Scope & updates
This notice applies to consumers who have or seek a relationship with us, including visitors to our public websites who submit contact information. We will revise this notice when our practices or the law changes. The “Effective date” above indicates the version posted on this site. For material changes, we will provide additional notice as required (for example, by mail, secure message, or email if permitted).
Information we collect
Depending on your relationship and products, we may collect:
- Identifiers & contact data: Name, postal address, email, telephone numbers, date of birth, government ID numbers where permitted, online identifiers, and similar data.
- Financial & account data: Account numbers, balances, transaction history, wire and payment instructions, tax and withholding information, credit and income details for lending and onboarding.
- Professional & household data: Employment, business ownership, trust and entity documents, beneficial ownership, and household relationship data for private banking services.
- Device & technical data: IP address, device type, browser language, session logs, and authentication factors used to secure digital channels.
- Inferences: Risk scores, product eligibility indicators, and fraud models derived from the above.
Some information may be considered “nonpublic personal information” under the Gramm-Leach-Bliley Act (GLBA) and is subject to the confidentiality standards described below.
How we collect it
- Directly from you on applications, agreements, surveys, and correspondence;
- From transactions and account servicing (including cards, wires, ACH, and digital banking);
- From affiliates in our corporate family for servicing, fraud prevention, and offers permitted by law;
- From consumer reporting agencies, identity-verification vendors, public records, and commercial data sources;
- From joint accountholders, authorized users, guardians, or agents you designate;
- Automatically when you use our websites or mobile apps (see Online & mobile).
How we use information
We use personal information as permitted by law, including to:
- Open, service, and collect accounts; process transactions and instructions you authorize;
- Verify identity, authenticate users, and detect, investigate, and prevent fraud and financial crime;
- Perform credit underwriting, risk management, and portfolio monitoring;
- Comply with legal obligations (e.g., BSA/AML, sanctions, tax reporting, subpoenas);
- Communicate servicing, security, and legal notices;
- Develop analytics to improve products, channels, and client experience;
- Market our products or those of affiliates and selected partners where allowed, subject to your choices.
How we share information
We do not sell your personal information for monetary consideration as that term is commonly understood under U.S. state comprehensive privacy laws.
We may share information in these categories:
- Affiliates: We may share identifiers, transaction information, and creditworthiness among our affiliated companies for everyday business purposes, such as servicing, risk management, and offers permitted by law.
- Service providers: Vendors that assist with processing, technology, analytics, collections, print/mail, and professional services are bound by contract to use data only for our instructions and applicable law.
- Joint marketing: We may share limited information with nonaffiliated financial institutions for joint marketing agreements formalized between us; you will receive a description of such agreements where required.
- As directed or consented: When you request a transfer of funds, credit bureau inquiry, or introduction to a third-party manager, we share what is necessary to fulfill your instruction.
- Legal & protection: We may disclose information to regulators, law enforcement, or others when required or permitted by law, or to protect rights, safety, and the integrity of our services.
- Business transfers: In a merger, acquisition, or asset sale, information may transfer subject to confidentiality commitments and notice where required.
Your choices & rights
GLBA affiliate marketing opt-out: Federal law gives you the right to limit certain sharing of creditworthiness information about you among our affiliates for marketing solicitations. To limit such sharing, contact us using the information in Contact us and identify your request as an “affiliate marketing opt-out.” We will explain any exceptions (for example, sharing for servicing or as otherwise permitted by law).
State laws: Residents of certain states may have additional rights to access, delete, or opt out of certain processing. See State privacy notices. We will verify requests as required by law and respond within applicable timeframes.
Accuracy: Notify us of changes to your contact or profile information so statements, tax forms, and alerts reach you. You may review certain information through online banking or by contacting us.
Security & retention
We maintain administrative, technical, and physical safeguards designed to protect personal information in accordance with federal standards for financial institutions. Access is limited to personnel and vendors with a business need. We retain information for as long as needed to service accounts, meet legal and regulatory requirements, and resolve disputes. Retention periods vary by record type.
Online & mobile
We use cookies and similar technologies for session management, security, analytics, and preference storage where allowed. You may control cookies through browser settings; disabling certain cookies may limit functionality. Our mobile apps may collect device identifiers and diagnostic data consistent with platform rules. Third-party sites linked from our properties have their own privacy practices; review them separately.
State privacy notices
California residents: Depending on data collected, you may have rights under the California Consumer Privacy Act, as amended, including to know, delete, and correct certain personal information, and to opt out of certain “sales” or “sharing” as defined by California law. We describe categories collected and purposes above. Submit requests through the contact methods below; we do not discriminate for exercising rights.
Vermont residents: We will not share nonpublic personal financial information about Vermont consumers with nonaffiliated third parties except as permitted by Vermont law, your instructions, or your consent as described in applicable notices.
Other states may enact consumer data rights; we will update this section and processes as those laws become effective.
International users
If you access services from outside the United States, information may be processed in the U.S. and other countries where we or our vendors operate, subject to applicable law and safeguards such as contractual clauses where required.
Children
Our retail services are not directed to children under 13. We do not knowingly collect personal information from children under 13 without verifiable parental consent as required by the Children’s Online Privacy Protection Act.
Contact us
Sky International Private Bank — Privacy Office
11 Wall Street, New York, NY 10005
Phone: +1 (317) 552-0423
Email:
support@skyinternationalprivate.com
For written privacy requests, include your name, preferred contact method, and enough detail for us to verify your identity. You may designate an authorized agent where state law allows, with proof of authority.
Related: Legal disclosures · Online banking agreement