PRIVACY POLICY

Effective Date: September 30, 2026
Last Updated: September 30, 2026
Website: firstheritagetrust.com
Organization: First Heritage Trust Bank


1. INTRODUCTION

First Heritage Trust Bank ("First Heritage Trust Bank," "First Heritage," "the Bank," "we," "us," or "our") respects the privacy of individuals who visit our website, use our digital services, communicate with us, or maintain a relationship with us.

This Privacy Policy explains how we collect, use, disclose, protect, and retain information relating to customers, prospective customers, website visitors, applicants, authorized representatives, business customers, and other individuals who interact with First Heritage Trust Bank.

This Privacy Policy applies to information collected through:

  • firstheritagetrust.com;

  • online banking platforms;

  • mobile applications, where applicable;

  • account-opening applications;

  • customer-service channels;

  • email communications;

  • telephone communications;

  • forms and documents;

  • financial products and services;

  • marketing communications; and

  • other authorized Bank channels.

Certain financial products or services may have additional privacy disclosures. Where a specific privacy disclosure applies to a particular product, that disclosure may supplement or take precedence over this Privacy Policy to the extent required by law.


2. INFORMATION WE COLLECT

Depending on the Services you use and applicable law, we may collect different categories of information.

2.1 Personal Identification Information

This may include:

  • full legal name;

  • date of birth;

  • residential address;

  • mailing address;

  • telephone number;

  • email address;

  • government-issued identification information;

  • tax identification information;

  • nationality or residency information where legally required;

  • signature;

  • identification documents;

  • photographs or other verification information; and

  • other information necessary to establish identity.

2.2 Financial Information

Where necessary to provide financial products and services, we may collect:

  • account information;

  • transaction information;

  • account balances;

  • payment information;

  • income information;

  • employment information;

  • credit information;

  • source-of-funds information;

  • financial history;

  • assets and liabilities;

  • payment history;

  • loan information; and

  • other financial information relevant to the Services.

2.3 Business Information

For business customers, we may collect:

  • business name;

  • business address;

  • registration information;

  • ownership information;

  • beneficial ownership information;

  • business contact information;

  • tax information;

  • financial information;

  • information concerning directors, officers, partners, trustees, or authorized representatives; and

  • documents necessary to verify the business.

2.4 Account and Authentication Information

We may collect information associated with online banking access, including:

  • username;

  • encrypted or protected authentication information;

  • security questions;

  • authentication tokens;

  • device information;

  • login information;

  • authentication events;

  • security alerts; and

  • other information required to protect accounts.

We do not intend to collect passwords in plain text where appropriate technical safeguards can be used.

2.5 Transaction Information

We may collect information about financial transactions, including:

  • transaction date and time;

  • transaction amount;

  • sender and recipient information;

  • merchant information;

  • payment references;

  • transaction descriptions;

  • account information;

  • location information associated with transactions where available; and

  • other information necessary to process or investigate transactions.

2.6 Technical Information

When you visit our website or use digital services, we may automatically collect certain technical information, such as:

  • IP address;

  • browser type;

  • operating system;

  • device type;

  • device identifiers;

  • screen characteristics;

  • language preferences;

  • referring website;

  • pages visited;

  • date and time of access;

  • approximate geographic information derived from technical data; and

  • website interaction information.


3. INFORMATION COLLECTED FROM OTHER SOURCES

Where permitted or required by law, we may receive information from other sources, including:

  • identity-verification providers;

  • fraud-prevention providers;

  • credit-reporting agencies;

  • payment networks;

  • financial institutions;

  • public records;

  • government agencies;

  • regulatory authorities;

  • business-information providers;

  • service providers;

  • authorized representatives; and

  • other lawful sources.

Information obtained from third parties may be used to verify identity, prevent fraud, comply with legal requirements, assess applications, process transactions, and provide Services.


4. HOW WE USE INFORMATION

We may use information for legitimate business, contractual, security, operational, and legal purposes, including to:

  1. establish and maintain accounts;

  2. process applications;

  3. verify identity;

  4. process transactions;

  5. provide banking and financial services;

  6. communicate with customers;

  7. provide customer support;

  8. prevent fraud;

  9. detect suspicious activity;

  10. protect customers and the Bank;

  11. comply with legal obligations;

  12. comply with regulatory requirements;

  13. conduct risk management;

  14. maintain records;

  15. improve digital Services;

  16. maintain website functionality;

  17. analyze website usage;

  18. develop and improve products;

  19. send permitted marketing communications;

  20. investigate complaints and disputes;

  21. enforce agreements;

  22. protect legal rights;

  23. respond to lawful requests from authorities; and

  24. perform other purposes disclosed at the time information is collected.


5. IDENTITY VERIFICATION

Financial institutions may be required to verify the identities of customers and other individuals.

We may use personal information and documentation to:

  • establish identity;

  • verify documents;

  • prevent identity theft;

  • comply with customer-identification requirements;

  • prevent fraud;

  • comply with sanctions requirements;

  • identify beneficial owners;

  • assess account applications; and

  • satisfy applicable legal and regulatory obligations.


6. FRAUD AND SECURITY MONITORING

We may analyze account activity, transactions, login events, device information, and other information to identify potentially fraudulent or unauthorized activity.

Security monitoring may include:

  • unusual login detection;

  • transaction monitoring;

  • device recognition;

  • authentication monitoring;

  • fraud scoring;

  • suspicious activity detection;

  • account takeover detection; and

  • cybersecurity monitoring.

Where permitted or required by law, we may share information concerning suspected fraud with appropriate parties.


7. LEGAL AND REGULATORY COMPLIANCE

We may collect, use, retain, and disclose information when necessary to comply with applicable:

  • banking laws;

  • financial regulations;

  • anti-money-laundering requirements;

  • sanctions requirements;

  • tax laws;

  • court orders;

  • regulatory requests;

  • law-enforcement requests;

  • consumer-protection laws; and

  • other legal requirements.

We may be unable to disclose certain information about investigations or regulatory actions where disclosure is prohibited by law.


8. HOW WE SHARE INFORMATION

We do not treat customer information as something to be freely sold or publicly distributed.

We may disclose information where appropriate to:

Service Providers

We may share information with companies that provide services such as:

  • technology infrastructure;

  • cloud hosting;

  • identity verification;

  • fraud prevention;

  • cybersecurity;

  • payment processing;

  • communications;

  • document management;

  • customer support;

  • analytics;

  • mailing;

  • professional services; and

  • other operational functions.

Service providers may only receive information necessary to perform their services, subject to applicable contractual and legal requirements.

Financial Institutions and Payment Networks

Information may be shared with financial institutions, payment processors, card networks, correspondent institutions, and other entities when necessary to process transactions.

Government and Regulatory Authorities

Information may be disclosed when required or permitted by applicable law.

Professional Advisers

Information may be disclosed to lawyers, accountants, auditors, consultants, insurers, and other professional advisers where appropriate.

Corporate Transactions

Information may be transferred in connection with a merger, acquisition, restructuring, financing, sale of assets, or similar corporate transaction, subject to applicable law.


9. MARKETING

Where permitted by applicable law, we may use contact information to provide information about:

  • products;

  • services;

  • educational content;

  • announcements;

  • promotions; and

  • other relevant communications.

You may be able to opt out of certain marketing communications.

Even if you opt out of marketing, we may continue sending necessary communications relating to your account, transactions, security, legal obligations, and Services.


10. COOKIES

Our website may use cookies and similar technologies.

Cookies may help us:

  • operate the website;

  • remember preferences;

  • improve performance;

  • understand website usage;

  • protect against fraud;

  • maintain sessions;

  • improve security; and

  • provide analytics.

You may be able to control cookies through your browser settings.

Disabling certain cookies may affect website functionality.


11. ANALYTICS

We may use analytics technologies to understand how visitors interact with our website.

Analytics information may include:

  • pages visited;

  • time spent on pages;

  • browser information;

  • device information;

  • approximate geographic information;

  • referral information; and

  • interaction patterns.

Analytics information may be aggregated or otherwise processed to improve our Services.


12. INFORMATION SECURITY

We maintain administrative, technical, and physical safeguards designed to protect information.

Security measures may include:

  • access controls;

  • authentication systems;

  • encryption where appropriate;

  • monitoring;

  • logging;

  • employee controls;

  • security testing;

  • incident-response procedures; and

  • other protective measures.

However, no internet transmission or electronic storage system can be guaranteed to be completely secure.


13. CUSTOMER RESPONSIBILITIES

Customers are responsible for protecting their own credentials.

You should:

  • use strong passwords;

  • protect authentication codes;

  • keep devices secure;

  • avoid sharing credentials;

  • use trusted devices;

  • monitor account activity; and

  • report suspected unauthorized access promptly.

First Heritage Trust Bank will not ordinarily request your complete password or authentication code through unsolicited communications.


14. DATA RETENTION

We retain information for periods appropriate to the purpose for which it was collected and as required or permitted by:

  • applicable law;

  • regulatory requirements;

  • contractual obligations;

  • fraud-prevention requirements;

  • dispute-resolution requirements;

  • accounting requirements; and

  • legitimate business needs.

When information is no longer required, it may be securely deleted, anonymized, or otherwise disposed of in accordance with applicable requirements.


15. DATA TRANSFERS

Information may be processed or stored in locations where First Heritage Trust Bank, its service providers, or other authorized parties operate.

Where cross-border data transfers occur, we will handle information in accordance with applicable privacy and data-protection requirements.


16. YOUR PRIVACY RIGHTS

Depending on your jurisdiction and applicable law, you may have rights relating to your personal information.

These may include rights to:

  • request access;

  • request correction;

  • request deletion where legally applicable;

  • object to certain processing;

  • request restriction of certain processing;

  • request portability where applicable;

  • withdraw certain consents; and

  • submit a privacy complaint.

These rights are subject to applicable legal exceptions.

Certain financial records may need to be retained even when deletion is requested.


17. CHILDREN'S INFORMATION

Our Services are generally intended for individuals who are legally eligible to use the relevant financial product.

We do not knowingly collect children's personal information except where legally permitted and necessary for an appropriate product or service.

If you believe information concerning a child has been collected improperly, please contact us.


18. THIRD-PARTY WEBSITES

Our website may contain links to third-party websites.

We are not responsible for the privacy practices of third-party websites.

You should review the privacy policy of any third-party website before providing information.


19. MOBILE APPLICATIONS

If we provide mobile applications, the applications may collect information necessary to:

  • authenticate users;

  • provide account access;

  • protect transactions;

  • send security notifications;

  • support functionality; and

  • improve application performance.

Mobile applications may request device permissions where required for specific features.


20. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically.

When we make changes, we will update the "Last Updated" date.

Where required by applicable law, we will provide additional notice.

Your continued use of applicable Services after an effective update constitutes acceptance to the extent permitted by law.


21. CONTACT US

Questions, requests, or concerns relating to this Privacy Policy may be directed to First Heritage Trust Bank through the official contact information published on:

firstheritagetrust.com

First Heritage Trust Bank

Website: firstheritagetrust.com
Administrative Location: New York, New York, United States

A specific street address should only be published after First Heritage Trust Bank has legitimately obtained and is authorized to use that address.


22. IMPORTANT NOTICE

This Privacy Policy describes general information-handling practices.

Specific products, accounts, financial services, jurisdictions, and customer categories may be subject to additional privacy notices or legally required disclosures.

Where another legally required privacy notice applies to a particular product or relationship, that notice will supplement or control to the extent required by law.


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