Undertaking internal research for technological development and demonstration; and
• Complying with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reflecting legal or regulatory guidance, codes or opinions).

With respect to each category of Personal Information that we disclosed for a business purpose, the categories of persons or entities to whom we disclose that Personal Information are:

• ABNA Bank Affiliates and Subsidiaries;
• Service Providers and Contractors who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure, customer service, email delivery, auditing, marketing, marketing research activities, credit financing, event management, and real estate management;
• Other Service Providers and Contractors who provide services such as payment, banking and communication infrastructure, storage, legal expertise, tax expertise, real estate expertise, appraisal expertise, notaries and auditors, who promote the bank and its financial services and products to customers and other prospective buyers;
• Other Service Providers and Contractors who enable customers to conduct transactions online and via mobile devices, support mortgage and fulfillment services, vehicle loan processes and aggregators (at the direction of the customer);
• Other persons or entities to whom we transfer Personal Information as an asset that is part of a merger, acquisition or other transaction in which such other person or entity assumes control of all or part of the business;
• Government Authorities as required by laws and regulations; and
• Other persons or entities with which you may use or direct us to intentionally interact or to which you may use or direct us to intentionally disclose your Personal Information.

We do not disclose Personal Information to any other categories of third parties.
ABNA does not sell your Personal Information, therefore any rights that may be afforded to you under CCPA related to the selling of your Personal Information do not apply.

Section 3: Your Legal Rights

Subject to applicable law, you may have the right to exercise the following:

• The right to request access to, or copies of, your Personal Information that we have collected, used, or disclosed for the previous 12 months.
• The right to request deletion of your Personal Information that we process subject to certain exemptions.
• The right to correct inaccurate Personal Information

Household Requests - We currently do not collect household data. If multiple members of the household make a right to access or right to deletion request, we will respond as if the requests are individual requests.

To exercise rights under the CCPA, you must be a current resident of State of California. Only you, your authorized agent (a person or business entity registered with the California Secretary of State to conduct business in that state), or a person or entity to whom you have granted Power of Attorney to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

To exercise your access, correction or deletion rights call toll-free 1-866-248-6366, contact your relationship manager, or visit www.arrowbank.com.

We must verify your identity in order to process your request. We do this by verifying your name, address, and the last four digits of your Social Security Number, so please include this information in your request. We may reach out for additional information to complete this process.

Please also include your email address if you wish to receive your response via email, as well as the nature of your request (access to, correction or deletion of your data). We will acknowledge receipt of your request within ten days and will provide a response to your request within 45 days.

Authorized Agent

You may appoint an Authorized Agent to submit a request on your behalf. In order to do so, you must provide the appropriate documentation to ABNA or Arrow Financial Corporation (“AFC”) (Power of Attorney or proof of filing with the Secretary of State). In order for your authorized agent to act on your behalf, they must supply the appropriate documentation and verify their identity at the time they place the request.

Please note there are instances in which ABNA is required to maintain, or otherwise is not required to delete, your Personal Information. For example, ABNA is not required to delete your information if it is being used:

• To complete a transaction or provide a good or service requested by you;
• To detect security incidents or protect against malicious, deceptive, fraudulent, or illegal activity;
• To enable solely internal uses based on your relationship with us, such as a Do Not Solicit request;
• To comply with a legal obligation, such as federal recordkeeping requirements; or
• Internally, in a lawful manner that is compatible with the context in which you provided the information.

California Non-Discrimination

California prohibits businesses from discriminating against you for exercising any rights under the CCPA, including, but not limited to, by:

• Denying you goods or services;
• Charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Providing you a different level or quality of goods or services; or
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Consumer Rights Requests Metrics

ABNA, Arrow and their subsidiaries received [0] access, correction, or deletion requests, and have denied [0], during the 2023 calendar year. ABNA, Arrow, and their subsidiaries responded to such requests within [45] days, on average.

Section 4: Defined Terms

Questions about our Privacy Practices

If you have questions or concerns about our privacy notices or practices, please contact us toll-free at 1-866-248-6366.