U.S. STATE PRIVACY NOTICE

OakNorth Bank plc (“We”, “us”, “our” “OakNorth” or “Bank”) is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority (Financial Services Register No. 629564). Registered in England No. 08595042. Registered Office: 57 Broadwick Street, London, W1F 9QS.

OakNorth is committed to protecting your privacy and security.  We’ve created this U.S. State Privacy Notice (“Notice”) to provide information for United States’ residents that visit our website, oaknorth.com (the “Site”), apply for any service or product of the Bank and from whom the Bank shall collect and process the personal data to provide the service and/or product, as well as for previous and current customers of the products and/or services (“you” or “your”). By using the Site, our services or products, or otherwise interacting with OakNorth, you accept and agree to the practices this Notice descries

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing of personal information. Federal law also requires us to tell you how we collect, share, and protect your personal information.  We also may comply with certain state laws that supplement or add to the privacy protections afforded by federal law.  Please read this notice carefully to understand what we do.

You can contact our Business Desk:

i) By writing:
OakNorth Bank plc
445 Park Avenue, 6th Floor
New York, NY 10022

ii) By emailing:
questions@oaknorth.com

You can contact our Data Protection Officer directly by emailing: DPO@oaknorth.co.uk

COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION

We collect various types of personal information, categorised and exemplified below. Some data elements may fit into multiple categories. This information is gathered or generated through multiple sources, depending on our services and relationship with you. While most information is obtained directly from you, other sources are also indicated.

WHAT DOES OAKNORTH DO WITH YOUR PERSONAL INFORMATION?

In the section below, we list the reasons we share customers’ personal information; the reasons we choose to share such information; and whether you can limit sharing of such information.

We may transfer personal information to other countries, for example, for customer service or to process transactions.

RETENTION OF PERSONAL INFORMATION

When determining the retention period for personal information, we consider our legal and regulatory obligations, our retention policies as well as our legitimate business interests. These interests include managing our services, preventing fraud, responding to regulatory or supervisory inquiries, and establishing, exercising, or defending legal claims, disputes, or complaints.

COOKIES AND OTHER TRACKING TECHNOLOGIES

When you visit our website, we will set essential cookies on your device but request your consent to set non-essential cookies. You can find out more about how we use cookies in our Cookie policy – US – OakNorth Bank

“DO NOT TRACK” REQUESTS

Our Site currently does not respond to “do not track” or similar signals.

HOW DOES OAKNORTH PROTECT MY INFORMATION?

To protect your personal information, we take commercially reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered, or destroyed. However, no data protection procedures are entirely infallible. As a result, while we strive to protect your personal information, we cannot guarantee that it will be 100% secure. Your transmission of your information to OakNorth thus is done entirely at your own risk.

THIRD-PARTY WEBSITES

Our Site may contain links to other sites, including those of third parties or partners.  While we seek to link only to sites that share our high standards and respect for privacy, we cannot be responsible for the privacy practices other websites use.  By accessing other third-party websites or applications through our Site, you are consenting to the terms and privacy policies of those websites.  It is possible that other parties may collect personally identifiable information about your online activities over time and across different web sites when you use our Site.

USERS ONLY OF LEGAL AGE OF MAJORITY

Our Site and services are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Services or on or through any of its features/register on the Site or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or username you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13 without verifiable parental consent, please contact us at questions@oaknorth.com.

ADDITIONAL CHOICES

If you decide at any time that you no longer wish to receive marketing emails from us, please follow the “unsubscribe” instructions provided in such emails. Please note that even if you unsubscribe, we may continue to send transactional or administrative emails, such as legally required, regulatory, billing, or service.

INTERNATIONAL VISITORS

If you are accessing the Site or services from outside the United States, please be aware that your information may be transferred to, stored, or processed in the United States. The data protection and other laws of the United States and other countries may not be as protective as those in your state, province, or country.

CHANGES TO THIS POLICY

We shall inform you by way of email if our privacy notice has changed because of an update in the law or if there are changes to the nature of the processing of your personal information. We will not email you when we make minor changes (such as to correct typographical errors, or to add information about other products or services which do not affect the processing of personal data), but we shall make the updated privacy notice available on our website at all times.  Your continued use of our Site and interaction with OakNorth shall be deemed your agreement that your information may be used in accordance with the new notice.

ADDITIONAL STATE RIGHTS

Depending on your state of residence, you may have additional rights relating to your personal information.  However,  you should note that this section does not apply to personal information governed by specific sectoral privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) and its implementing regulations, the California Financial Information Privacy Act (FIPA), the Driver’s Privacy Protection Act of 1994, and other federal or state laws that may pre-empt a state data privacy law.

We have previously disclosed each category of personal information listed in the “Our Collection, Use and Disclosure Practices” section to one or more of the categories of recipients listed in the “Who Do We Share Data With?” sections for the business purposes listed in “Why Do We Collect This Data?” sections.

We may create, maintain, and use deidentified information, and if we do, we will not attempt to reidentify that information unless permitted by applicable law.

YOUR RIGHTS

You may have certain rights in relation to your personal information pursuant to applicable state law, such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA).  These include the right to:

1. Know the information about the personal information that we collect about you;
2. Know the manner in which we use, process and disclose your personal information;
3. Obtain the specific pieces of personal information that we have collected about you;
4. Correct inaccurate personal information that we maintain about you;
5. Delete certain personal information that we have collected about you, subject to exceptions;
6. Opt-out of the sale or sharing of your personal information to third parties under certain circumstances; and
7. Not be discriminated against as a result of exercising any of the aforementioned rights.

Although we may collect certain categories of sensitive personal information as described in “Our Collection, Use, And Disclosures Practices,” we do not use sensitive personal information in ways that state law permits you to limit.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to DPO@oaknorth.co.uk.

Selling and Sharing

The CCPA and other states’ laws require that we describe disclosures of personal information where:

1. We receive monetary or other valuable consideration (i.e., selling, as defined under the CCPA); or
2. We disclose personal information about you through our Sites to a third party for cross- context behavioural advertising (i.e., sharing, as defined under the CCPA).

We do not share personal information to third parties for cross-context behavioural advertising.

While we don’t “share” your personal information for cross-context behavioural advertising, we may disclose your personal information for allowed business purpose(s) or at your direction. For example, we share your personal information with our data hosting and storage providers. We enter into agreements with our service providers in which they can only use your information for specific purposes and are required to ensure its confidentiality. To the extent any disclosure of personal information constitutes a sale of personal information, you may opt-out of this disclosure by visiting the link at the footer of the homepage “Do Not Sell or Share My Personal Information.”

We do not knowingly sell or share the personal information of minors under 16 years of age.

Exercising Your Rights

If you would like to discuss or exercise such rights to access, delete, or correct your personal information, please contact our Data Protection Officer directly by emailing: DPO@oaknorth.co.uk

The CCPA  and other states’ laws mandate that we verify the requests we receive from you when you exercise certain rights listed above. To verify your request, we will compare the information you provide with third-party identity verification tools and confirm that any personal information pertains to you. As part of this process, we may contact you by phone after you submit your request to verify the information. You may also designate an authorized representative to exercise certain rights on your behalf. To do so, you must provide the authorized representative with power of attorney pursuant to your states’ requirements or execute other documentation as required.  The authorized representative can then make the request on your behalf by following the instructions provided. If an authorized representative submits a request on your behalf, we will contact you to verify their authority to act on your behalf.