Mobile & Digital Customer Privacy Policy Notice

Our Commitment to Privacy

First Dakota National Bank ("First Dakota," "we," "our," or "us") respects the privacy of our customers and consumers. We maintain safeguards designed to protect personal information and limit access to employees and service providers who need it for authorized business purposes.

This notice applies to consumer interactions with our online and digital services. It does not replace other notices, agreements, or disclosures that may apply to a particular account, product, service, transaction, or communication channel.

Information We Collect

We collect personal information that you provide directly, that is generated when you use our website or digital services, and that is received from service providers. We may obtain information about you from consumer reporting agencies, identity verification providers, fraud prevention services, and publicly available sources as permitted by law. Our privacy and information security practices generally continue to apply to information we maintain about former customers.

Information you provide may include:

Name, mailing address, email address, and telephone number.
Account number and other account-related information.
Social Security number, date of birth, identification information, and information used to verify identity.
Digital banking username, password, security questions, and authentication information.
Information submitted through applications, forms, secure messages, support requests, surveys, or other communications.
Images and documents you choose to submit, including check images, receipts, identification records, and profile photographs.
Mobile telephone number, messaging preferences, text-message consent and opt-out records, message content, and delivery or response information.

Information collected automatically may include:

Internet Protocol address, device identifiers, browser type, operating system, internet service provider, and device settings.
Dates and times of access, pages or features used, links selected, referring pages, session information, and error data.
Cookies, pixels, web beacons, analytics information, and similar technologies.
Location information is obtained when you grant permission through your device settings.
Information used to support biometric sign-in, such as fingerprint or facial recognition functionality. Biometric credentials are managed by your device's operating system or application provider, depending on the functionality enabled.

Mobile App Permissions

Our mobile applications may request access to features on your device. You may manage available permissions through your device settings. Certain app features may not function if a permission is disabled.

Biometric functionality to support secure sign-in.
Camera, photo library, or storage access to capture profile photographs, mobile-deposited checks, receipts, identification records, or other transaction images.
Location information to identify nearby branches or ATMs.
Notifications to provide account, security, service, or other messages you have enabled.

How We Use Information

We may use personal information to:

Provide, administer, authenticate, and support digital banking services.
Open and maintain accounts; process transactions, applications, inquiries, and requests.
Communicate with you and provide customer service.
Deliver account servicing, security, fraud, transaction, and other requested alerts.
Prevent, detect, investigate, and respond to fraud, unauthorized activity, security events, or other risks.
Maintain, analyze, troubleshoot, and improve our website, applications, products, and services.
Personalize content and present information about First Dakota products and services, subject to applicable law and your communication preferences.
Report to consumer reporting agencies or other entities as permitted by law.
Comply with legal, regulatory, audit, recordkeeping, and court-order requirements.
Protect our rights, property, systems, customers, employees, and others.

SMS and Text Messaging

First Dakota may use text messaging to communicate with customers and consumers about account servicing, requested customer support, security or fraud alerts, transaction information, and, when separately authorized, products or services that may be of interest.

When you share your mobile phone number or otherwise consent to receive text messages, we may collect your mobile phone number, messaging preferences, consent and opt-out records, message content, and information relating to the delivery of and response to messages. Certain account servicing, fraud prevention, security, and transactional communications may be provided as part of the services you request. Marketing and promotional text messages, where applicable, are subject to separate consent and preference management processes.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

We may disclose this information to service providers that assist us in delivering, administering, securing, monitoring, or retaining our text messages, subject to contractual confidentiality and security requirements, or when disclosure is otherwise required or permitted by law.

Consent to receive marketing text messages is not a condition of opening an account, obtaining a product or service, or maintaining a banking relationship with us. Message frequency may vary. Message and data rates may apply.

You may withdraw consent to receive text messages at any time by replying STOP when that option is available, by contacting us using the information in the Contact Us section, or any other reasonable method. We will process opt-out requests as required by applicable law. We may send one non-marketing text confirming that your request has been processed.

Opting out of text messages does not prevent First Dakota from communicating with you through other lawful methods. Certain security or service alerts may be managed separately through your digital banking settings.

Standard SMS text messages are not a secure communication channel. Do not send passwords, access codes, full account numbers, Social Security numbers, or other sensitive information by text. When sensitive information is needed, we may direct you to a secure channel, such as authenticated digital banking or another approved method.

Cookies, Analytics, and Similar Technologies

When you visit our website or use our digital services, we and our service providers may use cookies, web beacons, pixels, software development kits, and similar technologies. These technologies may be used to operate and secure our services, remember preferences, understand how visitors use our services, identify and correct errors, assist users who report problems, and improve website and application performance.

These technologies may collect information about website or application activity, browser or device characteristics, Internet Protocol address, cookies or similar identifiers, approximate location, session activity, and interactions with our services. Depending on the technology and configuration used, this information may be aggregated or associated with a pseudonymous browser, device, application, or session identifier.

We may use third-party analytics services, including Google Analytics. These providers may collect and process information about your use of our services in accordance with their privacy practices. For information about how Google uses information collected through sites or applications that use its services, visit the Google Privacy & Terms website. When you follow a third-party link, the third party’s privacy notice applies.

You may be able to control cookies and similar technologies through your browser or device settings. Disabling these technologies may affect the availability or operation of certain features. Where applicable, you may also manage Google advertising preferences through Google Ad Settings or opt out of certain participating companies’ interest-based advertising through the Network Advertising Initiative’s opt-out tools.

We do not currently respond to browser “Do Not Track” signals because no generally accepted standard governs how websites should respond to those signals. We may revise this practice if an applicable standard is established.

How We Disclose Information

We do not sell customers' nonpublic personal information. We disclose personal information only as described in this notice, in our federal Privacy Notice, at your direction, or as otherwise permitted or required by law.

We may disclose information:

To process or complete a transaction or provide a product, service, feature, or communication you request.
To service providers that perform functions on our behalf, such as data hosting, digital banking, analytics, fraud prevention, communications, payment processing, document delivery, records management, and customer support.
To consumer reporting agencies and other information-reporting services as permitted by law.
To joint marketing partners as described in our federal Privacy Notice.
To regulators, law enforcement, courts, auditors, or other parties when disclosure is required or permitted by law.
To protect against fraud, security threats, unauthorized transactions, claims, or other liability.
With your consent or at your direction.

We require service providers that receive customer information from us to use it only for authorized purposes and to maintain appropriate confidentiality and security safeguards, in accordance with applicable contracts and law.

For additional information about our collection and sharing of nonpublic personal information, including choices that may be available to you, review the First Dakota National Bank federal Privacy Notice provided at account opening and available on our website.

How We Protect Information

We maintain administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, alteration, or disclosure. We limit employee access to personal information to individuals with an authorized business need, and provide privacy and information security training to employees.

No method of transmission or storage can be guaranteed to be completely secure. If you believe your information or account may have been compromised, contact us promptly using the information below.
We will provide notice of qualifying security incidents in accordance with applicable laws, regulations, and supervisory guidance.

Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this notice, provide products and services, satisfy legal and regulatory requirements, resolve disputes, enforce agreements, and comply with our record-retention policies. Retention periods may vary based on the type of information, product, service, or communication, as well as applicable legal requirements.

Online Applications

When you apply for an account or other product online, we may collect information needed to evaluate and process the application, verify identity, satisfy legal requirements, and provide the requested product or service. Application sessions may expire after a period of inactivity for security purposes. Information already submitted may be retained in accordance with our record-retention practices and applicable law.

Links to Other Websites and Services

Our website and digital services may include links to websites or services operated by third parties. We do not control those parties or their privacy and security practices. A link does not mean that First Dakota endorses or guarantees a third party's products, services, content, privacy, or security practices. Review the privacy and security notices of each third party you choose to use.

Children’s Privacy Online

Our website and digital banking services are not directed to children under age 13, and we do not knowingly collect personal information online from children under age 13 without verifiable consent from a parent or legal guardian when consent is required. If we learn that personal information from a child under age 13 was collected in a manner inconsistent with applicable law, we will take appropriate steps to address the information.

Changes to this Notice

We may update this notice periodically. The Last Revised date identifies the current version. We will provide notice of material changes in the manner and within the time required by applicable law. Changes needed to address security, fraud prevention, legal, or regulatory requirements may take effect as permitted by law.

Contact Us

If you have questions about this notice, your privacy, or your communication preferences, you may:

Visit a First Dakota location.
Call us toll-free at 800-486-4712.
Send us a secure message through digital banking.
Visit www.FirstDakota.com.

Revision Date: 10/2/2026