CCPA Privacy Notice

Your privacy is important to us at WSFS Bank, Bryn Mawr Capital Management, LLC, Bryn Mawr Trust Company of Delaware and WSFS Wealth Management, LLC (along with any affiliates and subsidiaries, “WSFS,” “we,” “us,” or “our”), and we are committed to safeguarding, preserving, and respecting your privacy rights.  If you are a California resident, you have certain rights with respect to the collection, use, transfer, and processing of your personal information, as defined by the California Consumer Privacy Act (“CCPA”), Cal. Civ. Code § 1798.100 et seq., as amended by the California Privacy Rights Act (“CPRA”) and implementing regulations.  We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others.

Applicability

This California Privacy Policy (“Policy”) describes how we collect, use, share, disclose, retain, and secure the personal information covered under the CCPA, including through our website, https://www.wsfsbank.com/ (the “Site”), when you interact with us as a customer, or otherwise (collectively, the “Services”).

Under the CCPA, personal information means information that identifies, relates to, or could reasonably be linked directly or indirectly to a particular California resident. It also includes certain categories of information that qualify as Sensitive Personal Information, identified below.  Please note that the CCPA does not apply to certain categories of information, such as those subject to the Gramm-Leach Bliley Act (“GLBA”). Therefore, this Policy does not apply to information that we collect about California residents who apply for or obtain or financial products and services for personal, family, or household purposes. Such customers can learn more by viewing our Privacy Notice, available here.

What Information Do We Collect?

The below examples are illustrative examples from the CCPA as defined by Cal. Civ Code § 1798.140(v) and may not reflect the specific pieces of information we collect.

In the previous 12 months, we have collected the following categories of personal information from California residents:

Sources from Which Personal Information Is Collected

We collect your personal information directly from you, from your interaction with the Site, from publicly available sources, and from third parties and affiliates, which collect the personal information directly from you or from publicly available information.

Business or Commercial Purposes for Which Personal Information Is Collected

Your personal information is used for the following purposes:

• To present our Services and its contents in a suitable and effective manner for you and your device;
• To provide our Services, including banking and related financial services;
• To contact you to provide you with information or services that you request from us;
• To advertise opportunities, services, or special events that we think may be of interest to you;
• To provide customer support, troubleshoot issues, manage accounts, and respond to requests, questions, or comments;
• To carry out our obligations and enforce our rights arising from any contracts; and
• To notify you about any additions, upgrades, or changes in our services.

Third Parties to Whom Personal Information Is Disclosed, Shared, or Sold

In the preceding 12 months, we have disclosed each category of personal information with the following categories of entities for business purposes:

• Our Affiliates;
• Service providers and contractors who provide essential services, such as analytics, hosting, customer service, email, marketing, related IT, financial services;
• Professional service providers, such as attorneys, tax consultants, real estate experts, and notaries;
• We disclose content posted on our social media platforms (e.g., if a consumer “comments” on a story) with other consumers. Such posts may include personal information in categories A and B, but the content depends on the individual posts.
• We may disclose all of our information, including your personal information, with our subsidiaries and affiliates in connection with providing the Services to you or otherwise in connection with business operations.

In the preceding 12 months, we have shared for cross-contextual behavioral advertising the following the personal information in categories A (identifiers), B (personal), D (commercial), F (internet), G (geolocation), K (inferences), and L (Sensitive).

In the preceding twelve (12) months, we have not sold the personal information of any consumer for monetary consideration.  However, our use of cookies and other tracking technologies may be considered a sale or sharing of personal information under the CCPA.  Categories of personal information that we have sold under the CCPA include categories A (identifiers), B (personal), D (commercial), F (internet), G (geolocation), K (Inferences), and L (Sensitive).  Categories of third parties to whom personal information is sold or shared under the CCPA include data analytics providers and advertising and marketing providers.

Please note that your use of our website will still be tracked by WSFS and its service providers.

We do not have actual knowledge that we sell or share the personal information of consumers under sixteen (16) years of age.

We do not process Sensitive Personal Information for purposes other than those authorized under California law, which include but are not limited to:

• the performance of the Services reasonably expected by an average California resident;
• detection and prevention of security incidents or other malicious activity;
• Short-term, transient uses, including but not limited to non-personalized advertising shown as part of your current interaction with us; and
• To perform services such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying a California resident’s information, processing payments, providing financing, providing analytic services, and providing storage.

Retention of Personal Information

The length of time that we intend to retain each category of Personal Information depends on a number of criteria, including (i) the nature of our relationship with you; (ii) any legally required data retention periods; (iii) the length of time we may need to retain your information in order to accomplish the business or commercial purpose(s) for which we process such information; and (iv) whether you choose to exercise your right, subject to certain exceptions, to request deletion of your information.

Individual Rights

1. Right to Know About Personal Information Collected, Disclosed, Shared or Sold

You have the right to request that we disclose the personal information we collect, use, and disclose about you to third parties.  There are two types of Rights to Know requests that you can make:

1. Right to Know (Abbreviated Request):  If you make a Right to Know (Abbreviated Request), you will receive the following information about you:
   1. Categories of personal information collected, sold or shared;
   2. Categories of sources from which personal information is collected;
   3. Categories of third parties to whom the information is sold, shared or disclosed;
   4. Business or commercial purpose for collecting, sharing or selling personal information;
   5. Categories of personal information disclosed for a business purpose and categories of persons to whom it was disclosed for a business purpose.
2. Right to Know (Specific Pieces of Information Request):  If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:
   1. Specific pieces of personal information collected about you.

This information will be provided to you free of charge, unless we determine that your request is manifestly unfounded or excessive.  You may request this information twice in a 12-month period.

There are certain exceptions to a consumer’s Right to Know.  We will state in our response if an exception applies.

2. Right of Deletion

You have the right to request that we and our service providers delete any personal information about you which we have collected from you upon receipt of a verifiable request.  This right is subject to certain exceptions.  We will state in our response if an exception applies.

3. Right to Opt-Out of the Sale or Sharing of Personal Information

You have the right to opt-out of the sale or sharing of your personal information by a business subject to certain laws and regulations.

Please note that opt-out choices may be stored via cookies.  If you clear cookies, if your browser blocks cookies, or if you view the page from a different browser or device, your opt-out choice may no longer be logged or recognized.

For more information, please visit our Do Not Sell or Share My Personal Information page.

4. Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising the privacy rights conferred by California law.  We will not discriminate against you because you exercised any of your privacy rights, including, but not limited to, by: denying goods or services to you; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level of quality of goods or services to you; or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.  We will also not retaliate against any employee, applicant for employment, or independent contractor for exercising their rights under the CCPA.

5. Right of Correction

If we maintain inaccurate personal information about you, then you have the right to request that we correct the inaccurate personal information upon receipt of a verifiable request.  Taking into account the nature of the personal information and purposes of processing the personal information, you have the right to request that we correct inaccurate personal information about you, if applicable.

6. Right to Limit Use and Disclosure of Sensitive Personal Information

As identified above, we do not processed Sensitive Personal Information for purposes beyond those authorized under California law.

Submitting Requests

You can submit your request by emailing us at [email protected], by toll-free phone at 888.973.7226, or online request form.

Verifying Requests

To ensure the protection of your personal information, we must verify that the individual submitting a request to know, request to delete, or request to correct is the consumer to whom the request relates prior to processing the request.  To verify a California consumer’s identity, we may request up to three pieces of personal information about you when you make a request to compare against our records.  We may also request that you sign a declaration under the penalty of perjury from the consumer whose personal information is the subject of the request.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in your request to verify your identity and will delete any information you provide after processing the request.  We reserve the right to take additional steps as necessary to verify the identity of California consumers where we have reason to believe a request is fraudulent.

Authorized Agents

You may choose a person or a business registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”).  If you choose to use an Authorized Agent, we require that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with us.  Failure to do so may result in WSFS denying your request.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email at [email protected] or by toll-free phone at 888.973.7226.