Mobile Banking Privacy Policy

Mobiliti Mobile Banking (the “App”) – powered by Fiserv – helps you control your credit and/or debit cards through your mobile device, making it easy to manage your finances on the go.

The App allows you to:
• get real-time balances for your accounts
• manage your money
• view your transactions and statements
• make transfers
• pay your bills and manage billers
• deposit a check
• receive alerts
• manage cards

This Privacy Policy, in combination with other relevant privacy notices that we provide to you (e.g., pursuant to financial privacy laws), inform you of the policies and practices regarding the collection, use and disclosure of any personal information that we and our service providers collect from or about users in connection with the App’s website and mobile application (the “Services”).

**Rev. 02/2024**
FACTS
What Does Winter Hill 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 • Payment history Income • Credit history Account balances • Credit scores For former customers we will continue to adhere to the same privacy policies and practices 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 Winter Hill Bank chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information	Does Winter Hill 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 products 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	No	We don’t share
For our affiliates’ everyday business purposes – information about your creditworthiness	No	We don’t share
For non-affiliates to market to you	No	We don’t share

Questions?

Call toll-free 800-444-4300 or Contact Us

What We Do
How does Winter Hill 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 limit access to your personal information to those employees for whom access is appropriate.
How does Winter Hill Bank collect my personal information?	We collect your personal information, for example, when you: Open an account • Apply for a loan Deposit money • Use your debit card Pay your bills 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 non-affiliates 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. Winter Hill Bank has no affiliates.
Non-affiliates	Companies not related by common ownership or control. They can be financial and non-financial companies. Winter Hill Bank does not share with non-affiliates so they can market to you.
Joint Marketing	A formal agreement between non-affiliated financial companies that together market financial products or services to you. Our joint marketing partners include Insurance Companies.

Other Important Information

The security measures that we have in place also comply with the Massachusetts Data Protection Law which is designed to safeguard the personal information of Massachusetts residents.

For Vermont and California Residents Only: The information practices we have described above comply with federal law. Vermont and California laws place additional limits on sharing information about their residents. If you are a Vermont or California resident, we will automatically limit the disclosure of your information within and outside our family of companies as permitted or required by applicable law or regulation.

For Nevada Residents Only: We are providing you this notice pursuant to state law. You may request to be placed on our internal Do Not Call list by calling, 617-666-8600 or 800-444-4300. For more information on this Nevada law, contact Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 East Washington Avenue, Suite 3900, Las Vegas, NV 89101; telephone number 702-486-3420; email: [email protected]; or Winter Hill Bank, 342 Broadway, Somerville, MA 02145.

For California Residents Only: To exercise your privacy rights under CCPA, please review our privacy policy at www.winterhillbank.com or call us at 617-666-8600 or 800-444-4300.

Mobile Applications

Winter Hill Bank (“WHB”) customers have the option of downloading the WHB Mobile application (“app”) from the App Store or Google Play Store to conduct mobile banking activities. Information collected through the WHB Mobile app includes banking transaction information and information about your mobile activity, such as when the app is opened or exited, and which pages within the app are visited. If Location Services are enabled, the WHB Mobile app will also collect geolocation data which is used to send targeted push notifications, in-app advertisements and alerts. Please note that if Location Services are enabled, the WHB Mobile app will collect this location data even when the app is closed or not in use. You may disable the app’s collection of geolocation data at any time by disabling Location Services for the app on your mobile device(s). WHB does not link the information stored within the analytics software to any personally identifiable information you submit within the app. WHB may collect information when you initiate a transaction (for example, when you upload a check image while using WHB Mobile Deposit). This information will only be used or shared in order to provide the service that you requested.