Mobile App Privacy Policy

Privacy Policy for Transact Bank’s Mobile App’s

Effective November 17, 2025

The directors, management, and staff of Transact Bank, N.A. are concerned about and respect the privacy of customers’ and consumers’ personal financial information. We understand that our customers provide sensitive information to Transact Bank in the course of daily business, and Transact Bank is committed to treating such information responsibly.

Transact Bank will take all steps required by law to reasonably safeguard sensitive information that has been entrusted to us by our customers. The following Privacy Policy for Transact Bank’s Mobile App’s (the “Mobile App Privacy Policy”) describes the types of “Personal Information” (i.e., information that is identifiable to a particular person) that is collected (directly or through service providers) in connection with the Transact Bank N.A. Mobile App’s downloadable application (“App”) and related services (collectively, the “Service”) offered by your financial institution (“Transact Bank”, “Bank”, “we” or “us”). This Mobile App Privacy Policy is intended to supplement the disclosures in any Privacy Policy that you may have already been presented by us in connection with online banking or other services.

1. Eligibility

   The Services are offered only to individual residents of the United States, excluding its territories, who can form legally binding contracts under applicable law. Without limiting the foregoing, the Service is not offered to minors. Other restrictions and eligibility requirements for the Service apply as described in Transact Bank’s Mobile App’s Terms of Use. We do not knowingly collect any Personal Information from or about individuals under 18 years of age. Please do not submit such information to us, and as a parent or legal guardian, please do not allow your children to submit Personal Information without your permission. By using the App or the Service, you represent that you meet these requirements and that you agree to the terms of this Mobile App Privacy Policy.

2. Types of Personal Information We May Collect

   • Personal Information You Provide to Us. We may collect Personal Information about you, which may include: name, address, e-mail address, user IDs, telephone number, account numbers, payment card expiration date, payment card identification or verification numbers, social security number, mobile device location, and other information that we can use to contact you, verify your identity, provide the functionality available through use of the App and the Service, and manage risks, such as information maintained about you by identity verification services and consumer reporting agencies, including credit bureaus, and payment and other transaction information, and history for payments and other transactions in which you participate through the Service, and any Personal Information that you may enter into information blocks present in the App interface or made available through the Service. We may collect information regarding your mobile device such as device settings, unique device identifiers, information about your location, and analytical information that may assist with diagnostics and performance. For your convenience, you may be asked to grant permission for access to your mobile device's geolocation data. This information may be collected when you use certain services that are dependent on your mobile device’s location such as the location of an ATM or in store transactions or may be accessed to detect and prevent card transaction fraud and deposit fraud. Device images/videos may be accessed when you deposit a check or use a QR code to make peer to peer payments or other payments functionality. Device contacts may be accessed when you make peer to peer payments or other payments functionality.
     
     If you provide feedback or contact Transact Bank via email, Transact Bank will collect your name, email address and any other content included in your email messages to us in order to send you a reply. Transact Bank also collects other types of personal information that you provide voluntarily, such as any information requested by Transact Bank if you contact Transact Bank via email regarding support for Services.
   • Personal Information Collected From Third Parties. Transact Bank may collect certain information from identity verification services and consumer reporting agencies, including credit bureaus, in order to provide some of our Services.
   • Personal Information Collected Via Technology. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our Services, our communications and other online services such as:
     
     • Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
     • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, 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, remember your preferences, enabling functionality, and helping us understand user activity and patterns.
     • Location Information. If you have enabled location services on your phone and agree to the collection of your location when prompted by the Services, Transact Bank will collect your location information when you use the Services; for example, to provide our fraud detection services. If you do not want Transact Bank to collect this information, you may decline the collection of your location when prompted or adjust the location services settings on your device.

3. How We May Share Personal Information About You

   We share Personal Information about you only as permitted by law. For Personal Information that is nonpublic and that we collect in connection with a financial service, U. S. federal law permits us to share such information only for the purposes shown in the following table:

   Reasons we can share Personal Information about you	Do we share?	Can you limit this sharing?
   For our everyday business purposes - such as to process your transactions, respond to court orders and legal investigations, and report to credit bureaus;	Yes	No
   For our marketing purposes - to offer our products and services to you;	Yes	Yes
   For Joint Marketing with other financial companies;	No	We Do Not Share
   For our Affiliates' everyday business purposes (information about your transactions and experiences);	Yes	No
   For our Affiliates' everyday business purposes (information about your creditworthiness);	Yes	No
   For our Affiliates to market to you;	No	We Do Not Share
   For Nonaffiliates to market to you	No	We Do Not Share

4. How We May Use Personal Information About You

   We use Personal Information about you only as permitted by law, including, but not limited to, the following purposes:

   • To complete transactions and render services authorized by you;
   • Other everyday business purposes, such as to maintain your ability to access the Service, to send you information about the Service, to effect, administer and enforce transactions, to perform fraud screening, to prevent actual or potential fraud and unauthorized transactions, to verify your identity, to determine your credit history, to verify the information you provide to the Service, to perform collections, to report to credit bureaus (including furnishing delinquent account information), to comply with laws, regulations, court orders and lawful instructions from government agencies, to protect the personal safety of users of the Service or the public, to prevent and defend claims, to resolve disputes, to troubleshoot problems, to enforce our Terms of Use, to protect our rights and property, and to customize, measure, and improve the Service and the App, including pattern recognition, modeling, enhancement and improvement, system analysis, and Service performance analysis;
   • Transact Bank may share your personal information with third party or affiliated service providers that perform services for or on behalf of Transact Bank, for the purposes described in this Privacy Notice, including: to provide you with the Servies; to conduct quality assurance testing; to facilitate the creation of accounts; to optimize the performance of the Services; to provide technical support; and/or to provide other services to Transact Bank;
   • For marketing purposes - to offer products and services to you, although you may opt-out of receiving commercial email marketing messages from us by following the opt-out processes described in those messages; and
   • If we are involved in a merger, acquisition, or sale of all or a portion of our assets that results in a change of the majority ownership of the App or the Service or the entity that owns them, you will be notified of this via email and/or a prominent notice on the App, as well as any material change in uses of your Personal Information, as well as any choices you may have regarding Personal Information about you.

5. Definitions

   • "Affiliates" means companies related by common ownership or control. They can be financial or nonfinancial companies.
   • "Nonaffiliates" means companies not related by common ownership or control. They can be financial or nonfinancial companies.
   • "Joint Marketing" means a formal agreement between nonaffiliated financial companies that together market financial products or services to you.

6. How We Protect Personal Information About You

   To protect Personal Information about you from unauthorized access and use, we maintain physical, electronic, and procedural safeguards, including but not limited to security measures that comply with applicable federal and state laws. We also require our service providers and business partners to whom we disclose the information to do the same. When you enter sensitive information (such as a debit or credit card number) into the App, we encrypt the transmission of that information using secure socket layer technology (SSL). We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

7. Safeguards & Data Retention

   We will retain, protect, use, and share Personal Information about you as long as it is reasonably required for the purposes described in this Mobile App Privacy Policy, and as required by law, including, but not limited to, for risk management, regulatory compliance, and audit purposes. We implement reasonable administrative, technical and physical measures in an effort to safeguard the information in our customer and control against theft, loss and unauthorized access, use, modification and disclosure. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information.

8. Amendments

   We may amend this policy at any time by posting a revised version in the App. The revised version will be effective immediately at the time it is posted unless a delayed effective date is expressly stated therein. You may (in our discretion) also be provided with an email notification of such amendments. If we make any change in how we use your Personal Information, we will notify you by email or by means of a notice in the App prior to the change becoming effective. You may (in our discretion) be required to affirmatively acknowledge or accept the revised Privacy Policy in order to continue using the App and the Service. Any use of the App or the Service after a notice of change will constitute your express agreement to such changes.

9. Minor Children

   Transact Bank Services are not directed towards individuals under the age of 18 and Transact Bank does not intentionally gather personal information about visitors who are under the age of 18. If a child under 18 submits personal information to Transact Bank and Transact Bank learns that the personal information is that of a child under 18, Transact Bank will attempt to delete the information as soon as possible.

10. Other Transact Bank Privacy Policies & Information

    We encourage you to review Transact Bank’s privacy policies and notices concerning the privacy of your financial information. A copy of this Mobile App Privacy Policy and Transact Bank’s general Privacy Policy Notice to consumers and customers can be found on Transact Bank’s website by clicking here or navigating to https://www.transactbank.com/documents-and-fees.