Last Updated: July 29, 2024
The Huntington National Bank ("Huntington," "we," "our", or "us") understands the importance of data privacy and protecting Your Personal Information.
This Mobile Banking Application Privacy Policy ("Mobile App Privacy Policy") describes how we collect, use, and otherwise process Your Personal Information on connection with any of our Mobile Applications (each an "App"), and tells You about Your data privacy rights and how the law protects You.
This Mobile App Privacy Policy DOES NOT apply to information that:
- We collect offline or on huntington.com.
- You provide to or is collected on a website owned or operated by Huntington or a third party that You may access through the App.
- You provide to or is collected by any third party. These third parties may have their own privacy policies, which we encourage You to read before providing information on or through them.
By using the APP, You hereby represent and warranty that You (i) are at least 13 years of age, (ii) Reside in the United States of America, and (iii) acknowledge, understand, and agree to this Mobile App Privacy Policy.
FOR CUSTOMERS OF HUNTINGTON FINANCIAL-RELATED SERVICES USED PRIMARILY FOR PERSONAL, FAMILY, OR HOUSEHOLD PURPOSES, OUR COLLECTION AND USE OF YOUR PERSONAL INFORMATION COLLECTED THROUGH THE APP IS SUBJECT TO FEDERAL LAW APPLICABLE TO FINANCIAL INSTITUTIONS, SUCH AS THE GRAMM–LEACH–BLILEY ACT (GLBA). To learn more, please see our U.S Consumer Privacy Notice.
Interpretation and Definitions
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural. For the purposes of this Mobile App Privacy Policy:
- "Account" means a unique account created for You to access the App or parts of the App.
- "Cookies" are small files that are placed on Your computer, mobile device, or any other device by a website, containing the details of Your browsing history on that website among its many uses.
- "Device" means any device that can access the App such as a computer, a cell phone, or a digital tablet.
- "Personal Information" is any information that relates to an identified or identifiable individual, including but not limited to personally identifiable information, financial and payment information, authentication information, phonebook, contacts, device location, SMS and call related data, inventory of other apps on the device, microphone, camera, and other sensitive device or usage data.
- "Service Provider" means any natural or legal person who processes data on behalf of Huntington. It refers to third-party companies or individuals employed by Huntington to facilitate the App, to provide the App on behalf of Huntington, to perform services related to the App, or to assist Huntington in analyzing how the App is used.
- "Usage Data" refers to data collected automatically, either generated by the use of the App or from the App infrastructure itself (for example, the duration of a page visit).
- "You" means the individual accessing or using the App or that individual’s legal representative, or other legal entity on behalf of which such individual is accessing or using the App, as applicable.
App Permissions
In order to provide certain features of the App, the App will request Your prior permission to access Your Device as follows:
Contacts
- Permission to access and collect information from your device: Read your contacts.
- Purpose of permission: Person to Person payment, Recipient contact information used to facilitate payments.
- What happens if you don't give or you revoke permissions? You will not be able to select recipient contact information, requiring manual entry of contact information.
Approximate Location
- Permission to access and collect information from your device: Access your approximate location.
- Purpose of permission: Location is used to populate Branch and ATM locator and for fraud prevention and security.
- What happens if you don't give or you revoke permissions? Branch and ATM Locator will not function and app features such as Mobile Deposit and Zelle® may not be available.
Precise Location
- Permission to access and collect information from your device: Access your precise location.
- Purpose of permission: Location is used to populate Branch and ATM locator and for fraud prevention and security.
- What happens if you don't give or you revoke permissions? Some features such as Branch and ATM locator, Mobile Deposit, and Zelle® may not function optimally.
Storage
- Permission to access and collect information from your device: Download or save files to Your Device.
- Purpose of permission: Downloading or storing eStatements or other files accessed or received through the App.
- What happens if you don't give or you revoke permissions? User may not be able to download and/or save file and/or document requested.
Camera
- Permission to access and collect information from your device: Take a photo using Your Device’s camera.
- Purpose of permission: The permission is used for Mobile Check Deposit, specifically the pictures taken for Mobile Check Deposit are used/shared to process the item.
- What happens if you don't give or you revoke permissions? You will not be able to take a picture of an item, and will not be able to use Mobile Check Deposit to deposit Your check.
YOU CAN ENABLE OR DISABLE YOUR PERMISSIONS TO ACCESS AND COLLECT INFORMATION FROM YOUR DEVICE AT ANY TIME, THROUGH YOUR DEVICE’S SETTINGS.
Types of Personal Information We Collect in the App
Personal Information You Provide to Us
While using the App, we may ask You to provide us with certain Personal Information that can be used to contact or identify You, which may include, but is not limited to, Your email address; first name and last name; Registration Data (e.g., username and password); transaction information; telephone number; address; and Usage Data.
Personal Information Collected Via the App
While using the App, we may automatically collect certain information that may include, but is not limited to:
- Usage Data
- Device data, such as the type of Device You use, the Internet Protocol (IP) address of Your Device, Your Device’s operating system type and version, information about other applications installed on Your Device, the type and version of Internet browser You use, Your unique Device identifiers, Your Device’s manufacturer and model, Your Device’s screen resolution, Your Device’s RAM and disk size, Your Device’s CPU usage, the type of Your Device (e.g., phone, tablet, or computer), Your Device’s language settings, Your Device’s mobile carrier, Your Device’s radio/network information (e.g., WiFi, LTE, 5G), general location information such as city, state, or geographic area, and other diagnostic data.
- Online activity data, such as pages or screens You viewed, how long You spent on a page or screen, the time and date of Your visit, the website You visited before browsing to the App, navigation paths between pages or screens, information about Your activity on a page or screen, access times, and duration of access.
- Cookies, which are text files that websites store on a visitor’s Device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping You navigate between pages efficiently, remembering Your preferences, enabling functionality, and helping us understand user activity and patterns.
- Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
- Local storage technologies that provide cookie-equivalent functionality but can store larger amounts of data, including on Your device outside of Your browser in connection with specific applications.
- Location Information. If You have enabled location services on Your phone and agree to the collection of Your location when prompted by the App, we will collect Your location information when You use the App; for example, to provide our fraud detection services, finding a Huntington location, and Your use of Zelle®, or Mobile Deposit. If You do not want us to collect this information, You may decline the collection of Your location when prompted or adjust the location services settings on Your device. If You do not agree to location sharing, You will not have access to some features of the App.
Use of Your Personal Information
Huntington may use Your Personal Information collected through the App for the following purposes:
- To provide the financial services You request through the App.
- To provide and maintain the App, including to monitor the usage of the App.
- To manage Your Account: to manage Your registration as a user of the App. The Personal Information You provide can give You access to different functionalities of the App that are available to You as a registered user.
- To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To manage Your requests: To attend and manage Your requests to us.
- To protect our rights and interests and the rights and interests of our customers and partners, participate in legal and administrative proceedings and regulatory processes, defend ourselves and our interests, and respond to law enforcement, other legal authorities, and requests that are part of a legal process.
- To comply with applicable laws and regulations, including requirements regarding security, anti-terrorism, anti-bribery, customs, immigration, and similar matter.
- For other purposes: We may use Your Personal Information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our App, products, services, marketing, and Your experience.
Sharing Your Personal Information
We may share Your Personal Information in the following situations:
- With Service Providers: We may share Your Personal Information with Service Providers to monitor and analyze the use of our App, for payment processing, to contact You.
- For business transfers: We may share or transfer Your Personal Information in connection with, or during negotiations of, any merger, sale of Huntington assets, financing, or acquisition of all or a portion of our business to another company.
- With Affiliates: We may share Your Personal Information with our affiliates, in which case we will require those affiliates to honor this Mobile App Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
- With business partners: We may share Your Personal Information with our business partners to offer You certain products, services or promotions.
- With other users: when You share Your Personal Information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
- With Your consent: We may disclose Your Personal Information for any other purpose with Your consent.
Please note that we strive to ensure that all third parties, including Service Providers and business partners, who may have access to Your Personal Information provide the same or equal protection of such information as stated in this Mobile App Privacy Policy.
Retention of Your Personal Information
Huntington will retain Your Personal Information only for as long as is necessary for the purposes set out in this Mobile App Privacy Policy. We will retain and use Your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain Your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Huntington will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the App, or we are legally obligated to retain this data for longer time periods.
We will delete Your Personal Information when we are no longer required to retain that information or, in some instance, if You request we delete that information in accordance with the requirements of and subject to the limitations of Huntington’s Mobile App Privacy Policy.
Security of Your Personal Information
The security of Your Personal Information is important to us, and we seek to protect the security of Your Personal Information. HOWEVER, NO INFORMATION SYSTEM CAN BE FULLY SECURE, AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION. MOREOVER, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO THE APP OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY PERSONAL INFORMATION AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT THAT MAY COMPROMISE THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR PERSONAL INFORMATION CAUSED BY A THIRD PARTY. The safety and security of Your Personal Information also depends on You. Where we have given You, or where You have chosen, a username and password to access the App, You are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately (and in any event within twenty-four (24) hours) if You have reason to believe that the confidentiality of Your App username or password has been compromised. You acknowledge and agree that we may contact You via email or other electronic communications in the event we are legally required to notify You of a data security incident or event related to Your Personal Information.
Children’s Privacy
The App is not intended for use by anyone under the age of 13. We do not knowingly collect Personal Information from anyone using the App under the age of 13. If You are a parent or guardian and You are aware that Your child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers.
Links to Other Websites
The App may contain links to other websites that are not operated by us. If You click on a third-party link, You will be directed to that third party’s site. We strongly advise You to review the privacy disclosures of every website You access. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
Your Privacy Rights
FOR CUSTOMERS OF HUNTINGTON FINANCIAL-RELATED SERVICES USED PRIMARILY FOR PERSONAL, FAMILY, OR HOUSEHOLD PURPOSES, OUR COLLECTION AND USE OF YOUR PERSONAL INFORMATION COLLECTED THROUGH THE APP IS SUBJECT TO FEDERAL LAW APPLICABLE TO FINANCIAL INSTITUTIONS, SUCH AS THE GRAMM–LEACH–BLILEY ACT (GLBA). To learn more, please see our U.S. Consumer Privacy Notice.
If You are eligible pursuant to certain U.S. state privacy laws, You may have the following rights related to the Personal Information that Huntington has collected.
- Right to Know (Specific Pieces of Personal Information). You may have the right to know the specific pieces of Your Personal Information that we have collected about You.
- Right to Know (Categories of Personal Information). You have the right to know (i) the categories of Your Personal Information we have collected from You; (ii) the categories of sources from which Your Personal Information is collected; (iii) the categories of Your Personal Information we have sold or disclosed for a business purpose; (iv) the categories of third parties to whom Your Personal Information was sold or disclosed for a business purpose; and (v) the business or commercial purpose for collecting or selling Your Personal Information.
- Right to Delete. You have the right to request that we delete Your Personal Information that we have collected and retain.
- Right to Correct. You have the right to request that we correct inaccurate Personal Information that we have collected and retain about You.
- Nondiscrimination. You have the right not to be subject to discrimination for asserting Your privacy rights afforded to You under law.
Huntington does not engage in any activities related to the following rights:
- Opt Out of Sale or Sharing: The right to opt out of the sale or sharing of Personal Information.
- Limit Use or Disclosure of Sensitive Personal Information: The right to limit the use or disclosure of "sensitive personal information" as the term is so defined under applicable law.
How to Exercise a Privacy Right and What to Expect
Methods
For those eligible pursuant to certain U.S. state privacy laws, Huntington provides two methods for submitting a rights request:
- Option 1: Submit an online request
- Option 2: Call our designated "Personal Information Rights Request" line at (866) 644-9790, daily 6:00 a.m. to midnight ET.
Verification
To verify Your request made at an option above, we will ask You to provide information (for example: name, date of birth, address, email address, phone number, and last 4 of Your Social Security Number). We will use the identifying information You provided to attempt to verify Your identity. If necessary, we may also use a third-party provider to assist in verification.
Opt-Out Preference Signal
Huntington does not engage in any activity related to the right to opt out of the sale or sharing of Your Personal Information. As a result, Huntington does not process an opt-out preference signal.
Authorized Agent
You will be asked, to the extent permitted by law, to submit a notarized affidavit or other statement authorizing Your delegate to act on Your behalf. If You do not submit the notarized affidavit or other statement within 10 business days, Your case may be closed.
What to Expect
In the event You submit a rights request, You can expect the following:
- We will determine whether Your request can be fulfilled, which may include, verifying Your identity, determining whether You have reached Your request limit (no more than two for the preceding 12 months), determining whether You reside in a state that provides these rights, and determining whether You are ineligible under any other exception.
- We may take up to 45 days to fulfill Your request.
- We may also extend the time to fulfill Your request by another 45 days (for a total of 90 days); however, we will notify You when we make this extension.
- We will provide You with Your response via Your chosen communication method (mail or email).
Please note, Your submission does not guarantee that we will fulfill Your request.
Complaints
To the extent required by law, You may file a complaint about our data processing activities with Your local authorities, which may include the following:
- The Colorado Attorney General at: https://coag.gov/file-complaint/
- The Connecticut Attorney General at: https://portal.ct.gov/DCP/Complaint-Center/Consumers---Complaint-Center
- The Montana Attorney General at: https://dojmt.gov/consumer/
- The Nevada Attorney General at https://ag.nv.gov/Complaints/CSU_Complaints___FAQ/
- The Oregon Attorney General at: https://www.doj.state.or.us/consumer-protection/contact-us/
- The Texas Attorney General at: https://www.texasattorneygeneral.gov/consumer-protection
- The Virginia Attorney General at https://www.oag.state.va.us/contact-us/contact-info
However, we would like the opportunity to resolve any concern You may have with respect to our data processing activities, and we will seek to resolve any concern You may have.
Exceptions
Applicable state law may provide exceptions that impact Your rights under this notice. For example, most state privacy laws provide an exception to compliance with some of the rights under this Notice if the personal information is regulated under the federal Gramm-Leach-Bliley Act or if the personal information is being collected by a financial institution or its affiliates that is subject to the federal Gramm-Leach-Bliley Act.
Changes to this Mobile App Privacy Policy
We may update this Mobile App Privacy Policy from time to time. We will notify You of any changes by posting the new Mobile App Privacy Policy on the App. We will let You know via email and/or a prominent notice on the App, prior to the change becoming effective and update the "Last updated" date at the top of this Mobile App Privacy Policy. You are advised to review this Mobile App Privacy Policy periodically for any changes. Changes to this Mobile App Privacy Policy are effective when they are posted on this page.
Contact Us
If You have any questions or concerns about this Mobile App Privacy Policy, please contact us at privacy@huntington.com.