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Silicon Valley Bridge Bank, N.A. is a newly created, full-service FDIC-operated
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PRIVACY NOTICE

LAST UPDATED: November 1, 2022

SVB Financial Group's businesses and divisions include Silicon Valley Bank, SVB
Capital, SVB Private Bank a division of Silicon Valley Bank, SVB Investment
Services Inc., SVB Wealth LLC, and other affiliated organizations. SVB Financial
Group and its subsidiaries (collectively, "SVB," "we," or "us") want you to be
familiar with how we collect, use, and disclose data. When we refer to SVB in
this Privacy Notice, we are referring to the company in the SVB Financial Group
with which you interact.


TABLE OF CONTENTS

 1.  SCOPE AND APPLICATION
     
     
     This section sets out the applicability of this Privacy Notice and provides
     links to other applicable notices.

 2.  THE DATA WE COLLECT ABOUT YOU
     
     
     This section describes the type of data we collect about you.

 3.  HOW WE COLLECT YOUR PERSONAL DATA
     
     
     This section describes how we collect the Personal Data.

 4.  HOW WE USE YOUR PERSONAL DATA
     
     
     This section describes how we use your Personal Data.

 5.  HOW WE DISCLOSE YOUR PERSONAL DATA
     
     
     This section explains how we disclose your Personal Data.

 6.  SECURITY
     
     
     This section describes the measures we have in place to protect your
     Personal Data.

 7.  YOUR RIGHTS AND CHOICES
     
     
     This section describes the choices and individual rights that you may have
     with respect to your Personal Data.

 8.  RETENTION PERIOD
     
     
     This section addresses the measures we have in place for retaining Personal
     Data.

 9.  THIRD-PARTY SERVICES
     
     
     This section explains that we are not responsible for the information use,
     disclosure, security, and other practices of third parties.

 10. USE OF THE SERVICES BY MINORS
     
     
     This section explains that our services are not directed to individuals
     under the age of sixteen (16).

 11. JURISDICTION AND CROSS-BORDER TRANSFER
     
     
     This section addresses where Personal Data may be processed, and it
     identifies the measures in place for our transfer of Personal Data outside
     of the EEA and the UK.

 12. UPDATES TO THIS PRIVACY NOTICE
     
     
     This section explains that we may update this Privacy Notice from time to
     time and directs our users to the "Last Updated" legend above to learn when
     the notice was last updated.

 13. CONTACT US
     
     
     This section includes our contact details.

 


1. SCOPE AND APPLICATION

This Privacy Notice describes our practices in connection with data that we
collect through:

 * Websites operated by us from which you are accessing this Privacy Notice;
 * Software applications made available by us for use on computers and mobile
   devices ("apps");
 * Our social media pages;
 * Email messages that we send to you that link to this Privacy Notice; and
 * If you are outside the U.S., communications and interactions we have with
   you.

If you are a client of SVB Private Bank, Investment Services Inc., or SVB Wealth
LLC, please click here for an additional privacy notice applicable to you. If
you are a client of SVB Capital entities or SVB Securities, please click here
for an additional privacy notice applicable to you.

If you are a California resident with whom we interact in a consumer context but
who are not yet our client, such as prospective clients, including those who use
our consumer-focused online properties, or if you are a California resident and
a past, current, or prospective employee of SVB Financial Group or an emergency
contact or beneficiary of any such employee, click here for the SVB California
Consumer Privacy Act (CCPA) Notice. If you are a California resident who is also
a client, other privacy notices will be made available to you or mailed to you.


2. THE DATA WE COLLECT ABOUT YOU

"Personal Data" is data that identifies you as an individual or relates to you
as an identifiable individual. We may collect the following kinds of Personal
Data about you:

 * Identity Data, including name, username or similar identifier, date of birth,
   gender, marital status, and title.
 * Contact Data, including postal address, email address, and telephone numbers.
 * Financial Data, including bank account and payment card details.
 * Identification Data, such as Social Security number, driver's license or
   passport numbers.
 * Transaction Data, including details about payments to and from your bank
   accounts and other details of products and services you have purchased from
   us.
 * Device Data, including your Internet Protocol (IP) address, your login data,
   the domain and host from which you access the Internet, the date and time you
   access our online properties, browser and operating system data and the
   Internet address of the site from which you linked to our website.
 * Profile Data, including your username and password and your transactions,
   interests, communications and other preferences, feedback, and survey
   responses.
 * Usage Data, including data about how you use our websites and apps, products,
   and services.
 * Biometric data, including fingerprints, voice recordings or keystroke
   patterns.
 * Derived device geolocation information, such as approximate geographic
   location inferred from an IP address.
 * Marketing and Communications Data, including correspondence and other
   communications for the purposes of providing client support and your
   communication preferences.

We may change your data in a way that makes it unrecognizable as your Personal
Data, and it will no longer be considered Personal Data. To the extent that the
data we collect is not considered Personal Data under applicable law, we may use
and disclose it for other purposes.

Please do not send us any sensitive Personal Data if you are not a client. This
includes Social Security numbers, information related to racial or ethnic
origin, political opinions, religion or other beliefs, health, biometrics or
genetic characteristics, criminal background, or trade union membership.

If you disclose any Personal Data relating to other people (such as our clients'
beneficial owners) to us, you represent that you have the authority to do so and
to permit us to use the data in accordance with this Privacy Notice.


3. HOW WE COLLECT YOUR PERSONAL DATA

We collect Personal Data when you choose to provide it to us, such as when you
apply to open an account with us and receive banking or other services for
personal, family, or household purposes or on behalf of your employer. We also
collect Personal Data when you sign up to use our services or receive our
publications; request marketing material to be sent to you; complete a survey or
questionnaire; contact customer service or otherwise communicate with us; or
provide us with feedback.

We also collect certain Personal Data automatically from your interactions with
our online properties, including:

 * Through your browser or device. Certain data is collected by most browsers or
   automatically through your device, such as your Media Access Control (MAC)
   address, computer type, screen resolution, operating system name and version,
   device manufacturer and model, language, Internet Protocol (IP) address, and
   browser type and version. We use this data to ensure that our online services
   function properly. We may also derive your approximate location from your IP
   address.
 * Through your use of our apps. When you download and use one of our apps, we
   may track and collect app usage data, such as the date and time the app on
   your device accesses our servers, in order to ensure that the app functions
   properly and to understand how it is used.
 * Through the use of cookies and similar tracking technologies. If you interact
   with us online, you may encounter cookies. There will be a cookie notice you
   can read to learn how we use cookies and similar tracking technologies on our
   digital properties, including for analytics and advertising purposes. We do
   not currently respond to browser do-not-track signals.
 * Physical Location. We may collect the physical location of your device by,
   for example, using satellite, cell phone tower, or Wi-Fi signals, for fraud
   prevention and in order to provide you with personalized location-based
   services and content. You may be able to manage the collection settings of
   your device's location.

In addition, we receive your Personal Data from other sources, such as third
parties and publicly available sources, including, for example, social media
platforms, publicly available databases, government agencies, credit reference
and financial crime prevention agencies, consumer reporting agencies, specialist
data and research companies, and event or joint marketing partners.


4. HOW WE USE YOUR PERSONAL DATA

 A. For Individuals outside the European Economic Area ("EEA")
    
    We use Personal Data for the following purposes:
    
    * Providing our products and services or fulfilling your requests.
      
      * To communicate with you, to share important notices or advertising;
      * To evaluate your or your employer's eligibility for products and
        services;
      * To provide you or your employer with products and services, including
        opening and maintaining your account; managing payments, fees, and
        charges; collecting amounts owed to us; processing your transactions;
        and providing you with related customer service;
      * To respond to your questions and fulfill your requests and otherwise
        manage our relationship with you or your employer;
      * To send administrative information to you, such as changes to our terms,
        conditions, and policies.
    * Providing you with our newsletter or other marketing materials.
      
      * To send you marketing related emails, with information about our
        services, products, and other SVB news. If you do not want to receive
        marketing materials, you may opt out of those marketing communications
        at any time by following the opt-out instructions contained in the
        marketing messages or by contacting us.
    * Analyzing Personal Data for providing personalized content and improving
      services.
      
      * To analyze or predict users' preferences in order to improve our online
        services;
      * To better understand your interests and preferences, so that we can
        personalize our interactions with you and provide you with content,
        information, and offers that we believe will be relevant and interesting
        to you.
    * Accomplishing our business purposes.
      
      * For data analysis, including to improve the efficiency of our digital
        services;
      * For audits, to verify that our internal processes function as intended;
      * To address legal, regulatory, or contractual requirements, including
        requirements intended to prevent money laundering;
      * To control risk of fraud and for security monitoring purposes, such as
        to detect and prevent cyberattacks or attempts to commit identity theft
        or other fraud;
      * For enhancing, improving, maintaining, or modifying our products and
        services, as well as undertaking quality and safety assurance measures;
      * For identifying and understanding usage trends;
      * For determining the effectiveness of our promotional campaigns, so that
        we can adapt our campaigns to the needs and interests of our existing
        and prospective clients;
      * For troubleshooting, testing, system maintenance and reporting
    
     

 B. For Individuals in the EEA and Individuals with SVB Cayman Island Funds
    
    Most commonly, we will use your Personal Data in the following
    circumstances:
    
    * Where we need to perform the contract we are about to enter into or have
      entered into with you.
    * Where we need to comply with a legal or regulatory obligation.
    * Where it is necessary for our legitimate interests (or those of a third
      party) and your interests and fundamental rights do not override those
      interests.
    
    Generally, we do not rely on consent as a legal basis for processing your
    Personal Data. However, in relation to sending direct marketing
    communications to you, we may rely on legitimate interests or consent. If
    you do not want to receive marketing materials, you may opt out of those
    marketing communications at any time by following the opt-out instructions
    contained in the marketing messages or by contacting us.
    
    We have set out in the table below a description of the ways we use your
    Personal Data and which of the legal bases we rely on to do so. We have also
    identified our legitimate interests, where appropriate.
    
    We may process your Personal Data on more than one lawful ground, depending
    on the specific purpose for which we are using your data. Please contact us
    if you would like details about the specific legal basis on which we rely,
    if more than one is set out in the table below.
    
    Purpose/Activity Type of data Legal basis for Processing To register your
    employer as a new client (a) Identity
    (b) Contact
    (c) Identification Performance of a contract with your employer (our client)
    To provide banking and other services to your employer (our client):
    (a) Manage payments, fees and charges
    (b) Collect and recover money owed to us (a) Identity
    (b) Contact
    (c) Financial
    (d) Transaction
    (e) Marketing and Communications (a) Performance of a contact with your
    employer (our client)
    (b) Necessary for our legitimate interests (to recover debts due to us) To
    manage our relationship with your employer (our client) which will include:
    (a) Notifying you about changes to our terms or privacy notice
    (b) Asking you to leave a review or take a survey (a) Identity
    (b) Contact
    (c) Profile
    (d) Marketing and Communications (a) Performance of a contract with your
    employer (our client)
    (b) Necessary to comply with a legal obligation
    (c) Necessary for our legitimate interests (to keep our records updated and
    to study how clients use our products/services) To enable you to partake in
    a competition or complete a survey (a) Identity
    (b) Contact
    (c) Profile
    (d) Usage
    (e) Marketing and Communications (a) Performance of a contract with your
    employer (our client)
    (b) Necessary for our legitimate interests (to study how clients use our
    products/services, to develop them and grow our business) To administer and
    protect our business and our online properties (including troubleshooting,
    data analysis, testing, system maintenance, support, reporting and hosting
    of data) (a) Identity
    (b) Contact
    (c) Device (a) Necessary for our legitimate interests (for running our
    business, provision of administration and IT services, network security, to
    prevent fraud and in the context of a business reorganisation or group
    restructuring exercise)
    (b) Necessary to comply with a legal obligation To deliver relevant online
    content and marketing to you and measure or understand the effectiveness of
    the marketing we serve to you (a) Identity
    (b) Contact
    (c) Profile
    (d) Usage
    (e) Marketing and Communications
    (f) Device (a) Necessary for our legitimate interests (to study how clients
    use our products/services, to develop them, to grow our business and to
    inform our marketing strategy)
    (b) With your consent, where required by applicable law To use data
    analytics to improve our online properties, products/services, marketing,
    client relationships and experiences (a) Device
    (b) Usage Necessary for our legitimate interests (to define types of clients
    for our products and services, to keep our online properties updated and
    relevant, to develop our business and to inform our marketing strategy) To
    make suggestions and recommendations to you about products/services that may
    be of interest to you (a) Identity
    (b) Contact
    (c) Device
    (d) Usage
    (e) Profile Necessary for our legitimate interests (to develop our
    products/services and grow our business)


5. HOW WE DISCLOSE YOUR PERSONAL DATA

We disclose Personal Data:

 * To third party organizations and public bodies, including law enforcement
   agencies, to prevent and detect fraud.
 * To our affiliated and third party service providers, to facilitate services
   they provide to us in connection with the uses described in Section 4.
   * Our affiliated service providers within the SVB Financial Group and
     third-party service providers are based in the U.S., U.K., Canada, Germany,
     Israel, China, Hong Kong, India, Ireland, Denmark, Sweden and the Cayman
     Islands, and they may provide information technology, system
     administration, and other services to us.
   * Our service providers may also provide such services as website hosting,
     data analysis, customer service, email delivery, and auditing.
 * To our affiliates, to permit them to send you marketing communications.
   * For a list of the affiliates with which we share Personal Data, along with
     the locations of those affiliates, please contact us.

We also use and disclose your Personal Data as necessary or appropriate, in
particular when we have a legal obligation or legitimate interest to do so:

 * To comply with applicable law and regulations.
   * These may include laws outside your country of residence.
 * To cooperate with law enforcement and government authorities.
   * To respond to a request or to provide information when we believe necessary
     or appropriate.
 * For other legal reasons.
   * To enforce our terms and conditions or other agreements with our users and
     customers; and
   * To protect our rights, privacy, safety, or property, and/or that of our
     affiliates, you, or others.
 * In connection with a sale or business transaction.
   * We have a legitimate interest in disclosing or transferring your Personal
     Data to a third party in connection with a reorganization, merger, sale,
     joint venture, assignment, transfer, or other disposition of all or any
     portion of our business, assets, or stock (including in connection with any
     bankruptcy or similar proceedings). After the transfer is complete, if all
     or part of our assets are sold, then your Personal Data may be transferred
     to the new owner so services can continue to operate.


6. SECURITY

We use reasonable organizational, technical, and administrative measures to
protect Personal Data within our organization. Unfortunately, no data
transmission or storage system can be guaranteed secure. 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.


7. YOUR RIGHTS AND CHOICES

You may opt out from receiving marketing emails from us by following the
instructions contained in each email, or visit our Preference Center at. Even if
you opt out of marketing emails from us, we will continue to send you important
administrative messages. You may opt out of receiving push notifications from us
through the settings of your device.

Depending on your jurisdiction and our relationship with you, you may have
certain privacy rights that you can exercise. These rights include the right to
request to access, correct, modify, update, restrict processing, revoke consent,
or delete Personal Data, to object to or opt out of the processing of Personal
Data, or to receive a copy of your Personal Data for purposes of transmitting it
to another company. To exercise these rights, you can contact us in accordance
with the "Contact Us" section below or click here. We will respond to your
request consistent with applicable law.

If you are a California resident, please see the CCPA Notice link in Section 1
or to exercise your privacy rights, you can click here.

You may make a privacy complaint with our DPO or with an EEA of UK data
protection authority for your country or region where you have your residence or
place of work or where an alleged infringement of applicable data protection law
has occurred. A list of EEA data protection authorities is available at
https://edpb.europa.eu/about-edpb/board/members_en. Information regarding the UK
data protection authority is available here: https://ico.org.uk/. In the Cayman
Islands, you can submit a complaint to the Ombudsman. For more information, see
the Cayman Islands privacy regulator site: https://ombudsman.ky/data-protection.
We would, however, appreciate the chance to address your concerns before you
approach a data protection authority, so please contact us first.


8. RETENTION PERIOD

We retain Personal Data for as long as needed or permitted to fulfill the
purpose(s) for which it was obtained, including to satisfy any legal,
compliance, accounting, or reporting requirements, and consistent with
applicable law. We consider the following when determining our retention
periods:

 * The length of time we have an ongoing relationship with you and provide our
   products and services to you (for example, for as long as you have an account
   with us or continue to use our digital services);
 * Whether there is a legal obligation to which we are subject (for example, to
   keep records of your transactions for a certain period of time);
 * Whether retention is advisable in light of our legal position, such as in
   regard to applicable statutes of limitations, litigation, or regulatory
   investigations;
 * Our records retention schedule tiers


9. THIRD-PARTY SERVICES

This Privacy Notice does not address the privacy, data, or other practices of
any third parties, including any third party operating a website or service to
which our online services link. The inclusion of a link on our online services
does not imply endorsement of the linked site or service by us or our
affiliates.


10. USE OF THE SERVICES BY MINORS

Our services are not directed to individuals under the age of sixteen (16), and
we do not knowingly collect Personal Data from, or direct any of our products or
service to, individuals under age 16.


11. JURISDICTION AND CROSS-BORDER TRANSFER

Your Personal Data may be stored and processed in any country where we have
affiliates or in which we engage service providers. You understand that your
data will be transferred to countries outside of your country of residence,
including the United States, which may have data protection rules that are
different from those of your country. In certain circumstances, courts, law
enforcement agencies, regulatory agencies, or security authorities in those
other countries may be entitled to access your Personal Data.

ADDITIONAL INFORMATION REGARDING THE EEA and the UK: Some non-EEA countries are
recognized by the European Commission as providing an adequate level of data
protection according to EEA standards (the full list of these “specified”
countries is available here.) The UK recognizes the EEA and the specified
countries as providing an adequate level of data protection according to UK
standards. For transfers from the EEA or the UK to countries not considered
adequate by the European Commission or the UK government, as applicable, we have
put in place applicable measures where necessary, such as standard contractual
clauses to protect your Personal Data. You may obtain a copy of these measures
by clicking here.


12. UPDATES TO THIS PRIVACY NOTICE

The "LAST UPDATED" legend at the top of this Privacy Notice indicates when this
Privacy Notice was last revised. Any changes will become effective when we post
the revised Privacy Notice on our online services.


13. CONTACT US

SVB Financial Group, located at 3003 Tasman Drive, Santa Clara, CA 95054, is the
entity responsible for collection, use, processing and disclosure of Personal
Data under this Privacy Notice.

If you have questions about this Privacy Notice, please contact us at
privacyoffice@svb.com. Because email communications are not always secure,
please do not include sensitive data in your emails to us. Options to contact
us:


By phone:
+1 (800) 774-7390 (U.S.)

By postal mail:
Chief Privacy Officer
SVB Financial Group
3003 Tasman Drive
Santa Clara, CA 95054

By email:
PrivacyOffice@svb.com


By phone:
+44 207 367 7800

By postal mail:
Data Protection Officer (DPO)
SVB Financial Group
Alphabeta
14-18 Finsbury Square
London EC2A 1BR

By email:
dataprotectionofficer@svb.com

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These cookies allow us to count visits and traffic sources so we can measure and
improve the performance of our site. They help us to know which pages are the
most and least popular and see how visitors move around the site.    All
information these cookies collect is aggregated and therefore anonymous. If you
do not allow these cookies we will not know when you have visited our site, and
will not be able to monitor its performance.

FUNCTIONAL COOKIES

Functional Cookies

These cookies enable the website to provide enhanced functionality and
personalisation. They may be set by us or by third party providers whose
services we have added to our pages.    If you do not allow these cookies then
some or all of these services may not function properly.

TARGETING COOKIES

Targeting Cookies

These cookies may be set through our site by our advertising partners. They may
be used by those companies to build a profile of your interests and show you
relevant advertisements on other sites. They do not store directly personal
information, but are based on uniquely identifying your browser and internet
device. If you do not allow these cookies, you will experience less targeted
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