Wilmington Trust

Digital Privacy Notice

Protecting your privacy and your information is important to us.

This Digital Privacy Notice ("Notice") applies to users of the Wilmington Trust website and mobile application ("Online Services"). The term "Wilmington Trust", "we", "us" or "our" on any website we own or control and, in this Notice, refers to Wilmington Trust and our affiliates or subsidiaries that link to this Notice. This Notice describes how Wilmington Trust Online Services may collect, use and share information from or about you.

Last Updated: March 31, 2023.

Agreement to Privacy Notice

By viewing Wilmington Trust’s website and Online Services, you consent to this Notice which includes your consent to disclose and use information about you in the manner detailed in this Notice. Depending upon your relationship with us, other Wilmington Trust Privacy Notices may also apply and provide additional detail about our privacy practices.

Types of Information We Collect

We collect two kinds of information through Online Services: non-personal information and personal information.

The non-personal information we collect includes: the visitor's browser type, device type and operating system, area(s) of Online Services site visited, date and time of access, host or Internet Service Provider (ISP) information, and identity of the referring site (any site from which the visitor accessed Online Services).

Personal Information means personally identifiable information such as information you provide via forms, surveys, applications or other fields including name, postal or email addresses, social security number (SSN), telephone, fax or mobile numbers, or account numbers.

We collect personal information that can identify a visitor, user or customer, including but not limited to name, address or other contact information, or other information that you choose to provide to us, but only when you voluntarily provide it. If you apply for a job, we may collect personal information about your work and educational history.

We collect information about how you use and interact with our website and mobile applications. Examples of this include activities on pages visited, links clicked, or unique and measurable patterns such as keystrokes, mouse clicks and movements, swipes and gestures.

We may offer you the ability to register and access your accounts via Online Services. When you access your accounts via Online Services, we may also collect and analyze the following (in addition to the other types of information discussed in this Notice):

Device and Carrier Information

We may collect information about your device such as your phone number, the device model, identity of the carrier and the name and version of the operating system.

Location Tracking

There may be certain information transmitted to us regarding your location when you log in or request information through Online Services. We collect the Internet Protocol (IP) address of the device to determine your physical location for Online Services. This information may be provided to mapping applications to assist you in locating nearby branches and ATMs and for security purposes. Your location data will be retained by Wilmington Trust for as long as needed to fulfill business purposes but will only be used for the limited purposes stated within this Notice.

Transaction Information

We may collect information when you initiate a transaction. This information will only be used or shared in order to provide the service that you requested.

This information is collected and analyzed to assist us with fraud detection and for other security purposes, and to enhance our ability to optimize your experience while on our site. It will only be used for the purpose(s) stated within this Notice and retained by Wilmington Trust for only as long as needed to fulfill the business purpose(s).

How We Collect, Use and Protect Social Security Numbers

Wilmington Trust may collect SSNs in the course of our business. We strive to protect the confidentiality and security of SSNs in our possession, custody or control by: (i) limiting access to SSNs and (ii) maintaining reasonable administrative, technical and physical safeguards to protect against the loss, misuse or unlawful disclosure of SSNs.

How We Use Your Information

We may use the information we collect through Online Services for several purposes including:

to provide you with, renew, or modify products and services;
to provide you with the information and documents you request and for other customer service purposes;
to provide you with information about Online Services or required notices; to allow you to participate in digital surveys and other forms of market research;
to deliver affiliate marketing communications or promotional materials that may be of interest to you, and to assist us in determining relevant advertising;
to improve the services we provide and the usefulness of Online Services;
to customize your experience when using Online Services;
to comply with applicable laws;
to perform research;
and to prevent and detect fraud, infringement and other potential misuse.

We also may anonymize, combine or aggregate any of the information we collect through the Online Services or elsewhere for any of these purposes or for analyzing usage statistics and trends.

If you provide us with personal information in connection with products or services that we provide to you primarily for personal, family or household use, we will not sell, license, transmit or disclose this information outside of Wilmington Trust unless: (1) you expressly authorize us to do so, (2) it is needed to allow our service providers to provide services for us, (3) it is needed to provide our products or services to you, (4) it is disclosed to entities that perform marketing services on our behalf or to other entities with whom we have joint marketing agreements, (5) it is connection with a merger, consolidation, acquisition, divestiture or other corporate restructuring of all or part of our business, or (6) it is otherwise required or permitted by law.

How We Use Cookies and Other Data Collection Tools

Cookies, Web Beacons and Pixel Tags. To better serve you and to provide more effective Online Services, we use "cookies" as part of our interaction with the device you are using. Cookies are small text files that a website's server places on your computer or other device. In addition to cookies, we may use other devices for tracking online activity, including web beacons and pixel tags. Web beacons and pixel tags are small strings of software code that represent a graphic image on a website, or in email that is used to monitor the user's behavior.

These data collection tools provide a means for sites that you visit to track browsing activities conducted with the device you are using, your language preference, and your relationship with the site owner. This includes information such as pages and content viewed, time and duration of visits, search queries entered into search engines, and whether a computer user clicked on an advertisement. Cookies make the personalization of your Online Services experience possible and can also be used to retain data related to a particular browser, such as items in online shopping carts. We use these data collection tools to determine whether you have previously visited our website, the location from which you are visiting our website, and for several administrative purposes (for example, to store your preferences for certain kinds of information), website traffic reporting, unique visitor counts, advertising/auditing/reporting, and for personalization of a website. The data collection tools may be used in connection with some Online Services and email messages to measure the effectiveness of our communications and/or the success of our marketing campaigns, to compile statistics about usage and response rates, to personalize/tailor your experience while engaging with us online and offline, for fraud detection and prevention, for security purposes, for advertising, and to assist us in resolving account holders' questions regarding use of our Online Services.

We and our service providers may also use cookies, or similar technologies, to collect information about your browsing activities over time and across different websites following your use of our Online Services. We may use other technologies, such as the capture of screenshots while you are using the Services, to understand how you navigate and use the Services. This information helps us to better understand how the Services are used and to improve them. We may associate this tracking data with any personal information you provide, in which case we will treat it as personal information.

For more information about cookies, please see our Cookie Notice.

We may use information collected through your use of our Online Services, combined with information that we obtain from third parties, to determine who you are or your email address. This information helps us in our efforts to continually improve our Online Services and to deliver an experience personalized to your specific needs.

You can refuse to accept these cookies, and most devices and browsers offer their own privacy settings for cookies. You may manage your cookie settings for each device and browser you use. However, if you do not accept these cookies, you may experience some inconvenience in your use of our Online Services and some online products and services. For example, we will not be able to recognize your device and you may need to answer a challenge question each time you log on. You also may not receive tailored advertising or other offers from us that may be relevant to your interests and needs. Web beacons and pixel tags are dependent on cookies, so when web beacons and pixel tags are blocked on your browser, the cookies will not be created by consequence.

You should visit the "Help" section of your browser for how to manage your cookie settings, or follow the links below:

For further general information on cookies and more detailed advice on how to disable and enable them, please visit www.allaboutcookies.org.

Do Not Track

While, as described above, you may have the ability to control the use of cookies through your web browser, unless the browser settings block our data collection, we do not currently respond to "Do Not Track" signals or other mechanisms. The available settings vary greatly by browser; please refer to your Internet browser settings for more information. For more information about Do Not Track, please visit www.allaboutdnt.com

Children's Privacy

We recognize that protecting children's identities and privacy online is important and that the responsibility to do so resides with both the business and the parents. We do not knowingly solicit data from children under the age of 13, and we do not knowingly market through our website to such children. We comply with the requirements of the Children's Online Privacy Protect Act (COPPA) that are applicable to us.

Working with Other Companies

From time to time, Wilmington Trust may establish a relationship with other companies and vendors to collect and analyze data and provide you with additional value and new products we may not offer ourselves. When permitted or required by law, we may share information with third parties for purposes including response to legal processes. In these circumstances, we will treat information you provide us in the same manner described in this Notice.

Wilmington Trust offers access to other websites either using hyperlinks or through "co-branded" sites in which both Wilmington Trust and the other company share the same URL, domain name or pages within a domain name on the Internet. In some cases, the other site will also collect information from you. This information may include, but is not limited to, name, address, SSN, account numbers and date of birth. Prior to providing any information to any third party, review their privacy notices to determine the extent to which they may disclose your information.

Making Sure Your Information is Accurate

It is important for us to have your most accurate and up-to-date contact information. If any of your contact information has changed, please call or write us at the proper telephone number or address located within the Help page. You may also call or write us at the telephone number or mailing address located on your account statements or other records as indicated.

Security of Online Communications

We protect information you provide us online in several ways. Wilmington Trust Online Services leverages multiple layers of security, including password protection and the SSL (Secure Sockets Layer) communication protocol, which employs 256-bit encryption to ensure information is passed to Wilmington Trust without being intercepted by third parties. As always, we strongly encourage you to assist us in that effort by not sharing your Wilmington Trust User ID or Passcode with anyone. For more information about Online Services security, please visit the Wilmington Trust Privacy/Security page.

Aggregation Websites

Please use caution when using aggregation websites. Aggregation websites offer the ability to access all your financial account information on one website. To do this, an aggregation provider may request access to your User IDs and Passcodes. You should use caution and ensure that the aggregator company has appropriate policies and practices to protect the privacy and security of any information you provide or to which they are gaining access. We are not responsible for the use or disclosure of any Personal Information accessed by any other company or person to whom you provide your User ID and Passcode.

All transactions initiated by an aggregation website, using access information you provide are considered to be authorized by you, whether or not you were aware of the specific transaction. If you decide to revoke the authority you have given to an aggregation website, we strongly recommend that you change your User ID and Passcode to ensure that the aggregation website cannot continue to access your account.

Changes to this Digital Privacy Notice

This Notice should be reviewed periodically as it is subject to change from time to time. When a change has been made, we will post the revised Notice on this page with a new "Last Updated" date at the top of the page. All changes will become effective when posted unless indicated otherwise.

Your continued use of any of our Services following the posting of a revised version of this Digital Privacy Notice will constitute your acceptance of the revised Notice. If you do not agree with the revised Digital Privacy Notice, do not use any of our Online Services.

Additional Notice to California Residents (Effective on January 1, 2020)

The California Consumer Privacy Act ("CCPA") is a law which applies to residents of the State of California, who are not currently covered under the Gramm Leach Bliley Act ("GLBA").

California defines residency as: (1) every individual who is in the State for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the State who is outside the State for a temporary or transitory purpose. All other individuals are nonresidents. Examples of domicile include paying taxable income, maintaining a permanent home, paying resident tuition, voting in a California election, or any other benefit not ordinarily extended to nonresidents.

Note that as part of servicing consumer requests and customer accounts, M&T Bank and Wilmington Trust ("Wilmington Trust") may collect certain categories of information as noted in the "California Privacy Notice"; however, not all categories of information are likely to be collected from or about each individual consumer. The specific categories of information collected are dependent on the Wilmington Trust service(s) provided.

For further information on the categories of information Wilmington Trust collects, please visit the Wilmington Trust California Privacy Notice page.

Due to other Federal and State laws, Wilmington Trust may not be able to fulfill a request to access or delete personal information because such information is needed to provide your product or service and/or meet legal requirements.