Security Measures

Privacy Practices

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(as of 1-1-2011)

This financial institution recognizes the importance our customers place on privacy and the security of their personal information. Our goal is to protect your personal information in every way that we interact with you, whether it’s on the telephone, in our lobby, at one of our ATMs, or on the Internet.

We think it is important for you to be informed of the policies, procedures, and security measures we have in place to safeguard your personal and confidential information. We have developed this policy to help you to understand the steps we take to protect your sensitive information. Throughout our website, you will have access to our Privacy Policy at any time.


Our website and portal have a number of links to other websites. These links to third parties are offered as a courtesy and a convenience to our customers. We have reviewed the content of these third party websites to ensure that they also have privacy policies. Merchants in these websites may collect certain information from you when you visit their sites or when you provide them billing or shipping information.

If you have questions or concerns about the privacy policies and practices of these third parties, please review their websites and contact them directly. This financial institution assumes no responsibility for the content, safety, security, or privacy of any such site or any transactions you conduct through them. However, if you need any assistance in contacting these third parties, or if you have any concerns regarding unauthorized access to your accounts or financial institution credit cards, please contact us immediately.

Privacy Updates

New product releases may require changes to our Privacy Policy. When such changes are made, we will indicate the date of the update at the top of the Privacy Policy. We will provide our customers copies of our Privacy Policy on an annual basis. If you have agreed to accept disclosures electronically, we may send you an email telling you where the Privacy Policy can be viewed from our website.

Information That We Collect

We collect nonpublic personal information about our customers from the following sources:

  • Information we receive from you on applications, emails, or other forms.
  • Information you provide to customize our portal.
  • Information about your transactions with us and our affiliates.
  • Information we receive from a consumer-reporting agency.
  • Information that is generated when you contact us electronically.

Our Internet financial services provider, First Data Financial Network, Inc. (“First Data”), also collects and maintains certain information about our customers simply to help us provide banking and other financial services to you online. They may also collect certain information for security and statistical purposes. The information collected may include:

  • The internet address from which you access our web site.
  • The date and time you access our site.

We Do Not Collect Information From Children

We recognize the importance of protecting children’s identities and privacy online. Our website is not directed at children, and we do not knowingly collect or maintain personal information from children.


When you log on to our Internet banking system, our service provider, First Data, passes a cookie to your browser. The cookie only identifies your computer. First Data does not (and cannot) use cookies to collect or obtain new personal information about you.

This cookie allows First Data to process multiple transactions during your session without requiring you to reenter your passcode for each individual transaction. The cookies for online banking simply provide another level of security for our Internet banking product.

The First Data TM online banking product uses encrypted cookies that do not pass to your hard drive. Instead, the cookie is stored in the memory of your browser, identifying your computer while you are logged on. Only First Data can read the information in these cookies. When you log off, close your browser, or turn off your machine, the cookie is destroyed. A new cookie is used for each session. That way, no one can use the prior cookie to access your account. For additional security, the cookie expires after 10 minutes of inactivity. It must then be renewed by reentering your passcode.

When you log on to our customizable financial transaction platform (“Portal”), this financial institution does not send you a cookie. However, if you select the “Remember Me” checkbox when you login, a cookie is sent by First Data to your hard drive. This “Remember Me” cookie enables you to customize the Portal and bypass the login process each time you revisit the Portal. This cookie is retained on your hard drive until you either delete it or click on the Logout link within the Portal. When you use the Portal, First Data sends you another cookie called a “per-session” cookie or “server-side” cookie. This “server-side” cookie resides in the browser and is only used by First Data to monitor the session by a unique identification number. You must accept the “server-side” cookie to use the Portal. The cookie is destroyed after eight hours.

Neither the “Remember Me” cookie or the “server-side” cookie collect or maintain any personally identifiable information about you.

In the future, to assist us in our marketing program we may also collect information on the pages you visit.

Visitors to our website remain anonymous. We do not collect unique identifying information about you unless you voluntarily and knowingly provide us that information, and we don’t send you a “cookie.” We do collect general information about your visit, such as when you accessed our site, which pages you accessed in our website, and what Internet provider you used when you accessed our site. You may elect to provide us with more specific information, such as when you give us feedback or send us an email. If you provide us this information, it is only used internally and in furtherance of the purpose for which it was provided.

Information That We Disclose

We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law. We do not sell any of your personal information. We will not disclose any medical information that you provide to us, unless you specifically authorize its disclosure.
In the future, we may disclose portions of the information we collect on our customers and former customers with companies or other financial institutions that perform marketing services on our behalf. If we disclose any of your nonpublic personal information to a marketing company or other financial institution with which we have a joint marketing agreement, we will provide you an opportunity to opt-out or opt-in if required by law.

We would only share your personal information with a third-party advertising company in order to market more effectively to you. Improved marketing practices would allow us to only market products and services that may be of particular interest to you or save you money.

We will require any company or financial institutions performing marketing services on our behalf to sign a contract to maintain the confidentiality of our customer information to the same extent that we must do.

We do not disclose or sell to any third-party information that we collect or that is provided to us from visitors to this website. We do not send advertisements or email to someone who just visited our website.

External Third-Party Links

This financial institution has numerous links to third-party sites. These links to external third parties are offered as a courtesy and a convenience to our customers.


Third-party merchants may collect personal information from you when you visit their sites. For example, they collect personal information from you when you provide billing information or send them an email. Some third party merchants may also send your computer a cookie to collect data on your Internet usage and preferences. When you click on advertisements at third party sites, the advertising company may also send your computer a cookie. With the exception of our service provider, First Data, we do NOT have access to the information collected by any third party, nor can we control how they use this information. If you have questions or concerns about the privacy policies and practices of these third parties, please review their websites and contact them directly.


This financial institution has developed strict policies and procedures to safeguard your personal information. We restrict employee access to your nonpublic personal information to a “need to know” basis. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information. We educate our employees about the importance of confidentiality and customer privacy . We take appropriate disciplinary measures to enforce employee privacy responsibilities.

Our Internet banking service provider, First Data, has also developed security policies and procedures to protect the customer information they must collect and maintain to help us process your banking transactions over the Internet. They have developed a top-of-the line security system to ensure your customer information is protected on the Internet and within the First Data environment. For more information on the First Data security measures, please click security measures.


If you would like to know what information your financial institution and First Data have collected regarding your use of Internet products and services, please contact us at 1-800-421-1105 or via email to First Data at support@First After reviewing the information, if you believe any of the information is in error, contact your financial institution either by phone or email, or send a letter that explains the alleged discrepancy. If the information is incorrect, we will work with First Data to ensure your information is promptly updated. In addition, if you believe any information that this financial institution or First Data has collected about you has been used for an improper purpose, please contact your financial institution, or contact First Data at support@First Explain your concerns in as much detail as possible so that we may take any appropriate action.

Consumer Complaints

Arrowhead Bank is chartered under the laws of the State of Texas and by state law is subject to regulatory oversight by the Texas Department of Banking. Any consumer wishing to file a complaint against Arrowhead Bank should contact the Texas Department of Banking.

Arrowhead Bank also engages in the business of selling checks as an agent for a company licensed under the laws of the State of Texas and subject to regulatory oversight by the Texas Department of Banking. If you have any complaints regarding the company’s money transmission or currency exchange activity, you should first contact American Express. If you still have an unresolved complaint after contacting American Express, then you should contact the Texas Department of Banking.

Consumers may file complaints with the Texas Department of Banking by contacting the Department through one of the means indicated below:

In Person or U.S. Mail: 2601 North Lamar Boulevard, Suite 300
Austin, Texas 78705-4294

Telephone Number: 1-877-276-5554 (toll free) Fax No.: (512) 475-1313