California Consumer Privacy Act Disclosure

Effective 1/1/2020

Your privacy is important to us. This California Consumer Privacy Act Disclosure explains how Farmers & Merchants Bank of Central California and Farmers & Merchants Bancorp (“Company,” “Bank”, “we,” or “us”) collect, use, and disclose personal information relating to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”). This notice is provided pursuant to the CCPA.

What Personal Information is Covered?

‘Personal Information’ is defined under the CCPA to include any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with a particular consumer or household. Examples include social security numbers, account information, transaction histories, credit information, and biometric data.

What Personal Information is Not Covered?

Much of the personal information that we collect is already regulated by federal and state laws, and therefore is exempt from the CCPA. For instance, the CCPA does not apply to personal information collected or disclosed in connection with financial products or services that are used primarily for personal, family, or household purposes. The CCPA also does not apply to information that is governed by the privacy, security and breach notification rules issued by the U.S. Department of Health and Human Services pursuant to Health Insurance Portability and Accountability Act. Currently, the CCPA does not apply to personal information that reflects a communication or transaction between us and another company, partnership, sole proprietorship, non-profit, or government agency, so long as that communication or transaction involves due diligence about the us or the other business, or if we are providing a product or service.

For more information about how we collect, disclose, and secure information relating to personal information not covered by CCPA (as listed above), please refer to our Online Privacy Notice. For more information about our Regulation P privacy notice, please refer to our Privacy Policy.

The CCPA also currently does not afford access or deletion rights if your information was collected and used by us in the context of your role as a job applicant, employee, director, officer, or contractor of the Bank.

Keeping Personal Information secure is one of our most important priorities. Consistent with our obligations under applicable laws and regulations, we maintain physical, technical, electronic, procedural and organizational safeguards and security measures that are designed to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, or access, whether it is processed by us or elsewhere.

Collection and Disclosure of Personal Information

In the past 12 months, we have collected, and disclosed to third parties for our business purposes, the following categories of Personal Information relating to California residents covered by this disclosure:

  • Audio, electronic, visual and similar information, such as call and video recordings.
  • Background check reports, such as criminal history.
  • Characteristics of protected classifications under California or federal law, such as sex and marital status.
  • Geolocation data, such as device location and Internet Protocol (IP) location.
  • Identifiers, such as name and government-issued identifier (e.g., Social Security number).
  • Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an  individual’s preferences and characteristics.
  • Internet or network activity information, such as browsing history and interactions with our website.
  • Personal information, as defined in the California safeguards law, such as contact information and financial information.
  • Professional or employment-related information, such as work history and prior employer.
  • Relevant non-public licenses and certifications

The categories of sources from which we collected this Personal Information are:

  • Directly from a California resident or the individual’s representatives.
  • Mobile Application, Online Banking, and Bill Pay.
  • Public Record Sources (Federal, State or Local Government Sources).
  • Service Providers.
  • Websites.

The categories of third parties to whom we disclosed Personal Information for our business purposes described in this privacy disclosure are:

  • Government Agencies as required by laws and regulations.
  • Partners and Third Parties who provide services such as storage, legal expertise, tax expertise, and auditors.
  • Vendors and Service Providers who provide services such as website hosting, information technology and related infrastructure, employment background checks, customer service, email delivery, auditing, and marketing.

Use of Personal Information

In the past 12 months, we have used Personal Information relating to California residents to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including the following:

  • Assessing qualifications for hiring and promotion as permitted by law.
  • Auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
  • Complying with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reflecting legal or regulatory guidance, codes or opinions).
  • Debugging to identify and repair errors that impair existing intended functionality.
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
  • Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services.
  • Undertaking activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance the service controlled by the business.

Sale of Personal Information

In the past 12 months, we have not “sold” Personal Information subject to the CCPA. For purposes of this Disclosure, “sold” means the disclosure of Personal Information to a third-party for monetary or other valuable consideration.

Rights under the CCPA

If your Personal Information is covered by the CCPA, you have the right to:

  1. Request we disclose to you free of charge the following information covering the 12 months preceding your request:
    1. the categories of Personal Information about you that we collected;
    2. the categories of sources from which the Personal Information was collected;
    3. the purpose for collecting Personal Information about you;
    4. the categories of third parties to whom we disclosed Personal Information about you and the categories of Personal Information that was disclosed (if applicable) and the purpose for disclosing the Personal Information about you; and 
    5. the specific pieces of Personal Information we collected about you;
  2. Request we delete Personal Information we collected from you, unless the CCPA recognizes an exception; and
  3. Be free from unlawful discrimination for exercising your rights under the CCPA

We will acknowledge receipt of your request and advise you how long we expect it will take to respond if we are able to verify your identity. Requests for specific pieces of Personal Information will require additional information to verify your identity.

If you submit a request on behalf of another person, we may require proof of authorization and verification of identity directly from the person for whom you are submitting a request.

In some instances, we may not be able to honor your request. For example, we will not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual. Additionally, we will not honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer or where the Personal Information that we maintain about you is not subject to the CCPA’s access or deletion rights.

We will advise you in our response if we are not able to honor your request. We will not provide social security numbers, driver’s license numbers or government issued identification numbers, financial account numbers, health care or medical identification numbers, account passwords or security questions and answers, or any specific pieces of information if the disclosure presents the possibility of unauthorized access that could result in identity theft or fraud or unreasonable risk to data or systems and network security.

We will work to process all verified requests within 45 days pursuant to the CCPA. If we need an extension for up to an additional 45 days in order to process your request, we will provide you with an explanation for the delay.

How to Exercise Your Rights

If you are a California resident, you may submit a request by:

  1. Writing to us at 121 W. Pine St, Lodi CA 95240
  2. Calling (800) 888-1498, M-F, 8am-6pm, PT

Changes to This California Consumer Privacy Act Disclosure

We may change or update this Disclosure from time to time. When we do, we will post the revised Disclosure on this page with a new revision date.