Privacy Policy

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Privacy Policy

Last Updated July 29, 2026

FIRST BANK OF THE LAKE PROVIDES ACCESS TO ITS WEBSITES, APPLICATIONS, PRODUCTS, AND SERVICES (COLLECTIVELY, “SERVICES”) TO YOU SUBJECT TO THIS PRIVACY POLICY (“POLICY”) AND THE ADDITIONAL INFORMATION LINKED IN THE INTRODUCTION SECTION BELOW. PLEASE READ CAREFULLY.

1. Introduction

This Policy describes how First Bank of the Lake collects, uses, discloses, and retains personal information. In addition to this Policy, additional First Bank of the Lake policies, agreements, and notices may impact how we handle your information, including our:

The terms “Bank”, “we,” “us,” and “our” mean First Bank of the Lake.

The terms “you” and “your” mean any person or entity who accesses or uses our Services.

The terms “such as”, “including”, and “includes” mean that it includes but is not limited to what is shown.

2. Information We Collect

We may collect personal information and other information about you, your device, your household, and your entities in connection with our Services. This includes information such as the following:

Personal Identifiers. Personal identifiers such as real name or alias, address, online identifier, IP address, email address, account name, SSN, driver’s license number, passport number, or other similar identifiers about your and your business interests
Characteristics of legally protected classifications under state or federal law. Characteristics of protected classifications under state or federal law such as age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, sex, and veteran or military status
Commercial Information. Commercial information such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Biometric Information. Biometric information such as 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
Internet or Other Electronic Network Activity Information. Internet or other electronic network activity information such as browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement
Geolocation Data. Geolocation data such as information that can be used to determine your physical location
Sensory Data or Recordings. Sensory Data or Recordings such as audio, electronic, visual, or similar information that can be linked or associated with a particular consumer or household
Professional or Employment-Related Information. Professional or employment-related information such as compensation, and current and past job history.
Education Information. Education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
Inferences Drawn from Personal Information. Inferences drawn from personal information such as profile information about you which includes attributes such as preferences, characteristics, abilities, and aptitudes.
Sensitive Personal Information. The following categories of sensitive personal information: (i) social security, driver’s license, state identification card, or passport number; (ii) 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; (iii) Your precise geolocation (i.e. within 1850 foot radius); (iv) racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership; (v) the contents of your mail, email, and text messages unless the business is the intended recipient of the communication; (vi) biometric information for the purpose of uniquely identifying a consumer.
Other Personal Information. Public and nonpublic financial information about you and your related or affiliated business interests, our transactions with you and your related or affiliated business interests, and your transactions with nonaffiliated third parties
Other Entity Information. Information about your business, affiliates, and related interests such as entity identification, formation, ownership, financial, tax, and other information such as tax identification numbers.

3. How We Collect Information

We may collect this personal information from various sources such as the following.

Customers. Directly from you, such as when you provide information to us, and indirectly from you, such as when we automatically collect technical and usage information when you access or use our Services or social media accounts.
Third Parties. Service providers, contractors, and other third parties that support our operations, such as for those operations for business and commercial purposes shown in the section of this Policy titled How We Use Collected Information
Government. Government authorities, agencies, and offices, including federal, state, and municipal.

We and our third party service providers may collect this personal information manually or automatically when you contact us or access or use the Services. Examples of information that may be collected automatically include IP address, device identifiers, browser type, operating system, referring URLs, pages viewed, clicks, and other usage data. This information may be collected through the use of cookies, pixels, SDKs, and similar technologies which is described in greater detail in the section of this Policy titled Cookies and Other Online Tracking and Monitoring.

4. How We Use Collected Information

We may use collected personal information for one or more of the following business or commercial purposes:

Products & Services. To perform activities related to evaluating, providing, servicing, personalizing, developing, and enhancing our website, applications, products, services, accounts, and other Services.
Communications. To communicate with customers and related parties about website, applications, products, services, and accounts used or requested.
Marketing. To perform marketing, targeted advertising, communications, research, and analytics activities
Research and Development. To perform business research and improvement activities such as identifying opportunities and issues with existing products and services, planning improvements to existing products and services, and creating new products and services
Customer Service. To perform customer service/quality assurance activities and manage complaints and inquiries
Human Resources. To perform human resources activities to attract, hire, and maintain personnel such as to conduct recruiting and candidate evaluation activities and to inform our employment decisions.
Asset Security & Integrity. To perform activities associated with maintaining the security and integrity of our personnel and our physical and digital assets, locations, and systems.
Financial. To perform financial management activities associated with our financial, accounting, and tax interests.
Compliance. To perform compliance activities associated with our legal, regulatory, and contractual obligations under applicable law
Legal. To perform legal proceedings activities such as establishing, exercising, and defending our legal rights, and otherwise complying with our legal obligations.
Risk. To perform risk management activities such as audit, compliance, controls and other risk management activities.
Fraud Prevention. To perform fraud prevention activities such as the detection, prevention, and investigation of potential and actual incidents of fraud.
Economic. To advance our commercial or economic interests.
Mergers & Acquisitions. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
Aggregation & Anonymization. To aggregate and/or anonymize personal Information so that it will no longer be considered personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.
Other Purposes. Any other purpose you consent to or as described to you when collecting your personal information before or at the time of collection.

5. Our Disclosure of Your Information

We may also disclose your personal information to the following categories of third parties for our business or commercial purposes:

Operational Support. Entities we use to provide services to or for us to facilitate our business and commercial operations to provide products and services to you and to facilitate our business and commercial purposes. Some examples include internet service providers, software providers, consumer reporting agencies, financial technology partners, auditors, recruiters, and our agents and representatives
Marketing Support. Marketing and advertising technology providers, advertising partners, and social media platforms, such as those involved in connection with our cross-context behavioral advertising activities
Customer Representatives. Entities or individuals that represent customers such as an accountant, agent, attorney, service provider, person holding power of attorney, and other representatives
Law Enforcement & Government. Government agencies, including federal, state, and municipal agencies and authorities, courts, law enforcement, and other third parties to support regulatory and legal requirements
Affiliates. Our affiliates
Mergers & Acquisitions. Third parties, such as an acquiring entity and its advisors, in connection with a sale or business transaction, including to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.

We may also share your personal information with other third parties at your direction or with your consent.

6. Cookies and Other Online Tracking and Monitoring

About Cookies.

Cookies are small data files stored on the device (computer, mobile phone, tablet or any other electronic device connected to the internet) that you use to access any of our Services. The term “Cookies” is used to collectively refer to these and other pieces of text, pixels, clear gifs, log files, web beacons or other similar internet tracking technology that are placed on your devices.

Cookies store information about how you use an online service so that the website can recognize your device, provide functionality, enhance your experience (like remembering your preferences), analyze usage patterns, and personalize content and advertising.

Cookies set by us are called “first party cookies”. Cookies set by parties other than us are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website (such as advertising, interactive content and analytics). The parties that set these third party cookies can recognize your computer or mobile device both when it visits the Services and also when it visits other websites.

How We Use Cookies.

We, our services providers, and our marketing providers use Cookies to collect a variety of information for different purposes. Here are some examples of the types of information that we collect through Cookies:

Information related to your login so we can remember that you’ve logged in before or so you can stay logged in after you leave the website
Number of visitors, the frequency with which the websites and apps are used, the pages viewed, the clicks made, and the total duration of use
The name of the website visited prior to visiting our websites and mobile apps
Information about your device, browser, IP address, and browsing preferences
Whether you are a first-time visitor
Your viewing preferences (e.g. layout, sizing preferences, etc.)

Some examples of how we use this information collected through Cookies includes to:

Remember the tasks you are involved in to provide access to those tasks each time you log-in
Customize your visit to our websites and mobile apps based on prior preferences you made
Tailor our advertising and marketing messages to you, based on our understanding or the understanding of our third party service providers of your activity on the Services and other websites and services, to highlight products or features that might interest you
Analyze usage trends across our user base to improve our website, mobile apps, and services, and inform how we can offer you new services

Categories of Cookies We Use.

Some of the cookies we use are first-party cookies, which are created by us to help make our Services work properly and analyze usage. We also allow certain third-party providers to place third-party cookies to enable third-party features or functionalities or to assist us with our analytics and advertising activities. We classify these cookies by their purpose into the following categories.

Required Cookies: These Cookies are necessary to provide you with the basic features of this site to function, such as providing secure log-in, allowing images to load, or allowing you to select your cookie preferences. Because these cookies are essential to providing our services to you, they cannot be disabled.
Functionality Cookies: These Cookies allow us to analyze your use of the site to evaluate and improve its performance. They may also be used to provide a better customer experience on this site, such as by remembering your log-in details, optimizing video performance, or providing us information about how our site is used. If you do not enable these cookies, or choose to disable them in the future, that could impact your ability to use certain features.
Advertising Cookies: These Cookies are used to show you ads that are more relevant to you. We may share this information with advertisers or use it to better understand your interests. For example, Advertising Cookies may be used to share data with advertisers so that the ads you see are more relevant to you, allow you to share certain pages with social networks, or keep track of when visitors return to our site.

Duration of Cookie Storage.

The length of time that cookies are stored on your device will vary, depending on whether the cookies are temporary or persistent.

Session cookies. We use temporary cookies called session cookies on our secure pages to assign and register a session ID. This allows you to visit and use our websites and services without interruption, and provides us with internal reporting. These cookies expire when you close your browser.
Persistent cookies. Persistent cookies are used by us and our third-party providers to understand visitors’ browsing behavior over a longer period of time or to provide additional features or customization. They can stay on your device for different lengths of time depending on their function. These cookies survive after your browser is closed and can be used to recognize your device when you reopen your browser and revisit our websites and apps.

How To Manage Cookie Preferences.

Our Settings. Our Services are only intended to be used by United States residents and businesses. Depending on the U.S. state law applicable to you, we may provide you with the ability to opt-in to or opt-out of certain Cookies. If one of these state laws applies to you, you will be presented with a Cookie consent banner on our website which will allow you to manage your Cookie preferences. You can also manage your Cookie preferences at any time by clicking the following link (the “Cookie Preferences Center”), which will let you change your preferences or withdraw your consent.
- Do Not Sell or Share My Personal Information
Your Browser Settings. You can disable and/or delete most types of cookies by using your browser settings. As the means by which to activate or deactivate cookies varies from one web browser to another (e.g., Safari, Chrome, Mozilla Firefox), you should visit your specific web browser’s help menu for more information on cookie preferences. Please note that currently, it is technically impossible for you to synchronize your settings across the different browsers and devices you use. You must therefore set them on each browser/device that you currently use and each time you use a new browser or device.

Additionally, there is no industry standard for how consumer browser settings for “Do Not Track” signals should work on commercial websites. Due to the lack of such standards, our Services do not respond to these “Do Not Track” browser settings.

Universal Opt-out Mechanism – Global Privacy Control. Global Privacy Control (GPC) is a technical mechanism that you can set in some browsers or through an extension to signal your privacy preferences to the websites you visit. If we detect that you are a resident of California and that your browser is communicating a GPC signal, we will process that as a request to opt that particular browser out of all Cookies which are not considered “Required”, in accordance with applicable law. Note that if you come back to our websites from a different device or use a different browser on the same device, you will need to opt out (or set the GPC for) that device and browser as well. For additional information and how to enable GPC, please visit https://globalprivacycontrol.org/
Third-Party Account Cookies and Browser Sessions. Some features of our websites may use content, security services, or other functionality provided by third parties. If you are signed in to a third-party account (such as a Google account) while visiting our websites, your browser may already contain cookies or similar technologies placed by that third party as part of your separate relationship with that provider. Our Cookie Preference Center applies only to cookies and similar technologies that we control or that are deployed through our websites. We cannot access, modify, or delete cookies that are placed and controlled by another company on its own domains, including cookies associated with your separate account or browser session with that company. If you wish to manage or remove cookies associated with your account with a third party, you should review that provider’s privacy settings, account settings, and browser controls.

Impact of Disabling Cookies.

If you choose to deactivate Cookies, you may continue to use certain parts of our Services; however, some useful features may not work anymore, depending on which Cookies you deactivate. Please note that if you have disabled one or more Cookies, we may continue to use the information that was collected by such Cookies before they were deactivated. However, we will cease to collect any new information via the opted-out cookie once a cookie has been deactivated.

7. Marketing Choices

If you no longer want to receive marketing-related communications from us on a going-forward basis, you may opt out by following the unsubscribe instructions in any such message or by contacting us by email at [email protected]. Please note that if you opt out of receiving marketing from us, we may still send you important administrative messages, from which you cannot opt out.

8. Linked Websites

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third parties operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates. To the extent that you access or use the Services through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites and services before proceeding to use them. We do not guarantee and are not responsible for the privacy or security of these websites or services, including the accuracy, completeness or reliability of their information.

In addition, we are not responsible for the information collection, use and disclosure practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, BlackBerry or any other application developer or provider, social media platform provider, operating system provider, wireless service provider or device manufacturer.

9. Data Security

Your privacy is very important to us and we are committed to protecting your personal information from unauthorized access or use. We will use reasonable organizational, physical, technical and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure, and our measures do not guarantee that your information will not be accessed, disclosed, altered, or destroyed. Any information provided is at your own risk, and by accessing or using our Services, you understand and agree to assume these risks. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.

10. Preventing Identity Theft

In order to help us protect your personal information, it is important that you always keep your account information safe. Never share your username, password, or PIN with anyone, under any circumstances.

We will never initiate (unless otherwise stated for a specific product or Service application), a request via email for your sensitive personal information (e.g., Social Security number, personal ID, password, PIN or account number). If you receive an email asking for your sensitive personal information, you should be suspicious of the request and promptly contact us to report the suspicious activity.

Please be aware, however, that in certain transactions we may ask for your full Social Security number, account number or other information to verify your identity before conducting the transactions you have requested. For example, we may ask for such information to verify your identity when you contact us.

Additional information regarding identity theft and the steps you can take to help protect yourself from fraud can be found on our Security page and on the Federal Trade Commission website.

11. Children’s Privacy

We do not use the Services to knowingly solicit personal information from or market to children under the age of eighteen (18) without parental consent. We request that such individuals do not provide personal information through the Services. Only the adult parent or legal guardian of a child under the age of 18 can access our Services, even if a deposit account has been established on behalf of the child. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should promptly contact us and we will delete such information from our files. For additional information regarding the Children’s Online Privacy Protection Act (COPPA), please visit the Federal Trade Commission website.

12. External Aggregation Services

You have the responsibility to help us protect your accounts by never revealing your username, password, or other credentials to any person or third party. By providing your username, password or other credentials to any person or third party (including an aggregation service) you authorize that person or third party to initiate transfers to or from your account.

Some third-party companies offer aggregation services that allow you to consolidate your financial account information from a variety of sources, such that you can view all your account information at a single online location. For example, an aggregation service might collect and consolidate your checking and savings account balances at your bank, the value of your stocks and bonds in your brokerage account and your frequent flier mileage information from an airline. In order to do so, the aggregator may request access to personal information – including identification information, account information, personal IDs and passwords – from you for each individual website.

Please use caution when providing personal information to an aggregation service. By providing your username, password or other credentials to an aggregation service you authorize that person or third party to initiate transfers to or from your account.

Should you decide to revoke the authority you have given to an aggregation service, you should notify the aggregation service in addition to contacting us, in which case we may need to block your account until we issue new access codes.

13. Social Media Platforms

We may interact with users of various social media platforms, including, without limitation, Meta®, Instagram®, X® and LinkedIn®. Please note that any content you post to such social media platforms (for example, pictures, information, or opinions), as well as any personal information that you otherwise make available to users (for example, your profile), is subject to the applicable social media platform’s terms of use and privacy policies. We recommend that you review this information carefully to better understand your rights and obligations with regard to such content.

14. Retention

Retention periods may vary depending on legal obligations, dispute resolution, and operational needs. We retain your personal information for as long as reasonably necessary for the purposes described in this Privacy Policy; to comply with our legal, regulatory and contractual obligations; and to protect ourselves from any potential disputes.

15. Privacy Rights of California Residents

If you are a resident of the State of California, this Privacy Policy includes by incorporation our California Consumer Privacy Notice, that includes additional information required to be provided under California law and can be found via the above link. The California Consumer Privacy Notice also includes instructions for California residents wishing to exercise their right to submit a data privacy request under California law.

16. Cross-Border Transfer

The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any country or territory other than that of the United States.

17. Changes to Our Privacy Policy

We reserve the right to periodically amend this Privacy Policy at our sole discretion at any time. When we make changes to this Privacy Policy, we will post the updated Privacy Policy to our website and update the “Last Updated” date. Any changes will become effective when we post the revised Privacy Policy on the website as of the “Last Updated” date shown at the top of the Privacy Policy. You are responsible for periodically visiting our website and this page to check for any changes and/or updates to this Privacy Policy. By continuing to access or use the Services after the date of any change to the Policy, you agree to be bound by such terms contained in the most recent version of the Policy.

18. Contact Us

Please direct any questions or concerns related to this Privacy Policy to us at [email protected] or by mail to 4558 Osage Beach Parkway, Suite 100, Osage Beach, MO 65065