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Metropolitan Commercial Bank Online Privacy Policy

We at Metropolitan Commercial Bank (“MCB,” “we,” “us,” or “our”) have created this Online Privacy Policy (“policy”) because we know that you care about how information you provide to us is used and shared. This Online Privacy Policy relates to the information collection and use practices of MCB in connection with our website located at https://www.mcbankny.com (the “Website”).

Metropolitan Commercial Bank Online Privacy Policy

By visiting our Website, you are agreeing to the terms of this Online Privacy Policy.

The Information We Collect

By visiting our Website, you are agreeing to the terms of this Online Privacy Policy.

1. Personal Information

When you request information about our products and services or sign up or submit a request to receive information from us, you may be required to provide us with personal information about yourself, such as your name, company, title, address, e-mail address, and phone number. We do not collect any personal information from you when you access and use the Website for informational purposes unless you provide such information voluntarily. We do not recommend that you provide any personal information to us through the Website except for use of our online services as described immediately below. All information we collect and/or receive under this section is collectively called “Personal Information.” When you use our online services through our Website, such as online banking or mobile banking, we and third party service providers acting on our behalf may request Personal Information from you solely for the purpose of providing the service to you. This personal information is, in general, limited to your company ID, user ID, facility ID, login, username, and/or password to access such online services.

2. Other Information

In addition to the Personal Information, we may collect additional information (collectively, the “Other Information”). Such Other Information may include:

a. From Your Activity. Information that we or our technology providers may automatically collect when you visit, access, and/or use the Website, such as your IP addresses, Internet service provider, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Website you visit, number of links you click while on the Website, search terms, and operating system.

b. From Cookies or Other Tracking Mechanisms. Information that we may collect using “cookie” technology or other tracking mechanisms. Cookies are small files of data that a website stores on your device so that your device will “remember” information about your visit. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them) to help us collect Other Information and to enhance your experience using the Website. If you do not want us to place a cookie on your device, you may be able to turn that feature off on your device. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the Website may not function properly. We may use tracking data to help us tailor and optimize our website and potentially provide you relevant MCB advertisements outside of our Website.

How We Use and Share the Information

We may use the Personal Information and the Other Information (collectively, the “Information”) to administer our marketing programs; to improve our Website and services to you; to request your feedback; and to inform you about our products and services.

We may also use and/or share Information as described below.

We may employ other companies and individuals to perform functions on our behalf. Examples may include providing technical assistance, customer service, and marketing assistance. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.
In an ongoing effort to better understand visitors to our Website and our services, we may analyze the Other Information in aggregate form in order to operate, maintain, manage, and improve the Website and/or our services. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and services to current and prospective business partners and to other third parties for other lawful purposes.
In order to provide our services and administer our marketing programs, we may share your Personal Information and Other Information with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.
As we develop our businesses, we may sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.
We do not sell your Personal Information to third parties. We may share your Personal Information with our (i) affiliates, parent companies, or other companies under common control with us and (ii) service providers that have agreed to confidentiality restrictions and use any Personal Information they collect on our behalf solely for the purpose of providing the contracted service to us, to confirm the status of your transactions or accounts for a legitimate third party (such as a credit bureau, a biller, etc.), or to investigate an error or potential fraud.
To the extent permitted by law, we may also disclose the Information: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of MCB or others.

Accessing and Modifying Information and Communication Preferences

You may manage your receipt of marketing and communications via e-mail by clicking on the “unsubscribe” link located on the bottom of any MCB marketing e-mail, as required by law. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases.

Protection of Information

MCB will treat as confidential any information it collects. MCB maintains an Information Security Program that provides guiding policies and procedures that promote practices and methodologies that protect the security and confidentiality of this information by limiting employee access to and use of this information. We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee that the Information that you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to or from the Website may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. For more information regarding this policy, call us at 800-852-7632.

Links to Third Party Sites and Third Party Sites

The Website may contain links to third-party websites. MCB has no control over the privacy practices or the content of these websites. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

MCB’s Investor Relations website located at https://investors.mcbankny.com/corporate-profile is hosted and operated by third party provider Q4 Inc. on behalf of MCB. Please refer to Q4 Inc.’s online privacy policy located at https://www.q4inc.com/privacy-center for more information on how your information is collected and used when you access MCB’s Investor Relations website.

When you visit pages that are “owned” by MCB through social media platforms, such as Facebook, LinkedIn, Twitter, etc., you understand that you are subject to the privacy policy of the social media platform and MCB has no control over the privacy practices, the content, or the information collected by these social media platform websites. MCB advises you to be cautious of pages on social media platforms appearing to be owned or operated by MCB but are not.

Children’s Privacy

From our web pages, we do not knowingly collect personal information from individuals under the age of 13 without obtaining verifiable consent from their parents.

For more information about the Children’s Online Privacy Protection Act (COPPA), visit the FTC website: www.ftc.gov.

Changes to This Online Privacy Policy

This Online Privacy Policy is effective as of the date set forth below. We may change this policy from time to time. By accessing and/or using the Website after we make any such changes to this policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Online Privacy Policy in effect at the time we collect the Information. Please refer back to this Online Privacy Policy on a regular basis.

Effective Date: April 27, 2021

Metropolitan Commercial Bank California Consumer Privacy Act Privacy Policy and Notice

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The California Consumer Privacy Act (“CCPA”) applies to “California Residents” only and provides them with control over the Personal Information that businesses collect about them, including the right to know what information is collected on them and how it is used and shared, subject to exceptions; the right to delete such personal information, subject to exceptions; the right to opt-out of the sale of their personal information, if applicable; and the right to non-discrimination for exercising their rights under the CCPA.

This CCPA Privacy Notice outlines how Metropolitan Commercial Bank (“MCB”, “we”, “us”, “our”) collects, uses, and shares Personal Information in compliance with the CCPA and supplements MCB’s Privacy Policy only for California Residents. “You” and “your” refer to California Residents.

Definitions

California Resident is defined under the CCPA as a natural person who resides in California, even if the person is temporarily outside of the state, and does not include a corporation or other business entity.

Personal Information is defined under the CCPA as information that identifies, relates to, or could reasonably be linked with you or your household. The CCPA provides exclusions for certain Personal Information, such as Personal Information collected, processed, sold or disclosed pursuant to the Gramm-Leach-Bliley Act or the federal Fair Credit Reporting Act.

Collection Of Personal Information

The categories of personal information MCB may have collected about you in the preceding 12 months is as follows:

Identifiers such as a real name, alias, postal address, internet protocol address, online identifier, email address, social security number, driver’s license number, passport number, or other similar identifiers.
Personal information, as defined under the California customer records law, such as bank account number, debit card number, or any other financial information.
Characteristics of protected classifications under California or federal law, such as race, color, religion, national origin, gender, marital status or age.
Commercial information, such as records of personal property or products or services purchased, obtained, or considered.
Biometric information.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with our internet website.
Geolocation data, such as internet protocol location.
Audio, electronic, visual, or similar information.
Professional or employment-related information, such as employment history.
Education information, such as schools attended and dates of attendance.
Inferences drawn from any of the information identified above to create a profile about you, such as your preferences and characteristics

We may have collected the Personal Information listed above from the following categories of third party sources:

Directly from you or your representative.
Government entities where public records are obtained.
Consumer data resellers, such as consumer credit reporting agencies and data verification services.

Purposes for Collecting Personal Information

Depending on our relationship with you, MCB’s business purpose for collecting Personal Information may include:

Performing services for you, including maintaining or servicing accounts, providing customer service, processing or fulfilling transactions, verifying your information, processing payments, or providing financing.
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Complying with laws, regulations and internal policies, including for purposes of auditing, accounting, internal investigations, and legal processes.

Disclosure/Sharing of Personal Information

The following is a list of categories of personal information MCB may have shared with third parties for our business purposes in the preceding 12 months:

Identifiers such as a real name, alias, postal address, internet protocol address, online identifier, email address, social security number, driver’s license number, passport number, or other similar identifiers.
Personal information, as defined under the California customer records law, such as bank account number, debit card number, or any other financial information.
Characteristics of protected classifications under California or federal law, such as race, color, religion, national origin, gender, marital status or age.
Commercial information, such as records of personal property or products or services purchased, obtained, or considered.
Biometric information.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with our internet website.
Geolocation data, such as internet protocol location.
Audio, electronic, visual, or similar information.
Professional or employment-related information, such as employment history.
Education information, such as schools attended and dates of attendance.
Inferences drawn from any of the information identified above to create a profile about you, such as your preferences and characteristics

MCB may have disclosed the Personal Information described above for our business purposes to the following categories of third parties:

Service providers and vendors to provide products and services to you, such as account transactions and maintenance, and online and mobile banking services.
Data verification services, such as to verify your identity.
Government entities as required by laws and regulations.

Your Rights to Make Requests

The Right to Know: If you are a California Resident, you have the right to request that we disclose to you:

The categories of Personal Information we have collected about you.
The categories of sources from which the Personal Information is collected.
The business or commercial purpose for collecting the Personal Information.
The categories of third parties with whom the business shares Personal Information.
The specific pieces of Personal Information it has collected about you..

The Right to Delete: A California Resident also has the right to request that we delete any Personal Information that we have collected from you.

Both of these rights are subject to exceptions. For examples, we are not required to comply with a request to delete Personal Information if the Personal Information is necessary for us to complete a transaction for which the information was collected, or if we must retain the Personal Information to comply with a legal obligation. Certain Personal Information also is not subject to the CCPA.

How to Submit Requests

California Residents may submit a Request to Know and/or a Request to Delete Personal Information described in this CCPA Privacy Policy and Notice, subject to limitations and exceptions, by:

(1) By calling us at 800-852-7632 (toll-free);
(2) Submitting a request on MCB’s website, at https://www.mcbankny.com/ccpa-request; or
(3) Sending an email to [email protected]

When we receive a Request to Know and/or Request to Delete from you we will verify your identity to confirm the Personal Information we maintain relates to you. We may request information from you, not limited to your name, address, and contact information, in order to verify your identity. We may use a two-step process for online Requests to Delete where you must first submit the Request to Delete and then second, we will separately confirm you want your Personal Information deleted. If you submit a request on behalf of another individual, we may require proof that you are authorized to submit such a request on behalf of that individual.

Sales of Personal Information

MCB has not sold Personal Information about California Residents in the preceding 12 months. To our knowledge, we never sell the Personal Information of California Residents under 16 years of age.

Non-Discrimination

You have the right to be free from discriminatory treatment for exercising your privacy rights under the CCPA.

Contact for More Information

For questions or concerns about MCB’s privacy policies and practices, send an email to [email protected].

Effective: January 1, 2020
Updated: April 19, 2021

Consumer Privacy Notice

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FACTS	What Does Metropolitan Commercial Bank Do With Your Personal Information?
Why?	Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?	The types of personal information we collect and share depend on the product or service you have with us. This information can include: • Social Security number • Account balances • Transaction history • Account transactions • Checking account information • Wire transfer instructions When you are no longer our customer, we continue to share your information as described in this notice.
How?	All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Metropolitan Commercial Bank chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information	Does Metropolitan Commercial Bank share?	Can you limit this sharing?
For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus	Yes	No
For our marketing purposes – to offer our product and services to you	Yes	No
For joint marketing with other financial companies	Yes	No
For our affiliates’ everyday business purposes – information about your transactions and experiences	Yes	We don’t share
For our affiliates’ everyday business purposes – information about your creditworthiness	No	We don’t share
For nonaffiliates to market to you	No	We don’t share

Questions?

Call 1-866-363-8226 or go to www.mcbankny.com

What we do

How does Metropolitan Commercial Bank protect my personal information?	To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We also maintain other physical, electronic and procedural safeguards to protect this information and we limit access to information to those employees for whom access is appropriate.
How does Metropolitan Commercial Bank collect my personal information?	We collect your personal information, for example, when you • Open an account • Apply for financing • Provide account information • Give us your contact information • Show your driver’s license We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
Why can’t I limit all sharing?	Federal law gives you the right to limit only • sharing for affiliates’ everyday business purposes – information about your creditworthiness • affiliates from using your information to market to you • sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

Definitions

Affiliates	Companies related by common ownership or control. They can be financial and non-financial companies. • Metropolitan Commercial Bank does not share with our affiliates.
Nonaffiliates	Companies not related by common ownership or control. They can be financial and non-financial companies. • Metropolitan Commercial Bank does not share with nonaffiliates so they can market to you.
Joint marketing	A formal agreement between nonaffiliated financial companies that together market financial products or services to you. • Our joint marketing partners include credit card account companies.

Other Important Information

For Alaska, Illinois, Maryland and North Dakota Customers. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing – without your authorization.
For California Customers. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing – without your authorization. We will also limit our sharing of personal information about you with our affiliates to comply with all California privacy laws that apply to us. Further, we may collect personally identifiable information about you through our website, including but not limited to your first and last name, home address, e-mail address, telephone number, or any other identifier that permits the physical or online contacting of a specific individual. If we change our privacy policy for our website, you will be notified as required by law.
For Massachusetts, Mississippi and New Jersey Customers. We will not share personal information from deposit or share relationships with nonaffiliates either for them to market to you or for joint marketing – without your authorization.
For Vermont Customers.
• We will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures.
• Additional information concerning our privacy policies can be found at www.mcbankny.com or call 1-866-363-8226.