Digital Banking Privacy Policy

Last Updated: June 26, 2026

Your privacy is important to us. This Digital Banking Privacy Policy (this “Policy”) explains how we collect, share, use, and protect information when you visit or use this online service and any other online services offered by Cogent Bank (collectively, our “Services”). This Digital Banking Privacy Policy applies to our digital services, including our websites, mobile banking services, mobile applications, Cogent Bank-branded social media pages, and interactions you may have with content provided through Cogent Bank’s digital advertising campaigns.

This Digital Banking Privacy Policy applies specifically to information collected through our digital channels and Services. Information regarding our collection, use, sharing, and protection of nonpublic personal information related to your banking relationship with Cogent Bank is described in our Cogent Bank Privacy Notice, which is available on our website and through our banking locations.

We use your personal data to provide, maintain, secure, and improve the Services. By using the Services, you acknowledge the collection and use of information as described in this Policy.

INTERPRETATION AND DEFINITIONS

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Policy:

• Account means a unique account created for you to access our Service or parts of our Service.
• Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Application means the software program provided by the Company downloaded by you on any electronic device, named Cogent Bank
• Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Cogent Bank, 420 S Orange Ave, Suite 150., Orlando, Florida, 32801
• Country refers to: Florida, United States
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual.
• Service refers to the Application and/or Website.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

COLLECTING AND USING YOUR PERSONAL DATA

Types of Data Collected

Personal Data

While using the Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of the Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit the Service or when you access the Service by or through a mobile device.  We may use cookies, pixels, SDKs, and similar technologies to collect Usage Data and support the functionality, security, performance, and analytics of the Service.

Information Collected while Using the Application

Some information is collected automatically and does not require any action on your part. This information may include unique device identifiers including but not limited to Internet Protocol (IP) addresses; browser type and version, the date, time, and length of your visit; pages visited; and activity.

We use this information to operate, maintain, secure, and improve the functionality and performance of the Service, and to enhance your user experience.

You may be asked to grant permission to access certain features on your mobile device, which may include but is not limited to, the following:

Permission:	Allows Access To:	Purpose:
Access to external storage	Files/media on the device	Secure Message Attachments
Camera	The device’s camera	Mobile Deposit
Contacts	Contacts on the device	Person to Person Payments Recipient List
Diagnostics and Crash Logs	App performance information	Assist with diagnostics and performance
Location	Your location	Maps, Fraud Prevention and Security
Photos	Photo Library	Upload Selected Image for Mobile Deposit

We use this information to provide and support the features of the Service and to improve and customize your experience. The information may be transmitted to and stored on our servers and/or those of our service providers, or stored locally on your device as necessary to support application functionality. You may enable or disable access to these permissions at any time through your Device settings. Disabling certain permissions may limit the functionality of the application.

Understanding and Managing Cookies

Cookies are small pieces of information that are generated and stored when you visit a website while using a computer or mobile device. A website may place a cookie on your browser to remember the device and to track the activities of your browser. This allows for a more personalized and consistent online experience. Cookies may also be used for fraud prevention and, where permitted, advertising and marketing purposes.

We, or service providers we work with, may deploy and use cookies and similar technologies to collect certain information when you use our Services. These tracking tools may detect characteristics or settings of the specific device you use to access our Services. We comply with applicable legal requirements and may provide you with the ability to opt in or opt out of certain cookie types through a consent banner. Most web browsers allow you to adjust your browser settings to decline or delete cookies; however, doing so may reduce your experience with our online services. If you delete cookies, or access our Services from a different device, you may be prompted to make your selections again.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain the Service, including to monitor the usage of the Service.
• To manage Your Account: to manage your registration as a user of the Service. The personal data you provide can give you access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: to provide, maintain, and support the products and services you request from us, fulfill our obligations related to those products and services, and administer your use of the Service.
• To contact You: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers and general information about products, services and events that may be of interest to you, unless you have opted not to receive such communications.
• To manage Your requests: To attend and manage your requests to Us.
• For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about the Service users is among the assets transferred.
• For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our communications and promotional efforts, enhancing security and fraud prevention, and evaluating and improving the Service, products, services, and your experience.

We may share Your personal information in the following situations:

• With Service Providers: We may share your personal information with Service Providers that perform services on our behalf, including supporting, operating, securing, maintaining, and analyzing the Service, and communicating with you regarding the Service.
• For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
• With Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
• With business partners: We may share information with trusted business partners and service providers as necessary to provide, support, or enhance products and services made through the Service, or as otherwise permitted by law.
• With Your consent: We may disclose your personal information for any other purpose with your consent.

Security of Your Information

We maintain administrative, technical, and physical safeguards designed to protect the security and confidentiality of personal information collected through the Services. While we strive to protect your information, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

Retention of Your Personal Data

The Company will retain your Personal Data to the extent necessary to comply with legal and regulatory obligations, maintain appropriate business and operational records, support security and fraud prevention efforts, resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the Service, or we are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices in the United States and at locations where our service providers maintain operations.  As a result, your information may be transferred to and maintained on computers or systems located outside of your state of residence, including data centers and other facilities used to support the Services.  If you access or use the Services from outside the United States, please be aware that your information may be transferred to, processed, and stored in the United States, where data protection laws may differ than those from your jurisdiction.

By using the Services and providing information to us, you acknowledge that your information may be processed and stored as described in this Policy.

The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.  No transfer of your Personal Data will take place to an organization unless there are appropriate safeguards and controls in place to protect your information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different online privacy policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose your personal data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

CHILDREN’S PRIVACY

We are committed to protecting children’s privacy.  We do not knowingly collect personally identifiable information from anyone under the age of 13 through our Services. If you are a parent or guardian and are aware that your child has provided Us with Personal Data, please contact Us. If we become aware that we have collected Personal Data from a child under the age of 13 without appropriate parental consent where required by law, we will take reasonable steps to delete or otherwise address such information.

Certain portions of our Services, including educational and financial literacy resources, may be accessible to individuals of all ages. However, children under the age of 13 should not provide Personal Data through our Services without the involvement of a parent or guardian.

Where required by applicable law, we may obtain parental or guardian consent before collecting, using, or processing a child’s personal information.

LINKS TO OTHER WEBSITES

Our Service may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We encourage you to review the online digital privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy practices of any third-party websites or services.

CHANGES TO THIS PRIVACY POLICY

We may update this Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Digital Banking Privacy Policy periodically for any changes. Changes to this Policy are effective when they are posted on this page.

CONTACT US

If you have any questions about this Digital Banking Privacy Policy, you can contact us:

• By visiting this page on our website: www.cogentbank.com
• By phone number: 888.577.0404
• By mail: 420 S Orange Ave, Suite 150, Orlando, FL 32801

You can also access Cogent Bank’s Privacy Notice at Cogent Bank Privacy Policy.