At ICICI Bank Limited, New York Branch (ICICI - NY) we take your privacy very seriously and take precautions to maintain it. We do not sell customer lists or individual customer information. We collect, retain and use your information only where we believe it will be reasonably useful or necessary in performing the functions of a financial institution, such as providing products and services to you. The following privacy policy applies to ICICI - NY.

Security Standards

Policies and procedures have been instituted to protect your personal financial information and to maintain the privacy of personal information relating to your relationship with ICICI - NY. These include controls that limit access to consumer information, procedures to ensure the maintenance of accurate information and privacy covenants in third-party service and business agreements. ICICI - NY maintains up-to-date physical, electronic and procedural safeguards that comply with federal standards to guard against unauthorized access to your non-public, personal information.

Collecting Information and Information We Share

To aid us in keeping accurate information about your accounts and to provide you with the high standard of customer service you expect from us, we collect non-public information about you from the following sources:

• Information we receive from you on applications and other forms, such as your name, address, social security number, assets and income
• Information about your transactions and experiences with us and our affiliates, such as account balances and loan payment history
• Information we receive from a consumer reporting agency, such as credit worthiness and credit history
• Information we receive from public sources, such as real estate records and telephone numbers.

Access to Information by our Employees

Access to your personal financial information is limited to those employees who have a legitimate business need to know the information as part of their job responsibilities. We train our employees on privacy and information security, and on their responsibility to protect information.

Information We Share with Other Companies

At times, to improve the efficiency of the products and services we offer you, ICICI - NY may outsource some of its work to specialists. To accomplish this, it may be necessary to disclose some or all of the information we collect about you

In other cases, ICICI - NY may join with other financial institutions to provide you with joint products or services. Although it may be necessary for ICICI - NY to share with these other financial institutions certain information it collects about you, we will never share your account(s) or access code(s) for these purposes.

The information we provide to outside companies in either of these two circumstances will be limited to that which is necessary for them to do their job. These companies are required to keep your information secure and use it only as authorized by ICICI - NY.

Information Shared Between ICICI-NY and its Affiliates

ICICI - NY is made up of a number of companies or affiliates. We may share information about you with our affiliates as permitted by law. This helps us to offer you financial products and services such as loans, deposits and investments. We may share the following types of information with our affiliates: information based on your transactions with us (for example, information that we could collect about your loan amounts and deposits with us in order to offer you a rate on the basis of total balances) and contact information (such as your name and address); credit information received from you or others (such as information from your credit application or your employment or credit history) to evaluate your eligibility for various financial services. You may tell us not to share credit information with our affiliates or otherwise limit the information we share with affiliates by contacting us at 1 8 66 ICICI 4U (1 866 424 2448) or by sending us a written request, addressed to Customer Service; ICICI Bank Limited, New York Branch, 500 Fifth Avenue, 28th Floor, New York, NY 10110. In the event you tell us not to share credit information with our affiliates, we may still share transaction and experience information such as account balance and payment history. For purposes of this section, the term affiliate includes ICICI Securities, Inc. and such other affiliates as we may designate from time to time

Sharing Information in Other Circumstances

As permitted or required by law, ICICI - NY may share the information it collects about you for purposes such as:

• To process transactions you have requested and authorized
• To protect against fraud and/or identity theft
• To respond to subpoenas
• To regulatory authorities and/or law enforcement officials
• To credit bureaus or others asking for credit references in accordance with ordinary and customary business practices
• In connection with a proposed or actual sale, merger or transfer of a part of our business.

Except as noted above, ICICI - NY does not share non-public information about customers or former customers with non-affiliated third parties.

Your Opt-Out Rights

Under the law, you are permitted to opt-out of: (1) our sharing of non-transactional information about you with our affiliates under the federal Fair Credit Reporting Act; and (2) our sharing information about you with non-affiliated companies and persons other than those to whom we have outsourced specialized services and those with whom we have joint marketing agreements. However, since we do not currently share such information, no opt-out action is necessary or provided. Should our policy change, you will be notified and given an opportunity to opt out.

We protect your information

At ICICI - NY, we take your security and privacy very seriously and take adequate measures to ensure that your information is protected. We use the latest technology and ensure your online security through sophisticated encryption and business procedures.

ICICI - NY is a federally chartered bank and as such we are required by law to have appropriate measures to safeguard customer information. We have stringent standards that enable us to abide by the legal requirements and protect customer data, including compliance with ''Fair and Accurate Credit Transaction (FACT) Act.''

Our Website

The use of cookies, web bugs, images, and other techniques to gather covertly information about individuals who use the Internet is incompatible with this policy. When you visit our website at www.icicibankusa.com, ICICI - NY wants you to be sure that we are respecting your privacy. The only private information we have about you is the information you choose to give us (such as providing feedback or completing a form). We do not release that information to others without notifying you and getting your consent.

Children’s Information

ICICI - NY makes every effort to comply with the Children's Online Privacy Protection Act. We will not knowingly collect or retain personally identifiable information from customers under the age of 13.

E-mail

Customers should take note of the disclaimer carried within the e-mails sent by the ICICI - NY, namely:

"This e-mail message may contain confidential, proprietary or legally privileged information. It should not be used by anyone who is not the original intended recipient. If you have erroneously received this message, please delete it immediately and notify the sender. The recipient acknowledges that ICICI Bank or its subsidiaries and associated companies, (collectively "ICICI Group"), are unable to exercise control or ensure or guarantee the integrity of/over the contents of the information contained in e-mail transmissions and further acknowledges that any views expressed in this message are those of the individual sender and no binding nature of the message shall be implied or assumed unless the sender does so expressly with due authority of the ICICI Group. Before opening any attachments please check them for viruses and defects."

Customers should also note that, e-mails sent to us that are general in nature, as well as our responses, are not secure.

Changes to this Policy

ICICI - NY may update this policy with respect to any change in the regulatory requirements or on an annual basis. We will notify you of any changes. As a part of this notification, ICICI - NY shall provide individuals with a summary of the words that have changed and what these changes mean.

How to Contact Us

If you would like additional information or have any questions regarding ICICI Bank Limited, New York Branch's Privacy Policy, please telephone us at 1 866 ICICI 4U (1 866 424 2448). You may also write us at ICICI Bank Limited - New York Branch, 500 Fifth Avenue, 28th Floor, New York, NY - 10110, or stop by our branch and discuss your questions with our staff.

Former Customers

This privacy policy applies to current and former customers.

Special Notices to Residents of Certain States

Customers resident in certain states, including California and Vermont, may receive additional information with respect to the requirements imposed by those states.

Privacy Statement for California Residents

This privacy statement (herein, the “California Privacy Statement” or “Privacy Statement”) supplements the information contained in the Privacy Policy of ICICI-NY (referred to herein as “ICICI-NY” or “we,” “us” or “our”) set forth above and applies to ICICI-NY’s collection and use of California residents’ personal information governed by California law, including the California Consumer Privacy Act (CCPA).  It applies only to California residents (referred to herein as “consumers” or “you” or “your”).  

The CCPA grants California residents specific rights regarding  personal information and imposes various data protection duties on ICICI-NY in connection with its provision of remittance services under the Money2India (“M2I”) program or any other services that ICICI-NY might provide to California residents.  Any terms defined in the CCPA have the same meaning when used in this California Privacy Statement.  In the event of any conflict between the terms of this California Privacy Statement and the Privacy Policy set forth above, the terms of this California Privacy Statement shall apply in the case of California residents.  This Privacy Statement does not cover information that is exempted from the privacy policy notification requirements of the CCPA, including information that is covered by the Gramm-Leach-Bliley Act;  information about employee, independent contractors, and job applicants, which we cover in separate notices; and information processed exclusively in the context of a business person acting in a business capacity. 

Personal information that is protected under the CCPA means information that identifies, relates to, describes, is reasonably capable of being associated with, or may reasonably be linked, directly or indirectly, with a particular consumer. It may include (among other items): (i)  Identifiers, such as a real name, an alias, postal address, email address, unique personal or online identifier, internet protocol address, account name, Social Security number, driver’s license or passport number, or other similar identifiers; (ii)  Personal information categories described in the California Customer Records Statute (Cal. Civ. Code Section 1798.80(e)), including information such as a person’s name, signature, Social Security number, physical characteristics or description,  address, telephone number, passport number, state identification card number, insurance policy number, education, employment or employment history, bank account number, credit card number, debit card number or any other financial information, medical information or health insurance information (some of these categories may overlap with (i) above); (iii)  Protected classification characteristics under California or federal law, such as age (40 years or older), race, religion, gender, national origin, sexual orientation, citizenship, marital status or medical condition; (iv)  Certain commercial information, including records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies; (v)  Biometric information, such as genetic, physiological, behavioral and biological characteristics or identifying information such as fingerprints and voiceprints; (vi)  Internet or other electronic network activity information, including:  browsing history, search history, or information regarding a consumer’s interaction with an internet website, application or advertisement; (vii)  Geolocation data, such as physical location or movements; (viii)  Sensory data such as audio, electronic, visual or similar information; (ix)  Professional or employment-related information, such as current or past job history or performance evaluations; (x)  Non-public education information, defined as non‑public personally identifiable information under the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232(g)); or (xi)  Inferences drawn from any of these personal information categories to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological tendencies, predispositions, behavior, attitudes, intelligence, abilities or aptitudes. 

Personal information does not include certain publicly available information such as information lawfully made available from federal, state or government records.  The CCPA also excludes certain personal information covered by other sector specific legislation from its coverage scope. For example, medical information or protected health information governed by California and federal health information privacy laws is not covered by the CCPA.

The CCPA requires that we inform you about the categories of personal information that we collect and the intended use of each category of such information.  ICICI-NY currently collects and shares information only as described above in our Privacy Policy and as indicated in the chart below.  We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated or incompatible purposes without providing notice to you.

We have collected the following categories of personal information from California residents within the last twelve (12) months:

ICICI-NY does not sell your personal information to third parties.  In the event that we wish to do so in the future, we are required to provide you with an opt-out right so that you may prevent the sale of your personal information to third parties. 

You have the right to request disclosure of your personal information that we collect and to receive additional details about how ICICI-NY collects and uses this information, including the categories of third parties, if any, with which ICICI-NY has shared this information in the 12 months prior to receipt of your request.  If you request that we disclose to you specific pieces of your personal information we have collected about you in the 12 months prior to your request, we must provide such information in a readily useable format so that you will be able to transmit this information without hindrance.  You also have the right to request that we delete certain personal information that we have collected about you, subject to certain exceptions.  If we receive such a request from you, we must also instruct our service providers with whom we have shared this information to delete it.

We may deny your request to delete information if retaining such information is necessary for us or our service providers to complete the transaction for which we collected the personal information or provide the service that you have requested or to comply with a legal obligation or for certain others purposes specified in the CCPA. 

If you wish to request information on the information that we collect about you and how we use it or if you wish to request that we delete such information, you can place a request by writing to us at nri@icicibank.com from your registered e-mail ID.You may also submit requests using our toll-free number (1-866-424-2448).  

We may not discriminate against you if you exercise your rights under the CCPA.

 
If you wish to designate an authorized agent to make a request on your behalf, you must provide us with a notarized power of attorney authorizing such agent to act on your behalf.

If we receive a request from a California consumer, we must (i) acknowledge receipt within 10 days and explain how we will process your request and respond within 45 days after we receive your request, unless such time period is extended in accordance with the provisions of the CCPA; (ii) inform you of any reasons for not taking action; and (iii) provide any information that you request free of charge, unless your request is manifestly unfounded or excessive.  You may only make most information requests twice a year and only with respect to a 12-month look back period.  However, there are no limits on the number or timing of your deletion or do not sell requests.

There may be some types of personal information that can be associated with a household (a group of people living together in a single dwelling).  Requests for access or deletion of household personal information must be made by each member of the household.  We will verify each member of the household using the verification criteria explained above.

If we are unable to verify the identity of each household member with the degree of certainty required, we will not be able to respond to the request.  We will notify you to explain the basis of our denial.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits California residents to annually request, free of charge, information about the personal information (if any) disclosed to third parties for direct marketing purposes in the preceding calendar year.  We do not share personal information with third parties for their own marketing purposes.

“Do Not Track” is a privacy preference that users can set in certain web browsers.  We do not respond to browser or do not track signals.

Personal Information of Minors

Our products and services are not directed to minors under the age of 18 and we do not knowingly collect or sell the personal information of minors.

We implement and maintain reasonable security appropriate to the nature of the personal information that we collect, use, retain, transfer or otherwise process.  Our reasonable security program is implemented and maintained in accordance with applicable law and relevant standards as outlined in the report issued by the California Attorney General in February 2016, available at https://oag.ca.gov/sites/all/files/agweb/pdfs/dbr/2016-data-breach-report.pdf.  Specifically, among other safeguards, our reasonable security program implements and maintains all 20 of the Center for Internet Security’s Critical Security Controls for Effective Cyber Defense identified in Appendix A of the California Attorney General Report. As noted in that report, “there is no perfect security,” and reasonable security is a process that involves risk management rather than risk elimination.  While we are committed to developing, implementing, maintaining, monitoring and updating a reasonable information security program, no such program can be perfect; in other words, all risk cannot reasonably be eliminated. Data security incidents and breaches can occur due to vulnerabilities, criminal exploits or other factors that cannot reasonably be prevented.  Accordingly, while our reasonable security program is designed to manage data security risks and thus help prevent data security incidents and breaches, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security.

We reserve the right to amend this California Privacy Statement at our discretion and at any time.  We will post any changes on the website and update the date of the update.  In certain cases, and if the changes are material, we will notify you by email or through a notice on our website.

Accessibility

We are committed to ensuring that our communications are accessible to people with disabilities.  To make accessibility-related requests or report barriers, please contact us at [+1-866-424-2448] or contact nri@icicibank.com.  

If you have any questions or comments about this Statement, or the ways in which we collect and use your personal information, your choices and rights regarding such use or if you wish to exercise your rights under California law, please do not hesitate to contact us by telephone at 1-866-424-2448 (toll free), by sending us a written request, addressed to Customer Service, ICICI Bank Limited, New York Branch, 575 Fifth Avenue Suite 2600, New York, NY 10017; or by sending an email to nri@icicibank.com.
This California Privacy Statement was most recently updated as of January 1, 2020.