Online and Mobile Privacy Policy

Effective Date: September 1, 2015

For users and visitors in the United States

SUMMARY

Scope

Collection of Personal Information and Consent

Purposes for Use and Disclosure

Use of Tracking Tools

Internet-Based Advertising and “Do Not Track” Signals

Your Choices

Safeguards and Third Party Links

Scope

BMO Harris is committed to respecting and protecting the privacy of our online and mobile visitors. This Online and Mobile Privacy Policy (this “Policy”) explains what information BMO Harris Bank N.A. (the “Bank") and our U.S. banking and non-banking affiliates and subsidiaries, specifically BMO Asset Management Corp., BMO Harris Financial Advisors, CTC myCFO, LLC, and Taplin, Canida & Habacht, LLC, that link to this Policy (together with the Bank referred to collectively “BMO Harris” or “we” or “us”) may collect about you via our websites and mobile services (collectively, “Online Services”) and how we use and protect that information. It should be read in conjunction with the Website Terms of Use.

The Bank uses and shares its customers’ personal information in accordance with the terms of its Privacy Notice. In addition, each of the entities identified above uses and shares its consumer customers’ personal information in accordance with the terms of its Privacy Notice, which is available on each entity’s website.

Your Consent

Each time you use our Online Services, you are indicating your acknowledgement and consent to the collection, use and disclosure of information about you collected through our Online Services as set forth in this Policy. We may revise this Policy periodically without advance notice. We will let you know of any changes by posting a revised Policy on our website with a new effective date. If you do not accept the terms outlined in this Policy or revised Policy, please do not use our Online Services.

Collection of Personal Information

We may collect personal information when you use our Online Services, including when you apply to open an account online, log in to our online or mobile banking services or schedule an appointment. For example, we may collect your name, email address, user ID, password, Social Security Number, and employment and income information.

We may also collect other data about you through your online or mobile activities or through third parties on our behalf. This data may or may not be personally identifiable to you. Data that we may collect includes:

We do not knowingly solicit from, and the Online Services are not intended for, children under 13, and children under 13 should not provide personal information online. If a parent or guardian becomes aware that his or her child under the age of 13 has provided us with information without their consent, he or she should contact us. We will delete such information from our files.

Purposes for the Use and Disclosure of Personal Information

We may use and disclose your personal information that is collected through our Online Services in accordance with applicable law and the applicable consumer customer privacy notice, which uses may include:

Use of Tracking Tools

We or our service providers may use various tracking tools, such as Cookies, Pixel Tags and Web Beacons, on our websites and advertisements.

Interest-Based Advertising

We or our service providers use data collected about you over time across multiple websites or other platforms to present interest-based ads to you. This data may be collected on our websites and platforms, or the websites and platforms of others. This may include information collected on apps. We and our service providers also use this data to help manage and optimize our Online Services and communications to you. Our ads may be for products or services we think are relevant based on your browsing habits or online activities. These ads may be about our products and services, or other companies’ products and services.

We use certain tracking tools (as described above) to collect information about you to serve these ads. These tools track if you have clicked on a BMO Harris ad on a website and identify your activity when you clicked on that ad using cookies and web beacons.

BMO Harris uses third-party advertising networks to distribute our advertisements on other websites and mobile applications where we have paid to advertise. Our ads may also be served in emails. These advertisements may use tracking technologies to capture certain data, such as your IP address, usage information, or your responsiveness to our advertisements. To stop certain online advertising by BMO Harris, please see the “Do Not Track Signals” section below.

Third parties may collect certain information on BMO Harris websites or other sites where BMO Harris advertises. These third parties might link your name or email address to other information they collect from certain third party websites you may visit.

"Do Not Track" Signals and Opting Out of Online Behavioral Advertising

There is no industry standard for how Do Not Track consumer browser settings should operate on commercial websites. As a result, BMO Harris does not respond to “do not track” signals from your browser at this time. If you block or reject cookies, not all of the tracking described here will stop. Options you select are browser and device specific.

However, BMO Harris participates in third party ad network self-regulatory programs for online behavioral advertising, including the Digital Advertising Alliance (DAA) Self-Regulatory Program for Online Behavioral Advertising . The DAA’s Principles are intended to provide consumers with transparency about the collection and use of data for online behavioral advertising and to promote the consumer’s choice in managing its scope. BMO Harris adheres to the DAA’s Principles.

Pursuant to the DAA’s Principles, BMO Harris honors Do Not Track opt-out preferences that you make to participating third party advertising networks that we hire to perform advertising on our behalf. To limit or stop the collection of your online behavior for advertising purposes, you can visit http://www.aboutads.info/choices/ . You can also learn more at http://www.youradchoices.com . You can also click on DoubleClick, http://info.evidon.com/more_info/4311?cps%5b4311%5d=1 , to opt out of that ad program. These opt-outs work by placing a cookie on your browser. If you delete cookies, use a different computer, or change browsers, you will need to opt out again.

Certain BMO Harris ads on third-party websites may display an Advertising Options Icon that you can click on to learn about your choices. This icon will only appear on certain platforms. You should always review the privacy policy on any third party site you visit. You can also help limit the amount of online and mobile advertising that you receive by opting-out of advertising from Network Advertising Initiative member companies at http://www.networkadvertising.org/choices .

For mobile users, you can also download the AppChoices mobile app on your supported Apple or Android mobile device. You can also visit http://www.aboutads.info/appchoices for more information on how to limit advertising while using apps on your mobile device. Additionally, you may be able to limit ad tracking on apps by adjusting the settings on your mobile device.

You may still receive online advertisements from us even if you opt out in any of the ways identified above but they will not be customized based on your choices or behavior. Choices you make are browser and device specific.

Your Choices

Email Communications: If you prefer not to receive email communications from us, you can unsubscribe by clicking the “Unsubscribe” button provided in the promotional emails you receive from us. Please allow up to 10 business days for us to process your request. However, if you unsubscribe, we may still send you transactional email (for example, a notice about an upcoming change affecting your account) about your accounts and services.

Voluntary Participation: From time to time, you may choose to enter your information in order to participate in online surveys, contests, sweepstakes or other activities that we sponsor. We use this information for a variety of reasons, such as measuring the performance of the website, or identifying products and services that might interest you. All information is used in accordance with the purposes outlined in this Policy and
the official rules of the contest or sweepstakes, if applicable. Do not participate in these voluntary activities if you do not want your information used for these purposes.

Safeguards

We use security controls to protect against unauthorized use, access, modification, destruction, disclosure, loss or theft of your personal information in our custody or control.

To learn more about the Bank’s online and mobile security practices, visit www.bmoharris.com/security. To learn more about the other Bank-affiliated entities’ security practices, visit each entity’s website.

Third Party Links

Our websites may contain links to other sites that we do not own or operate. Also, links to our websites may be featured on third party websites on which we advertise. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of, or referral to, the linked websites. The linked websites have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.

Contact Us

For more information, please contact us at:

BMO Harris Bank N.A.
Office of the Chief Privacy Officer
111 West Monroe
Chicago, Illinois 60603
Privacy.Office@bmo.com