Bell Bank
Privacy Policy

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, date of birth, income and employment information Account balances, transaction history and credit information Investment experience and insurance claim history Home ownership status, property value estimates and email address
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 Bell Bank chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information	Does Bell 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, Bell Bank shares.  No, you cannot limit this sharing.
For our marketing purposes—with service providers we use to offer our products and services to you	Yes, Bell Bank shares.  No, you cannot limit this sharing.
For joint marketing with other financial companies	Yes, Bell Bank shares.  Yes, you can limit this sharing.
For our affiliates’ everyday business purposes—information about your transactions and experiences	Yes, Bell Bank shares.  No, you cannot limit this sharing.
For our affiliates’ everyday business purposes—information about your creditworthiness	No. We don't share.
For our affiliates to market to you	Yes, Bell Bank shares.  Yes, you can limit this sharing.
For nonaffiliates to market to you	No. We don't share.

To limit our sharing	Visit our Privacy Preferences page Call our toll-free phone number at 1-855-374-4061 Please note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.
Questions?	Call toll free 1-855-374-4061 or Contact Us

Who We Are
Who is providing this notice?	Bell Bank Bell Bank Insurance Services LLC
What We Do
How does Bell 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.
How does Bell Bank collect my personal information?	We collect your personal information, for example, when you open an account or apply for a loan make deposits or withdrawals from your account use your credit or debit card apply for insurance or seek advice about your investments 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 credit worthiness affiliates from using your information to market to you sharing for nonaffiliates to market to you  State laws and individual companies may give you additional rights to limit sharing. See Other Important Information section for your rights under state law.
What happens when I limit share for an account I hold jointly with someone else?	Your choices will apply only to you - unless you tell us otherwise.
Definitions
Affiliates	Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include Bell Insurance Services LLC, a wholly owned subsidiary of Bell Bank.
Nonaffiliates	Companies not related by common ownership or control. They can be financial and nonfinancial companies. Bell Bank does not share with nonaffiliates so they can market to you. Nonaffiliates we share with for our everyday businesses purposes can include financial services companies such as banks, digital payment networks, collection agencies, credit bureaus, and  service providers such as printing, shipping and delivery vendors, property and appraisal services, and direct marketing companies.
Joint Marketing	A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Our joint marketing partners include financial services companies.

Other Important Information

Do Not Call Policy. This notice is Bell Bank’s Do Not Call Policy under the Telephone Consumer Protection Act. Bell Bank maintains an internal Do Not Call preference list. Do Not Call requests will be honored within 30 days and will be effective for at least five years from the date of request. Bell Bank employees receive training on how to document and process telephone marketing choices. We do not solicit via telephone numbers listed on the state or federal Do Not Call lists, unless the law allows.

Children’s Privacy. Visit our Children’s Online Privacy Policy for our information collection practices when offering online financial products and services to children under the age of 13.

Disabling Your Mobile Application Account. If the use of a Bell Mobile Application allows or requires the creation or registration of an Application Account1, you will be able to request that we disable the Application Account. Please contact us at 1-855-450-7990 to facilitate such a request.

California Residents: We will not share information we collect about you with nonaffiliated third parties, except as permitted by law, including, for example, with your consent or to service your account. We will also not use your information for joint marketing purposes. North Dakota Residents: Except as permitted by law, we will not share your personal information with nonaffiliates unless you authorize us to. To opt-in to sharing, please visit us online at: https://bell.bank/privacy-preferences or call us toll-free at 1-855-374-4061. Nevada Residents: We may contact our existing customers by telephone to offer additional financial products that we believe may be of interest to you. You have the right to opt out of these calls by adding your name to our internal do-not-call list. To opt out of these calls, or for more information about your opt out rights, please contact our customer service department. You can reach us by calling 1-800-450-8949, clicking the “Contact Us” link at www.bell.bank, or writing to us at Bell Bank, PO Box 10877, Fargo ND 58106-0877. You are being provided this notice under Nevada state law. In addition to contacting Bell Bank, Nevada residents can contact the Nevada Attorney General's office for more information regarding Nevada Statute Section228.600(3): 100 North Carson Street, Carson City, NV 89701, Telephone: 775-684-1100, Email: AgInfo@ag.nv.gov

Trust or Fiduciary Accounts: Fiduciary duties of confidentiality and privacy apply to trust and other fiduciary accounts for which Bell Bank is the trustee, personal representative, conservator, investment manager or services provider, including employer-sponsored retirement accounts such as 401(k)s. Information about these accounts is not shared for marketing purposes without specific consent.

 Affiliates Providing this Notice

• Bell Bank 
• Bell Insurance Services LLC

¹_{The term Application Account as used herein refers to the unique user identity provided to serve the use across the application (can often include use of usernames, email addresses, and passwords) and not the underlying deposit account itself. For information on how to close a deposit account, contact 1-855-450-7990.}

PRIVACY STATEMENT-CALIFORNIA

Effective date: January 2023
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy Statement of Bell Bank and its divisions (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and the amendments adopted under the California Privacy Rights Act of 2020 (CPRA), along with other California privacy laws. Any terms defined in the CCPA/CPRA have the same meaning when used in this notice.

Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). We will retain information collected in each category of personal information listed below no longer than required to comply with federal, state and local laws. In particular, we collect or have collected since January 1, 2022 the following categories of personal information from consumers:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	Yes
B. Personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Yes
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, requests for leave of absence, veteran or military status, genetic information (including familial genetic information), AIDS/HIV; status as a victim of domestic violence, assault, or stalking; political activities or affiliations.	Yes
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
E. Biometric information	An individual's physiological, biological or behavioral characteristics, including information pertaining to an individual's deoxyribonucleic acid (DNA), that is used or is intended to be used, singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.	No
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with an internet website application, or advertisement.	Yes
G. Geolocation data.	Physical location or movements.	Yes
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	Yes
I. Professional or employment-related information.	Current or past job history or performance evaluations.	Yes
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	Yes
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No
L. Sensitive Personal Information	Social security number, driver’s license, state identification card or passport number. An account log-in, financial account, debit card or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. A precise geolocation, racial or ethnic origin, genetic data, religious or philosophical beliefs or union membership. The contents of an email, and text messages, unless the business is the intended recipient of the communication. The processing of biometric information to uniquely identify a consumer. Personal information collected and analyzed concerning a consumers health, sexual orientation or sex life.	Yes

Personal information does not include:

• Publicly available information from government records or lawfully obtained, truthful information that is a matter of public concern made available to the general public by the consumer or from widely distributed media, or by the consumer.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you, for example on applications or other forms you complete on our website or in-person.
• Indirectly from you, for example from observing your interactions with our website.
• From information about your transactions with us, our affiliates, or others.
• From a consumer reporting agency and other service providers.
• Service providers, contractors or third parties that provide data to support activities such as fraud prevention, underwriting, and marketing. Examples may include internet service providers, social networks, advertising networks, and data analytics providers.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to extend a loan or open an account, we will use that information to complete the transaction requested by you.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
• To improve our website and present its contents to you including to repair errors that impair functionality.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA as amended by the CPRA.

We may not collect all of the examples of data listed in the categories listed above. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Disclosure of Personal Information

We may disclose your personal information to a service provider, contractor or third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing under the terms of the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

• Category A: Identifiers.
• Category B: California Customer Records personal information categories.
• Category C: Protected classification characteristics under California or federal law.
• Category F: Internet or other similar network activity
• Category G: Geolocation data
• Category I: Professional or employment-related information.
• Category J: Non-public education information
• Category L: Sensitive Personal Information

We disclose your personal information for a business purpose, pursuant to our relationship with you, to the following categories of third parties:

• Our affiliates.
• Service providers and contractors
• In the preceding twelve (12) months, we have not sold, or shared for targeted advertising, any personal information.

In the preceding twelve (12) months, we have not sold, or shared for targeted advertising, any personal information.

We do not share the personal information of consumers under 16 years of age.

Your Rights and Choices

The CCP as amended by the CPRA provide consumers (California residents) with specific rights regarding their personal information. This section describes your rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting, sharing or selling that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• Categories of personal information that we sold (if applicable) or disclosed about you for a business purpose and, for each category identified, the categories of third parties to whom we disclosed that particular category of personal information.
• Categories of third parties to whom the personal information was sold (if applicable) or disclosed for a business purpose

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers or contractors to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Correction Requests

You have the right to request that we correct any of your personal information that we collected and retain about you, subject to analysis of information you submit supporting the correction. Once we receive and confirm your verifiable consumer request, we will update any inaccurate personal information (and direct our service providers or contractors to correct) as required by the CCPA.

Exercising Access, Data Portability, Deletion and Correction Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 855-450-7990.
• Contact Us

Only you, or a person/registered legal entity acting as your authorized agent, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Once you submit your verifiable consumer request, we will verify your identity by matching the information you provided us with information in our systems. If you submit a request to know specific pieces of personal information, delete certain information or correct inaccurate information, in addition to verifying your identity with information we have on file, you also may be required to submit a signed declaration under penalty of perjury stating that you are the consumer whose personal information is the subject of the request.

There is certain information that we will not disclose to you. This information includes but is not limited to your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answer, or unique biometric data generated from measurements or technical analysis of human characteristics

Authorized Agents

You may authorize an agent to make an access or deletion request on your behalf. Your authorized agent may make a request on your behalf by contacting us at the toll-free number or website listed above. As part of our verification process, we may request that you provide your signed authorization to release information to the agent. Additionally, we may require you provide other documentation such as a power of attorney or legal conservatorship if applicable.

For a company or organization (“legal entity requestor”) making a request on your behalf, we will ask you to provide proof that you have authorized the legal entity requestor to make the request.

Response Timing and Format

Once we receive your verifiable consumer request, we will confirm our receipt of your request within 10 business days and provide you with information about how we will process the request. We endeavor to respond to a verifiable consumer request within 45 calendar days of its receipt. If we require more time (up to 90 calendar days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Response Timing and Format

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website and will update the notice’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

• Call us: 855-450-7990
• Contact Us

California Do Not Track Disclosure

Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, we do not respond to Do Not Track browser settings or signals. For information about Do Not Track, please visit: www.allaboutdnt.org.

Bell Bank Children’s Online Privacy Policy

Your child’s privacy is important to us. This Children’s Privacy Policy and all references to “Your Child” exclusively pertain to online banking users under the age of 13. It explains how we collect, use, and disclose personal information collected online from children under the age of 13 in compliance with the Children’s Online Privacy Protection Act (“COPPA”). For more information on how Bell protects your child’s personal information, refer to our Online Banking Security Policy.

Personal Information We Collect About Your Child

Before your child uses Bell Bank’s online services, you'll enroll them into the program and consent to our collection, use, and disclosure of their personal information in connection with the use of their account. We won't require your child to disclose more personal information than is necessary to access their account in Online Banking.

During enrollment you'll provide your child’s name, date of birth, and address. We also require an email address for your child. Your child will need to create a username/password for their online account access. When your child uses their account, they'll have the ability to make changes to their personal information such as their:

• Account nickname
• Telephone number(s)
• Address
• Email address
• Username and password

By signing the consent form provided at the time your child’s account was opened, you consent to our collection of the personal information above to the extent your child chooses to update his or her profile, which may occur without notice to you. As described below, you have the right at any time to review the personal information we collect from your child online, refuse to allow further use or collection, or request deletion of that information.

Other Information We May Collect

In addition to the personal information described above, we may collect certain information about your child’s use of our online services. For example, we may capture the IP address or unique identifiers of the device they use to connect to the online service, the type of operating system and browser they use, and their browsing history. We or our partners may also use cookies, web beacons or other technologies to collect and store other information about their visit to, or use of, our online services. In addition, we may later associate the usage and other information we collect online with personal information about them.

If your child accesses our online services using a mobile device, we may also collect information such as unique device identifiers for their mobile device, screen resolution and other device settings, information about their location, and analytical information about how they use their mobile device.

Use of Information

We use the information discussed above in a number of ways, such as: 

• Processing transactions;
• Verifying your child’s identity (such as when they access their account information);
• Preventing fraud and enhancing the security of their account or our online services;
• Providing your child with support and responding to their inquiries, including to investigate and address concerns and monitor and improve our responses.
• Managing their preferences;
• Improving our online banking services, including to repair errors that impair functionality; and
• For any other purposes that we may specifically disclose to you during the account opening process.

Disclosure of Information

We may share the information we collect from and about your child with our affiliates and others. For example, we may share their information with:

• Bell service providers;
• Successors or affiliates in connection with a corporate transaction, such as a sale, consolidation or merger of Bell businesses; and
• Others, in order to comply with legal requirements such as the demands of applicable subpoenas and court orders; to verify or enforce our terms of use, our other rights, or other applicable policies; to address fraud, security or technical issues; to respond to an emergency; or otherwise, to protect the rights, property or security of our customers or third parties.

Your Rights as Parent or Legal Guardian

As a parent or legal guardian, you have the right to:

• Review the personal information collected online from your child;
• Refuse to allow further use or online collection of personal information from your child; and
• Delete the personal information collected online from your child (unless we're required by law to retain).

To exercise any of these rights, call us at 800-450-8949, stop by any of our Bell Bank locations, or send your request in writing to:

PO Box 10877
Fargo, ND 58106-0877.

If you don’t want us to continue to collect or use your child’s personal information, or if you ask us to delete it, we’re required to remove their online profile; however, your child’s account will remain open.

Contact Details

If you have any comments, questions or concerns about any of the information in this Policy, please contact us at:

Bell Bank
520 Main Ave.
Fargo, ND 58103
855-450-7990
customerservice@bell.bank