BBVA Wallet Application Privacy Policy Effective date: September 14, 2015 This Privacy Policy describes our practices related to the use, storage and disclosure of information we collect from or about you in the course of providing the Wallet Service through our Wallet Application. We reserve the right to modify this Privacy Policy at any time and without prior notice. The privacy policy link within the Wallet Application will direct your device to the most recent version of this Privacy Policy. This Privacy Policy is not a contract and does not create any legal rights or obligations. Terms defined in the BBVA Compass Wallet Terms of Use shall have the same meaning in this Privacy Policy, unless otherwise stated below. Through the Wallet Application, you may use your Eligible Mobile Device to (i) view balances and recent transactions for each Payment Card; and (ii) access additional services that may be available through the Wallet Application. What information does the Wallet Application obtain and how is it used? User Provided Information The Wallet Application obtains the information you provide when you download and register the Wallet Application. Registration with us is mandatory in order to be able to use the basic features of the Wallet Application. You can use the Wallet Application after registering for Online Banking or registering for Mobile Banking from within the Wallet Application. During registration, you generally provide: your check card number and PIN, name, email address, phone number, user name, password and other registration information. You may also be asked to provide your Payment Card number and its CVV2 number, your partial or complete social security number, and your date of birth to set up the Wallet Service. We use this registration information to create a unique user profile for you, which is required to access and use the Wallet Service. We may also use the contact information you provide us to notify you from time to time of important information and updates related to the Wallet Application. When using the Wallet Application, you generally provide information we must use to complete requested transactions. Such transaction-related information may include: account information, transfer amounts, dates, frequency, and security codes. Automatically Collected Information and Device Access - In addition, the Wallet Application may collect certain device information automatically, such as the type of mobile device you use, your mobile device s unique device ID, the IP address of your mobile device, your mobile operating system, and certain information about the way you use the Wallet Application. The Wallet Application may also access the following information when needed to perform services that you request: access to phone operations to call
phone numbers without user s intervention, access to phone information (e.g. phone number and serial number of device, whether a call is active, the phone number being called); internet access to create network sockets; access to contact (address) data stored on the phone; access to information about the state of Wi-Fi and all networks; access extra location provider commands; access to device storage to write, modify, or delete content. This information is only accessed to provide the services within the Wallet Application that you choose to use. What kinds of notifications does the Wallet Application send me and how can I manage them? When you are logged into the Wallet Application, you may receive a message asking if you would like to allow notifications. Such notifications are a way for an application to deliver information, including alerts, sounds and icon badges, to your Eligible Mobile Device. Notifications can be delivered whether or not you are currently logged-in to and/or using the application and whether or not your device is in locked and/or sleep mode. The following are examples of the types of notifications we may send, depending on your Payment Card and/or your preferences: Fraud-related Transaction Alerts, which may ask you to verify certain transactions and include details of such transactions, such as merchant name and transaction amount; Transaction Alerts, which may include transaction details such as merchant name, transaction amount and information regarding declined transactions, if any; Rewards and Offers related notifications, which may include earned rewards, offers available to you, and redemption confirmations; and/or Other information related to your Payment Card and/or the Wallet Service. You can manage notifications by turning on/off transaction and other alerts for all Payment Cards or specific cards in the Wallet Application settings. You may also be able to manage notifications via the privacy settings on your Eligible Mobile Device. Notifications and alerts outside of the Wallet will not be turned off. Even if you turn off notifications and alerts for the Wallet, you may still receive notifications and alerts from other applications you have with us, such as any online banking application. BBVA Compass does not charge a fee for such notifications, but fees may be imposed by your carrier and/or internet service provider depending on your data plan. Does the Wallet Application collect precise real time location information of the device? If you allow it, the Wallet Application may collect precise information about the location of your device through GPS, cell tower triangulation, wi-fi access point technology, blue-tooth beacons, crowd-sourced positioning, or other similar technology. This location data may be used to provide mapping, navigational, and/or location-relevant marketing and advertisement information. We will not share your current location with other users, except as you choose (e.g. posting location and activity information to social media). We will only share your current location information with third-parties as necessary to provide you the locationbased service. Prior to the Wallet Application collecting and using precise real time location information, the Wallet will ask
you if you would like allow the application to access such information. If you do not allow it, you may not be able to use some functions of the Wallet. If you allow the Wallet to collect and use such information and you later do not want the Wallet Application to use your location information for the purposes above, you should turn off the location services for the Wallet Application in your mobile device settings and/or within the Wallet Application. The Wallet Application may also use near real-time transaction and payment network information that identifies your Payment Card as being recently used at a particular merchant and/or merchant location. This implicit location information does not actually tell us where your device is located, but allows us to infer that your device might be at the place. This implicit location information may be used by the Wallet Application to display fraud-related, credit-related, and Rewards and Offers related notifications to you. Do third parties see and/or have access to information obtained by the Wallet Application? Yes. Subject to applicable law and regulation, we may share information collected by the Wallet Application with third parties only in the ways that are described in this Privacy Policy. We may disclose user-provided and automatically collected Information: as required by law, such as to comply with a subpoena, or similar legal process; when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; and with our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this Privacy Policy. How is information collected by the Wallet Application used? We use the information collected about you and your device to maintain and provide you with the Wallet Service, to respond to your questions and instructions, to maintain the integrity of our network and address security issues, to detect fraud, to investigate or take action regarding violations or suspected violations of law or our terms, and to improve the Wallet Service. What are my opt-out rights? You may refrain from using Wallet Application features that collect specific types of information. You can stop all collection of information by uninstalling the Wallet Application. You may use the standard uninstall processes available as part of your mobile device or via the removal features provided in your mobile application store or network. Once you have uninstalled the Wallet Application, any preferences that you previously set within the Wallet Application are deleted, such as whether you allowed us to send you push notifications. How does the Wallet Application respond to Do Not Track signals? Do Not Track (DNT) is a privacy preference that users can set in recent versions of most major web browsers, including Firefox 5+, Internet Explorer 9+, Safari 5.1+, and Chrome. DNT allows users to inform
web services that they do not want certain information about their webpage visits collected across websites. The Wallet Application does not operate within your web browser and does not receive or respond to DNT signals. Whether you have turned on DNT or not, the Wallet Application does not collect personally identifiable information (PII) about your online activities over time and across third party websites or online services. Nor do third parties use the Wallet Application to collect PII about your online activities over time and across third party websites. Data Retention Our operational systems will store user-provided data for as long as you use the related feature of the Wallet Application, unless you choose to delete it. Please note that some or all of the user-provided data may be required in order for the Wallet Application to function properly, and we may be required to retain certain information by law. If you close your profile established for Online and Mobile Banking, we will retain certain account data, such as transaction history and account balances, for a reasonable time to facilitate any request to reopen your profile. Children We do not use the Wallet Application to knowingly collect data from or market to children under the age of 13. If a child under 13 has provided us with personal information without parental or guardian consent, the parent or guardian may contact us at 1-800-273-1057. We will delete such information from our files within a reasonable time and unsubscribe the child from any promotional contact opportunities. Security Protecting the confidentiality of your information is very important to us. We have established appropriate physical, electronic, and procedural safeguards to protect information we collect from or about our users. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Wallet Application. These safeguards are regularly reviewed to protect against unauthorized access, disclosure and improper use of your information and to maintain the accuracy and integrity of that information. Changes This Privacy Policy may be updated from time to time, as new versions of the Wallet Application are released and the Wallet Service is modified or expanded. The Privacy Policy link within the Wallet Application will direct your device to the most recent version of this Privacy Policy. You may also visit www.bbvacompass.com/compass/policy/privacy.jsp to view the current copy of this Privacy Policy. We will notify you electronically of any material changes to our Privacy Policy in accordance with the BBVA Compass Wallet Terms of Use. Your use of the Wallet Application following an update to this Privacy Policy means that you accept the updated Policy. Your Consent By using the Wallet Application, you are consenting to our processing of user-provided and automatically
collected information as set forth in this Privacy Policy, now and as amended by us. "Processing, means using cookies on a computer/hand held device or using information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, as necessary to provide the Wallet Service to you. Contact us - If you have any questions regarding privacy while using the Wallet Application, or have questions about our practices, please contact us at 1-800-273-1057. BBVA Compass is a trade name of Compass Bank, a member of the BBVA Group. Compass Bank, Member FDIC.