Old Glory Bank Ownership Opportunity

Privacy Notice

Last Updated March 6, 2024

Protecting your private information is our priority. This Privacy Statement (“Statement”) applies to the Old Glory Holding Company website (own.oldglorybank.com) provided by Old Glory Holding Company (“HoldCo”, “our”, “us”, or “we”) and governs data collection and usage. The laws of the United States and as applicable, the State of California, apply. If you are a resident of California, please see the Privacy Notice for Residents of California below.

Please be aware that by using the website or submitting your personal information to us, you authorize HoldCo to use your information in order to provide you information and opportunities associated with your submission of personal information.

How We Use Information Collected by Us

HoldCo collects information about you to provide the best consumer experience possible. That data collection allows us to:

Customize your experience within the website;

Support you as a user and a consumer, respond to your inquiries and communications;

Contact you for purposes such as customer service, updates to the services and products offered through our affiliate Old Glory Bank ^®, or additional opportunities for investment in HoldCo.

Improve the Services and the consumer experience by trend and preference analysis.

Information that We Collect from You

When you use the website, HoldCo may collect the following information from you:

Full name
Email address
Telephone number
IP address

HoldCo does not collect any personal information about you unless you voluntarily provide it to us. However, if you choose to use the services or products provided by our affiliate, Old Glory Bank ^®, you may be required to provide additional personal information. Should you choose to use services or products provided by Old Glory Bank ^®, the privacy notice, customer disclosures, and terms and conditions will govern your relationship with Old Glory Bank ^®.

What are the legal bases for HoldCo to collect information about me?

Sending you information about investment opportunities with HoldCo and product and services information, special offers, and similar information related to our affiliate Old Glory Bank ^®.

Please note that on other occasions when we ask you for consent, we will explain what purposes the information will be used for, at that time. Where we need your consent to process information, you can withdraw your consent to such processing at any time.

Tracking User Behavior

HoldCo may keep track of your actions and submissions through the website in order to determine which HoldCo services are the most popular.

Automatically Collected Information

Information about your device hardware and software may be automatically collected by HoldCo. This information can include: your IP address, browser type, domain names, and access. This information is used for the operation of the website, to maintain quality of the website, and to provide general statistics regarding use of the website.

Security of your Personal Information

HoldCo is committed to protecting the security of all the personal information we collect and use.

We use a variety of physical, administrative, and technical safeguards designed to help protect it from unauthorized access, use, and disclosure. We have implemented and continually progress these safeguards based on best-practice standards and controls in compliance with internationally recognized security frameworks, as well as the use of encryption technologies to protect data at-rest and in-transit.

Children Under Thirteen Years Old

HoldCo does not intentionally collect personally identifiable information from children under the age of thirteen. If you have reason to believe that someone under the age of 13 has provided information to HoldCo through the website, please contact us using the details below so that we can remove this information from our systems, if possible.

E-mail Communications

From time to time, HoldCo may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. In order to improve our website, we may receive a notification when you open an email from HoldCo or click on a link therein.

If you would like to stop receiving marketing or promotional communications via email from HoldCo, you may opt-out of such communications by replying to the email, with ‘Unsubscribe’ in the subject line.

External Data Storage Sites

We may store your data on servers provided by third-party hosting vendors with whom we have contracted. While we strive to store all data in the geographic region that the consumer lives in, sometimes this is not possible, and data will be stored on HoldCo systems in the United States subject to appropriate safeguards.

Data Retention

We comply with local laws regarding data retention information provided to us by you.

Data Processing

The personal data which individuals allow to be processed is only used for the purposes stated in this Statement and is only shared with HoldCo affiliates.

Additionally, individuals may request the restriction of the processing of personal data in certain circumstances, namely where:

they contest the accuracy of the personal data which we have processed and we are verifying the query;
the data has been unlawfully processed;
we no longer need that personal data, but an individual requires us to keep it; or
the individual has objected to our processing their personal data, and we are considering whether our legitimate grounds override those of the individual.

If an individual requests that we suspend processing of their personal data, we would make that data temporarily unavailable and not process it apart from to store it.

The right of individuals to access their personal data

HoldCo ensures that individuals have the following rights in relation to their personal data:

the right to request a copy of some or all of their personal data;
the right to request rectification of any inaccurate personal data which we hold;
the right to request erasure of personal data;
the right to request restriction of processing of the personal data;
the right to object to the processing of the personal data; and
the right to transfer certain data to the individual or a third party.

In relation to access to personal data, individuals may make a request for access verbally or in writing. They will not be charged for receipt of a copy of their personal data (unless that the request is unfounded, repetitive or excessive) and they will be provided with such copy as soon as reasonably practicable and in any event within the statutory timeline of a month from receipt of the request, unless the request is particularly complex or you have made a number of requests.

Changes to this Statement

HoldCo reserves the right to change this Statement, from time to time, to integrate new technologies, regulatory requirements, aligning with evolving industry best practices, or other purposes. The “Last Updated” date at the beginning of this policy is updated when we update the policy; therefore, we encourage you to check this page periodically to understand how your data is treated by us. Your continued use of the available website after such modifications will constitute your: (a) acknowledgement of the modified Statement; and (b) agreement to abide and be bound by the modified Statement.

Contact Information

HoldCo welcomes your questions or comments regarding this Statement. If you believe that HoldCo has not adhered to this Statement, please contact us.

Regardless of where you reside, you can also reach us by emailing us at Info@OldGloryBank.com if you have any questions or concerns.

Privacy Notice for Residents of California

Effective Date: March 5, 2024

The following Privacy Notice (“CCPA Notice”) is provided by HoldCo, Inc. (“HoldCo”, “our”, “us”, or “we”) and applies to users of the HoldCo website (own.OldGloryBank.com who reside in California. The CCPA Notice is a supplement to the Privacy Statement found above. This notice has been issued by HoldCo to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.

Information that HoldCo Collects

HoldCo collects information about you that may identify, describe, relate to, references, or is capable of being linked or associated with a particular consumer or device. We call this information “Personal Information.” Personal Information that we may collect when you are using our website includes the following categories:

Category of Information	Description of Information	Collected by HoldCo
Identifiers	Information such as your name, postal address, unique personal identifier or social security number, driver license or passport number, or similar identifiers	Yes
Personal Information as defined by California Civil Code, Section 1798.80(e)	Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	No
Classification characteristics protected under California or federal law	Information about you such as your race, religion, ancestry, national origin, marital status, medical condition(s), sexual orientation, veteran or military status, or genetic information.	No
Commercial Information	Information about you such as your past personal property purchases and consumer histories or tendencies.	No
Biometric Information	Physiological, genetic, or biological characteristics about you such as fingerprints, faceprints, or voice prints; iris or retina scans, or other physical patterns.	No
Internet or activity occurring on or over networks	Information collected by cookies or other behavior tracking devices that collect your internet activity such as browsing and search histories, or information regarding your interaction with websites, applications, or advertisements.	Yes
Geolocation Information	Physical location, according to your Internet Protocol (IP) address.	Yes
Sensory Information	Information such as audio, electronic, visual, thermal, or olfactory.	No
Professional and Employment-related Information	Information about your current or past jobs, employment, or contracts, including the performance evaluations that may have occurred while employed or contracted.	No
Non-public Education Information	Information about your education such as records related to you as a student, grades, transcripts, student schedules, student identification codes, student financial information, or disciplinary records.	No
Inferences Drawn From Other Personal Information	Information about you that can be used to create a profile, such as preferences, characteristics, predispositions, behavior, attitudes, abilities, and aptitudes.	No

“Personal information” does not include:

Publicly available information that is lawfully made available to the general public from federal, state, or local government records.
De-identified, anonymized, or aggregated consumer information
Information that is expressly excluded from the scope of the CCPA but is covered by the Health Insurance Portability and Accountability Act (HIPAA) or other applicable legislation.

How HoldCo Uses Personal Information

Except as described herein, HoldCo does not disclose information that we collect about you through the website without your consent. We may, however, use and disclose Personal Information detailed above for business purposes such as:

To fulfill the service you requested by giving us the information
To provide you with products, services, or information that you have requested from HoldCo or HoldCo’s affiliate, Old Glory Bank ^®.
To provide email alerts, information on events or contests, or other notices about HoldCo, the website or services, or news when you have indicated that it may be of interest to you
To fulfill our obligations and enforce HoldCo’ rights arising from contracts entered into between you and us
To improve your consumer experience and our website

Disclosure of Personal Information

HoldCo will not disclose Personal Information to any third parties except our affiliate Old Glory Bank ^®. In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for business reasons:

None

In the last twelve (12) months, we have not sold any Personal Information.

Sources of Personal Information

HoldCo collects Personal Information about you from these categories of sources:

From you, directly
From you, indirectly when you use the HoldCo website. This information includes things like your IP address, the region or geographic area where your device is connected to the internet, the browser type, operating system, and other usage information about your use of the Services.

Your Rights Under the CCPA

California residents have specific rights regarding their Personal Information as granted by the CCPA, including the right to request information about how your Personal Information is used, collected, or disclosed.

Upon receipt of a verified request from you about the collection and use of your Personal Information, we will disclose to you:

Categories of Personal Information collected over the past twelve (12) months
Categories of sources where we have collected Personal Information about you over the past twelve (12) moths
Business reason for collecting or selling Personal Information over the past twelve (12) months
Categories of third parties that we have shared Personal Information with over the past twelve (12) months
Specific pieces of your Personal Information collected over the past twelve (12) months
Whether we have sold or disclosed your Personal Information for a business reason

Deletion Right

Subject to the limitations below, you have the right to request that we delete Personal Information about you that HoldCo has collected and retained. When you submit a request for Personal Information deletion, we will verify that it is a legitimate request and delete your Personal Information from our systems, unless:

We need the Personal Information to complete a transaction you directed us to conduct, provide a product or service requested by you, or otherwise to perform our obligations as defined by a contract or agreement with you
We need the Personal Information to detect security incidents; protect against malicious, fraudulent, or illegal activity; or prosecute those responsible for such activities
We need the Personal Information to identify and repair errors that impair existing functionality or to debug
We need the Personal Information to comply with a legal obligation

Opt-out of the Sale of Your Personal Information

While residents of California do have the right to opt-out of their Personal Information being sold, HoldCo does not sell your Personal Information. Therefore, there is no need for you to submit a request to opt-out.

Shine the Light

California Civil Code Section 1798.83 permits our consumers who are residents of California to request and obtain from us information about the Personal Information we disclosed to third parties for direct marketing purposes in the preceding calendar year, at no charge. If you are a resident of California and would like to make such a request, please submit your request to Compliance@OldGloryBank.com.

Verifiable Consumer Requests

Only you or someone legally authorized by you can submit a verifiable consumer request. You must provide HoldCo with sufficient information so that we can verify your identity and provide enough detail in the request to permit us to properly evaluate and respond. If we cannot verify your identity, we will not be able to respond to your request. You do not need an account with HoldCo in order to submit a request.

To exercise your rights described in the CCPA Notice, submit a verifiable consumer request by emailing us at Compliance@HoldCo.com.

It is HoldCo’s intention to respond to verifiable consumer requests within 45 days of receipt. In some cases, it may take longer but we will notify you within 45 days if it will take longer. We will respond through email. If we are not able to respond to a request, we will notify you in writing and explain why we are unable to respond.

If you choose to exercise your rights under the CCPA, we promise not to discriminate against you for that exercise.

Changes and Updates to the CCPA Notice

HoldCo reserves the right to change this CCPA Notice from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your account or by placing a prominent notice on the website. Your continued use of the website after such modifications will constitute your: (a) acknowledgement of the modified CCPA Notice; and (b) agreement to abide and be bound by that CCPA Notice.

HoldCo welcomes your questions or comments regarding this CCPA Notice. If you believe that HoldCo has not adhered to this CCPA Notice, please contact us.

Regardless of where you reside, you can reach us if you have any questions or concerns by emailing us at Info@OldGloryBank.com or by mail to P.O. Box 20550 Oklahoma City, Oklahoma 73116.