Privacy Policy

Your Privacy Matters to Us

Wellby, your member-owned financial institution, is committed to providing a safe place to save and borrow money at very competitive rates. Wellby is equally committed to protecting consumers’ privacy.

This Online Privacy Statement applies to Wellby’s webpages, Wellby-branded social media sites, mobile applications, digital banking applications, and digital advertising campaigns, collectively referred to as a “digital property”.

The terms “Wellby,” “we,” “our,” or “us” refer to Wellby and any affiliates or subsidiaries based in the United States.

Information collected by Wellby during the application for or servicing of one of our products or services is also governed by Wellby’s Privacy Notice, which should be referenced for additional details on our privacy practices.

Wellby is a Houston-based financial cooperative serving a Houston DMA-based target market and beyond. In addition to the privacy practices described within this statement and the Wellby Privacy Notice, social media sites may have their own privacy policies that you should understand prior to using their services to interact with Wellby.

Our Online Privacy Practices

We are committed to transparency about your personal information. We ask for your consent when required, otherwise, by using our Site and Mobile Apps, you consent to the collection, use, and sharing of your personal information subject to and consistent with applicable laws and other notices you may have received based on your relationship with us.

Links to Other Sites/Third-Party Sites

We may provide links to non-affiliated third-party sites, such as credit bureaus, service providers, or merchants. If you follow links to sites not affiliated with or controlled by Wellby, you should review their privacy and security policies and other terms and conditions, as they may be different from those of our Sites and Mobile Apps. Wellby does not guarantee and is not responsible for the privacy or security of these sites, including the accuracy, completeness, or reliability of their information.

Protecting Your Personal Information

To protect personal information from unauthorized access and use, we use security measures that comply with applicable federal and state laws. These measures may include device safeguards and secured files and buildings as well as oversight of our third-party service providers to ensure personal information remains confidential and secure. In the event of a data breach, we provide timely notification, in accordance with applicable laws.

We also recognize the importance of protecting privacy where children are involved. Our Sites and Mobile Apps are not directed to individuals under the age of 13, and we request that these individuals do not provide personal information through our Sites and Mobile Apps. We do not knowingly collect personal information from children under 13. Please see our COPPA Privacy Notice and COPPA Direct Notice to Parents for more information.

Maintaining Accurate Personal Information

Keeping your personal information accurate and up to date is very important. If your personal information is incomplete, inaccurate or not current, please use the Contact Us option on our website, or Messages/Conversations within online banking and the Wellby Mobile App, or call or write to us at the telephone numbers or appropriate address for changes listed on your account statements, records, online or other account materials. You can also speak to a Wellby banker at a branch or our contact center.

Information We Collect

How We Collect Information Online

We collect personal information about you through your computer, smartphone, tablet or other mobile devices by the use of cookies and similar tracking technologies (see our Cookie Policy for details) as well as personal information you provide when you visit or use our Sites and Mobile Apps, for example when you:

• Apply for or open a new account;
• Register for a new product or service, or request information about a product or service;
• Complete a survey, contest sweepstakes, or other promotion; or,
• Use aggregation services within the Wellby digital banking platform or Mobile App to consolidate your financial account or information at one online location.

We may use service providers and vendors to process personal information for business purposes on our behalf. Service providers and vendors are contractually obligated to comply with our policies to protect information we share with them or they collect on our behalf.

The personal information we collect is limited to what is required to provide our products or services and to support legal and risk requirements. For additional information, please review the How We Use the Information We Collect section below.

What Information We Collect

When using a Wellby digital property we may collect three categories of information about you:

Personal Information: We may collect personally identifiable information about you such as your name, address, phone number(s), email address, or other information that identifies you. This includes information you provide via applications, forms, subscriptions, contest entries, or other means of collection.

Non-public Information: Through your interactions with us, such as applying for a product or service, we may collect non-public information about you such as your Social Security number, tax identification number, driver’s license number, income, Wellby user name, Wellby password, occupation, or other types of non-public information.

Online Behavior: We may collect information about the Internet Protocol (IP) address of the device(s) you use to access Wellby’s digital properties; your operating system and browser type; referral website information; your digital property usage and page views; your social media preferences (e.g. likes, interests, profile, etc.); your geolocation; and aggregate or non-personally identifiable information.

These categories of information may be collected by Wellby, or by our third-party service providers, through the use of various technologies, such as cookies, web beacons, pixel tags, or other technologies, to associate your online use of our digital properties and/or with offline personally identifiable information.

We may use information collected from a Wellby digital property to acquire additional information about you from our marketing partners or service providers. For example, when you submit an application for membership or for a financial product or service, we may use the Social Security number you provided online to access a consumer report which may contain a credit score and information about your creditworthiness to determine if you meet our underwriting guidelines.

When interacting with Wellby on a digital platform that is not owned by Wellby such as a social media site, never include sensitive personal or non-public information. Communications with Wellby about your application, membership, and accounts with us should only take place in a secure Wellby channel such as Wellby Online or Mobile Banking, or by phone with a solution specialist. Social media sites are not an appropriate place to conduct or discuss your financial transactions.

How We Use the Information We Collect

We may use the information we collect online and that which we pair it with offline to:

• Market our products and services or those of our trusted partners
• Decide about your application for a product or service
• Service, manage, or collect on your account
• Offer special deals or promotions
• Process transactions initiated by you
• Verify your identity or information you provided on an application
• Perform everyday business tasks such as data analytics, digital property experience optimization, fraud prevention, security enhancements, or product and service improvements
• Respond to your questions or inquiries
• Comply with federal, state, or local laws; civil, criminal, or regulatory investigations; or other legal requirements
• Share with our affiliates or trusted third parties in accordance with the practices described in our Privacy Notice
• Aggregate or anonymized data for analytical purposes

Information Disclosure

Wellby may disclose all the information collected, as described above, to companies that perform marketing services on behalf of Wellby or to other financial institutions with which Wellby has joint marketing or other contractual agreements. Wellby may also disclose nonpublic personal information about its members under other circumstances as permitted or required by law and as described in our Privacy Notice.

Data obtained through the short code program will not be shared with any third-parties for their marketing reasons/purposes.

Information Security

Wellby restricts access to non-public personal information about its members to Wellby team members and approved third parties working on our behalf who have a specific business purpose in utilizing member data. Wellby team members are trained in the importance of confidentiality and member privacy by maintaining physical, electronic, and procedural safeguards that comply with federal regulations and leading industry practices to safeguard members' non-public personal information.

How You Can Help Protect Your Privacy

While Wellby is committed to protecting the privacy of its members and consumers, you can help safeguard personal information by following these simple guidelines provided as examples:

• Upon receipt of a debit card or credit card, verify the information on the front, sign the back panel immediately, and activate the card. Destroy old cards immediately.
• Report a lost or stolen card(s) immediately to Wellby by calling (281) 488-7070 for during or (866) 692.9364 during off-hours.
• Always protect your card(s) by carrying only the ones you intend to use. Store all other cards in a safe place.
• Be aware of your surroundings when approaching an ATM. Make sure no one can see you enter your PIN by shielding the keypad with your hand or body.
• Memorize your PIN and keep it confidential. Do not write it on the card or keep it in your wallet.
• Make sure the merchant returns your card and check it to make sure it's your card.
• Keep your ATM transaction and check card receipts. Log them into your check register. Destroy the carbons if present.
• Never give your card information over the phone unless you initiate the call.
• Never pre-sign your checks.
• Regularly review your transaction history and report any unauthorized transactions immediately.
• Treat all your financial information as confidential and proprietary.
• Keep usernames and passwords confidential.
• Do not use the same username and password for multiple online accounts; if you use the same username and password for multiple accounts and one of those accounts is breached, all your accounts could be at risk.

Digital Wallet Terms of Use

If your mobile or other electronic devices (“Device”) hosts a digital, virtual or mobile wallet application or platform (“Wallet”) that allows you to register, validate, store and use credit card or debit card information (“Cards”) to make contactless purchases, you may add Wellby Cards to the Wallet by agreeing to these Terms of Use (the “Terms”).

You are requesting, and Wellby is providing, a process whereby Wellby allows you to photograph or otherwise input the data from your physical Cards into a Wallet on a Device (“Service”). The card data is then encrypted and each card is assigned a unique reference number thereby making it a “Virtual Card,” which when used in combination with a transaction-specific security code, can be transmitted to process your payment to a merchant. The number on the physical card is not included in the transaction.

The Wallet and the processing of Virtual Card transactions are services that are provided by third parties without any warranty from Wellby. You acknowledge that Wellby is not a party to the agreement between you and the Wallet provider or the Virtual Card processor. Wellby is not responsible for delay, interruption or other failure, maintenance, support, software issues, or any damages, including but not limited to product liability claims and regulatory matters.

Your Card Agreement Also Applies

Your Wellby Card is governed either by the Wellby terms and conditions for your deposit account if your Card is a debit card, or by the Wellby terms and conditions for your credit card, if your Card is a credit card (your “ Membership Agreement,” as applicable, which includes all disclosures and other agreements referenced by or incorporated into your Membership Agreement). If your Card is a debit card, your payment transactions using the Service are subject to all provisions governing debit card transfers in the Electronic Fund Transfer Disclosures in your Membership Agreement. These Terms supplement and are part of your Membership Agreement. If a discrepancy or inconsistency is determined to exist between these Terms and the Membership Agreement, these Terms shall control with respect to the Service, but only to the extent necessary to address the discrepancy or inconsistency.

Important Security Notice

If your Device is lost or stolen, your fingerprint identity, password, or other authentication mechanism is comprised, or you have any reason to believe fraud or theft has or could be committed in relation to your Cards, you MUST notify Wellby IMMEDIATELY at (866) 692-9364 for Wellby Debit Cards or (800) VISA-911 for Visa Credit Cards. If you fail to do so, you may be liable for part or all of the losses in connection with unauthorized use of your Cards. You might want to consider activating any Device setting that assists you with finding a lost Device, designating the Device as lost, or erasing data if it is confirmed to be lost. Don’t forget to delete your Wallet from your Device if you discard or replace your Device.

Fees

Wellby does not charge a fee for the Service. Your Device carrier may impose data, usage, text messaging, or other third-party fees. You consent to receive text messages, if necessary for Card validation.

Terms May Change

Wellby may change these Terms at any time without notice to you. The most current version will be available on the Wellby website, and you are bound by all revisions, so please review the Terms at wellbyfinancial.com from time to time. Subject to applicable law, Wellby may terminate, modify or suspend this Service, change the eligibility of Cards or update the verification process.

Online Behavioral Advertising

What is Online Behavioral Advertising?

Personal information collected from and about you online as described in this Notice is used and shared to deliver advertising and marketing, including prescreened offers of credit, which may be of interest to you.

We present tailored ads to you:

• On our Sites and Mobile Apps through banner ads and splash ads that appear as your sign-on or off of your online accounts
• In off-line channels such as branches, call centers, and through direct marketing (for example. email, mail, phone)
• On third-party sites and mobile apps not affiliated with Wellby.

How We Tailor Ads to You

• Advertising on our sites, mobile apps, and offline channels such as branches, call centers, and through direct marketing (for example email, mail, phone): We may use certain personal information about your activities on our Sites and Mobile Apps, such as pages visited and keywords entered, to help determine which of our ads or offers may be of interest to you. We may use personal information about your relationship with us (such as types of accounts, transactional information, or the state in which you bank) to help determine which advertisements or offers to present to you.
• Advertising on non-affiliated third-party sites and mobile apps:Wellby contracts with advertising companies to advertise our products and services on sites and mobile apps not affiliated with us. We may use personal information we have collected or that you have provided to assist our non-affiliated third-party sites and mobile apps to select bank ads or offers that may appeal to you, display them to you and monitor your responses. Non-affiliated third-party sites and mobile apps are not subject to Wellby Privacy Notices.

How You Can Opt-out of Online Behavioral Advertising

You have choices about how Wellby advertises to you based on your online behavior.

There is no standard for how "do not track" consumer browser settings should work for online advertising purposes. As such, we do not respond to browser "do not track" signals from browser settings. However, there are several opt-out options available to you:

• Advertising on our Sites and Mobile Apps and off-line channels such as branches, call centers, and through direct marketing (for example email, mail, phone):If you prefer we not provide you with tailored content and advertising based on your online behavior with our Sites and Mobile Apps, you may opt-out with the Cookie Consent on this Site by turning off Advertisement Cookies. See our Cookie Policy to learn more about types of cookies. Please review the important Reminders section that follows.
• Advertising on Non-Affiliated Third-party sites:Wellby participates in the Digital Advertising Alliance ("DAA") self-regulatory Principles for Online Behavioral Advertising and uses the Advertising Options Icon on our behavioral ads on non-affiliated third-party sites (excluding ads appearing on platforms that do not accept the icon). Ads served on our behalf by these companies do not contain unencrypted personal information and we limit the use of personal information by companies that serve our ads. To learn more about ad choices, or to opt-out of interest-based advertising with non-affiliated third-party sites, visit YourAdChoices layer powered by the Digital Advertising Alliance or through the Network Advertising Initiative's Opt-Out Tool layer. You may also visit the individual sites for additional information on their data and privacy practices and opt-out options. See our Cookie Policy for more information.

Reminders After Opt-Out

Please note that if you opt-out of this advertising:

• You may still receive untailored advertising from Wellby.
• When accessing online account servicing areas (i.e. after sign-in), such as Online Banking, you may receive tailored content and advertising based on your account relationships.
• Solution specialists and financial consultants may continue to use personal information collected online as described in this Notice to provide details on products and services in accordance with account agreements.
• In order for online behavioral advertising opt-outs from our Sites and Mobile Apps and on other sites to work on your device, your browser must be set to accept cookies.
• If you delete cookies, buy a new device, access our Sites and Mobile Apps or other sites from a different device, login under a different screen name, or change web browsers, you will need to opt-out again.
• If your browser has scripting disabled, you do not need to opt-out, as online behavioral advertising technology does not work when scripting is disabled.

Aggregation Services

Some companies may offer aggregation websites and services that allow you to consolidate your account information from different sources (such as your accounts with us or with other financial institutions) so that you can view it in one location or perform actions related to your accounts using their services (a "Provider"). To do this, a Provider may request you to authorize access to your Wellby accounts by providing your Wellby username and passcode or by providing your information-sharing consent directly to Wellby.

• The Provider may access, on your behalf, information about yourself, your Wellby relationship, and your accounts at Wellby.
• You should use caution and ensure that the Provider has appropriate policies and practices to protect the privacy and security of any personal information you provide or to which they are gaining access.
• Use of your information by the Provider is governed by your agreement with them, not by Wellby.
• We are not responsible for the use or disclosure of any personal information accessed by any company or person to whom you provide your site username and passcode.
• If you share your Wellby username, passcode or other information about your accounts with others, we will consider that you have authorized any transaction or action initiated by using the access information you provide.
• If you decide to revoke the authority you have given to a Provider, we strongly recommend that you change your Wellby passcode to ensure that the Provider cannot continue to access your account.
• You may revoke your consent for certain Providers through the Security Center within Wellby Online Banking.

Social Media

Wellby engages with customers on social media platforms such as Facebook, Twitter, YouTube, and LinkedIn.

• Any content you post on official Wellby managed social media pages, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms, is subject to the Terms of Use and Privacy Policies of those respective platforms.
• When interacting with official Wellby social media pages, Wellby's privacy notices, our Social Media Guidelines may apply.
• Please review the privacy policy for the specific social media service you are using to better understand your rights and obligations with regard to such content.

We may allow certain non-affiliated third-party widgets (for example social share buttons) on our sites that enable users to easily share information on another platform, such as a social media platform. The non-affiliated third parties that own these widgets may have access to information about your browsing on pages of our Sites and Mobile Apps where these widgets are placed.

Electronic Communications

Wellby will not be deemed to have accepted any electronic communication unless Wellby provides the sender of the electronic communication with an acknowledgment verifying receipt of the communication. If Wellby sends any electronic communication, Wellby will assume the communication was received intact by the intended recipient. The recipient of such message must notify Wellby if the transmission was not received or was not received in a readable format.