Privacy

For the purposes of this policy, “personal information” refers to any information that would enable the Bank to identify you, such as your name, email address, telephone number, or home address. While you may visit the Bank’s Website and use its Content or services freely without providing any information about yourself, you may at times choose to give the Bank personal information in order to do such things as

• Subscribe to communications
• Complete a survey
• Request information or resources
• Provide feedback

This Website may offer opportunities for you to submit your personal information through an online form or by sending an email. The Bank does not encrypt such electronic communications, and, therefore, the Bank cannot guarantee the security of any information sent electronically, whether submitted through an online form or by email.

No matter why you may give your personal information or how you may submit it, the Bank will use the information you provide exclusively for the purposes for which you gave it and/or to maintain a continuing relationship with you. The Bank will never rent, sell, share, or otherwise disclose your information to any person or organization outside of the Federal Reserve System without your permission, except under the following circumstances:

• When the Bank retains the services of outside agents or third parties under contract with the Bank. Such personal information is provided to and used by those parties only in conjunction with the services they provide to the Bank.
• When the Bank is required to disclose personal information about you or about a company with which you are associated to government officials or otherwise as required by subpoenas, court orders, legal process, or other legal obligations or to establish or exercise the Bank’s legal rights or to defend against claims.
• When the Bank investigates, prevents, or takes action against illegal activities or suspected fraud.

All information that you submit to the Bank through its Website becomes the property of the Bank and will not necessarily be handled confidentially.

The Bank’s Website is not directed toward children under 13 years old. We are committed to complying with applicable laws and requirements, such as the Children’s Online Privacy Protection Act. We do not knowingly collect personal data from children under 13. Minor children should always obtain parental consent before releasing personal information to any website. 

The Bank monitors the use of its Website to identify any unauthorized attempts to upload or change information, to defeat or circumvent security measures, or to use its Website or its Content for anything other than their intended purposes. In using the Bank’s Website you consent to such monitoring and are advised that if monitoring reveals possible evidence of criminal activity, the Bank may provide such evidence to appropriate law enforcement officials.

This Website is controlled and operated by the Federal Reserve Bank of Cleveland from its offices in the United States of America. By accessing this Website or providing us your personal information, you agree that all matters relating to our privacy practices and this Website shall be governed and construed in accordance with the federal law of the United States and the law of the State of Ohio to the extent state law is not inconsistent with the federal law. You agree that the United States District Court for the Northern District of Ohio shall have exclusive jurisdiction over any disputes related to this Website. If you use this Website from a location outside the US, you are also responsible for complying with any and all laws that govern that location.

The Bank uses a third-party vendor to track your visits to and use of the Bank’s Website content. The Bank gathers anonymous technical data about many aspects of your visit such as the content you visited, the brand of device you used, the device’s operating system, and the version of web browser used.

For some of that analysis, a “cookie” is saved to your computer or device. A “cookie” is a small text file that identifies your computer or device with a unique but anonymous alphanumeric code. The cookie’s only purpose is to identify your computer or device as either a new or returning visitor. The Bank cannot collect any personal information about you through its use of web analytics or cookies.

Gathering data through the use of cookies and other web analytics tools enables the Bank to identify aggregate trends and general patterns in how visitors interact with its Website and Content. The information the Bank draws from these data is used exclusively for the purpose of improving the quality of its content and the usability of its Website.

In addition, sometimes third-party contractors will use cookies on websites they manage and operate for us. For example, the job opportunities page is operated by a third-party contractor that uses cookies. Since that website is not operated by the Federal Reserve Bank of Cleveland, this Privacy Policy does not apply to the collection, use or maintenance of personal information or any other information from or by that site.

You can configure your browser to alert you when a website is attempting to place a cookie, at which point you can then either allow or deny that cookie. You can also delete any or all of the tracking cookies that websites may have installed on your computer or device through your web browser’s options and settings at any time. For more information, see your web browser’s privacy documentation.

Reasonable efforts are taken to ensure the quality and accuracy of the data and other information produced by the Bank and made available on or through its Website. The Bank may, without notice, periodically add, change, or update information and documents on its Website; however, it makes no commitment to do so. All service and content from or through the Bank’s Website is provided on an “as is” and “as available” basis. The Bank is not responsible for misprints, out-of-date information, errors, omissions, unavailable information, or denial of service or access.

The Bank assumes no legal liability or responsibility for the accuracy, correctness, completeness, or timeliness of any information available on or through its Website, nor does it represent that its use would not infringe privately owned rights. By using the Bank’s Website, you assume the risk that the information available on or through this Website may be inaccurate, incorrect, incomplete, or out of date or that it may not meet your needs and requirements or that it may be infringing.

The Bank assumes no liability or responsibility for any loss, injury, or damage of any kind resulting in any way from the content of its Website, including any computer viruses, malicious code, or system malfunctions.

The Bank makes no representation that its Website or its Content does not defame any individual or entity or infringe on any individual’s or entity’s rights of privacy or publicity.

The Bank specifically disclaims all warranties, express or implied, including without limitation, the warranties of merchantability, fitness for a particular purpose, title, quality, and noninfringement with respect to its Website and its Content.

The views expressed in Reserve Bank small business research, analysis, and Small Business Credit Survey reports and publications are strictly those of the authors. They do not necessarily represent the position of the Bank or the Federal Reserve System. Any conclusions that you draw from the information available on or through this Website, regardless of whether you received any assistance from the Bank or its employees, are your own and are not to be attributed to the Bank.

You may reproduce any reports, chartbooks, factsheets, or data appendices that are part of the Services if the reproduced information is not distributed for commercial purposes and is appropriately credited. For more information about this license, please visit https://creativecommons.org/licenses/by-nc/4.0/.

Publications or presentations that use information from the Small Business Credit Survey should be cited as follows: "Source: Small Business Credit Survey, Federal Reserve Banks."

The general policy above does not apply to the Small Business Credit Survey Questionnaires or other websites that may be linked to or from the website, which are governed by the individual policies of the relevant providers. In addition, some of the images or other content on the website may be copyrighted by others and permission to use such copyrighted material must be obtained from the copyright owner and cannot be obtained from the Reserve Banks.

All third party materials that are part of the Services are provided "as is" and all express or implied warrantees and all liabilities, damages, indemnities and obligations of any kind with respect to such materials are disclaimed. To the extent any license for such materials grants a licensee rights to use, copy or modify such materials that are broader than the rights granted herein, then such rights shall take precedence over these Terms of Use.

The Board of Governors of the Federal Reserve System (Board) is a federal agency that is responsible for the supervision and regulation of certain types of financial institutions (defined in section 3 below) including bank holding companies, state-chartered banks that are members of the Federal Reserve System, savings and loan holding companies, foreign banks operating in the United States, and other entities. The Board has delegated certain supervision and regulation functions, including the examination of supervised entities and the processing of certain banking applications and notices, to Reserve Banks as agents of the Board.

In performing these delegated functions, the Reserve Banks receive personal information from financial institutions. For example, Reserve Banks review consumer loan data as part of an examination of a bank. Reserve Banks may also receive personal information from supervised institutions about their shareholders, directors, and executive officers in connection with applications submitted by institutions for approval. The Reserve Banks protect this personal information in accordance with the Board's data privacy policies. For more information about what personal information may be involved in supervisory activities, please see the Federal Reserve Board Privacy Program site.

The Reserve Banks act as fiscal agents to the U.S. Treasury to support its goals related to collecting, disbursing, borrowing, investing, and accounting for government funds.

In this capacity, the Reserve Banks collect, use, and share personal information for the exclusive purpose of providing such fiscal services. In carrying out these functions, the Reserve Banks follow the Treasury's Data Privacy Policy and other requirements. See the U.S. Treasury Privacy Policy and the list of privacy impact assessments published by the Treasury: https://fiscal.treasury.gov/pia.html

The Reserve Banks provide financial services to depository institutions such as banks, credit unions, and savings and loans associations (together, “financial institutions.)” These services include acting as an intermediary between financial institutions for clearing checks, as well as settling Automated Clearing House (ACH) payments and electronically transferring funds.

The receipt and sharing of personal information are necessary aspects of the Reserve Banks' provision of financial services. As financial intermediaries, Reserve Banks come into possession of personal information such as names, addresses, and account numbers when they process payment transactions submitted by financial institutions. In some instances, a check or payment instruction might also include a social security number or other, more sensitive personal information. As financial intermediaries, the Reserve Banks receive such personal information from financial institutions and do not collect it directly from individuals. The Reserve Banks do not control the type or accuracy of personal information submitted by financial institutions. The Reserve Banks pass payment transaction information to the next financial institution in the payment chain either directly or through that financial institution's designated agent/vendor. Such information may also be used in connection with compliance activities, economic research, and for other operational purposes related to payments processing. For more information about these financial services, see Federal Reserve Bank Financial Services.

The Reserve Banks extend certain types of credit to financial institutions. This includes allowing short-term overdrafts on accounts (called daylight overdrafts) as well as other lending programs (called Discount Window advances).

Discount Window advances must be secured by collateral. The collateral pledged to a Reserve Bank may include consumer loans (e.g., mortgage loans or auto loans). While the loans generally remain in the custody of the financial institution borrowing from the Reserve Bank, the Reserve Banks require information about each of the loans pledged as collateral. The consumer-loan-level information obtained for collateral purposes include name, loan number, loan amount, and balance. If actual loan documentation is obtained for sampling or safekeeping purposes, it will include all the information contained therein, which may also include social security numbers, dates of birth, and account numbers. Personal information obtained for the lending functions is used only to support and facilitate these lending activities, and is shared only to the extent necessary to support these activities. Loan information may also be shared with other financial institutions, such as corporate credit unions and home loan banks, that similarly provide liquidity to depository institutions, to prevent double-pledging collateral. Please see www.frbdiscountwindow.org for more information about these activities.

The Research and Monetary Policy functions conduct independent economic research for publication in leading academic journals and provide policy analysis in support of the Federal Reserve's monetary policy mission and general responsibility to promote the effective operation of the U.S. economy and, more generally, the public interest.  Other departments in the Reserve Bank, such as Supervision and Regulation and Community Development, may conduct research in fulfilling their responsibilities and may collaborate with the Research and Monetary Policy functions. Overall, Federal Reserve research covers a wide range of topics to produce various forms of output available to the general public and other stakeholders.

Research and policy analysis can be data-intensive activities that involve analyzing detailed information. While some of this data include personal information, it is typically anonymized, or de-identified with strict prohibitions against re-identification. Some of this information is acquired from third-party data providers. The Reserve Banks may also acquire information using surveys they design alone or in partnership with other organizations. The safeguarding and responsible use of information for research is of the utmost importance to the Reserve Banks. Personally identifiable information collected or acquired by the Reserve Banks is subject to strict information security controls (based on the NIST framework) and other controls including restrictions on access, use, sharing, storage, and disposal of the information.

Each Reserve Bank has its own Federal Reserve law enforcement unit responsible for protecting its operations, facilities, and physical assets.

In order to protect the people and assets of the Reserve Banks, Law Enforcement collects some personal information from people who visit the Reserve Banks. Such visitors may be required to provide identifying information before being allowed access to Reserve Bank facilities. This information may include name and information on a government-issued ID. Some Reserve Banks also collect personal information to conduct background checks of vendors, contractors, and employees for the purpose of verifying identity and managing risk. Background checks, public records searches, and other information gathering may also be conducted for the purpose of assessing potential threats to the Federal Reserve System. These processes are conducted in accordance with applicable law, and could involve the sharing of personal information with vendors engaged to perform screening and/or with governmental agencies that conduct aspects of the screening.