Privacy Policy

The Board of Directors and management of Strategic Bank International Corp. (hereinafter “Strategic”) understand how important personal privacy is to our customers.  Employees of Strategic have a duty to protect the confidential nature of customers’ financial records.  In the interest of protecting the privacy of our customers, the Board adopts the following Privacy Policy.

Customer Expectations

Strategic knows that our customers expect privacy and security for their personal and financial affairs. We will take all the necessary steps to safeguard sensitive information that has been entrusted to us by our customers. To that end, the following standards and procedures are intended to prevent misuse of customer information.

Permissible Reasons To Collect, Maintain, And Use Information About Our Customers

Strategic will collect, retain, and use information about our customers only when we believe it will help administer our business or provide products, services, and other opportunities to customers. Strategic will collect and retain information about customers only for specific business purposes. When it does so, we will tell our customers why we must gather the information.

The information we gather comes from a variety of sources, including:

  • Information you provide to us (such as information on applications or other forms);
  • Information related to your transactions with us (such as account balance and payment history);
  • Information we receive from credit reporting agencies and other companies (such as your credit history) when you apply for a service;
  • Information obtained when you use Internet products and services (such as transaction information, information contained in e-mails you send us, and cookies); and
  • Strategic must also collect certain information to comply with certain laws and regulations.

Strategic may release customer financial information to sources such as a credit bureau or in response to a valid subpoena, summons or warrant.

Sharing Nonpublic Personal Information

Data Disclosure Restrictions

Strategic follows strict privacy procedures in regard to protection of personal data. No disclosure of personally identifiable information to third parties is allowed unless the related customer has been previously informed or the disclosure has already been authorized by the customer or otherwise is permitted, as disclosed to our Customers, or required by law. In connection with this, we may share the personal information about you that you provide to us with trusted companies we have hired to provide services for us relating to your account such as collecting and processing information on our behalf. These companies are contractually bound to use personal information that we share with them only to perform the services for which they have been hired.

At Strategic, we maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information. We have procedures in place ensuring that we:

  • Collect, retain and use information about our customers only when we believe it will help administer our business or provide products and services for our customers.
  • Maintain internal procedures to ensure that our customers’ financial information is accurate, current, and complete in accordance with laws and regulations.
  • Limit employee access to personally identifiable information to those employees with a business reason to know such information.
  • Take disciplinary measures to enforce employee privacy responsibilities.
  • Maintain security standards and procedures to help prevent unauthorized access to confidential information about our customers.
  • Update and test our technology to improve the protection of our customers’ information.
  • Disclose our privacy policy and commitment to our customers and the use of customer information on our Internet home page.

Fair Credit Reporting Act1

We strive to maintain complete and accurate information about you and your accounts. If you ever believe that our records contain inaccurate or incomplete information about you, please let us know immediately. We are committed to resolving any inaccuracies as quickly as possible.

Credit Reporting Agencies

If you believe we have reported inaccurate information about your account to any credit reporting agency, please let us know in writing as soon as possible. Be sure to include your complete name, current address, social security number, telephone number, account number, type of account, specific item of dispute, and the reason you believe the information is incorrect. Send your notice to

We will investigate your concern and correct any inaccuracies we find. We will inform you of any actions we take.

Right To Financial Privacy Act

The 1978 Right to Financial Privacy Act (RFPA) establishes specific procedures that federal government authorities must follow when seeking customer records. Strategic’s employees will follow those procedures when a U.S. federal agency requests customer financial information.  In the event that we receive an order from a foreign jurisdiction, we will follow the United States law applicable to a request from such jurisdiction.

Children On Line Privacy Protection Act2/FTC Rule (COPPA)

Strategic does not knowingly solicit data from children, and we do not knowingly market to children. We recognize that protecting children’s identities and privacy online is important and that the responsibility to do so rests with both the online industry and with parents.


Disclosure of Customer Information

Strategic’s customer information will only be disclosed to authorized account holders, and only after identification of that account holder has been verified. Verifying information may include social security number, date and/or place of birth, mother’s maiden name, signature and we will ask that the request be made via live video.

Strategic’s employees will not share personal or financial customer information with unaffiliated third parties except when legally required (in order to comply with federal or state laws/regulations, and government or court orders) or when legally permitted to serve the customer’s interests (such as disclosure to reputable credit reporting agencies). Information will only be disclosed to third parties under the following conditions:

  1. Where it is necessary to complete a transaction initiated by the customer;
  2. In order to report the existence and condition of an account to companies such as reputable credit bureaus;
  3. In order to comply with government or court orders; or
  4. If we have the written permission of the account holder.

Strategic will provide certain customer information to unaffiliated third party companies that we hire to provide us operational support. These unaffiliated third party companies provide services that allow us to complete transactions including real estate loans. Examples of these services include, but are not limited to, appraisals, title searches, flood certifications, and credit reports. All agreements between Strategic and third parties will include confidentiality and restrictions-of-use obligations.

Website Security

Strategic has implemented technology to help assure that any sensitive personal information you provide us or any account information you receive on-line is done in a safe and secure manner. Special secured-connection hardware and software (commonly called “firewalls”) are in place to help assure the security of online communication of your information.

Additionally, we have implemented procedures to help assure that only authorized Strategic employees may view the information you share with us. This is accomplished by limiting access to that information (via access capability and password control) to only those employees having a legitimate business purpose for viewing or responding to your information or inquiries.

Website Privacy

Our website includes sections that are public (not password protected) and areas that are password protected (for example customer banking areas). When any person visits the public areas of our website, we may collect certain basic information, such as how many people visited our site and what pages were visited.

Unlike the personal information that you provide and view with respect to your personal banking relationship (which is subject to the security procedures described above), all of the information we may gather in the public areas of our website is general. We use this general information to determine which parts of our website are most popular, how people access our site, how we can improve the content of our web pages and how we can improve service to our customers.

Also included in Strategic’s website is the capability for you to interact with us. This correspondence, via e-mail or phone, may be for the purpose of asking general questions, requesting literature, or responding to Strategic’s promotions. These activities may include sharing some personal information about you with us.


[1] 15 U.S.C. 1681 et seq