Protecting your personal information is important to us. This Online Privacy Policy describes how we collect and use personal information when you visit or use our website and/or any other online services of Tompkins Community Bank (“Tompkins,” “our,” “us,” or “we”), including those offered under the Tompkins Financial Advisors brand (“Tompkins”). This policy covers Tompkins’ online services, including our website, the Tompkins Financial Corporation website, the Tompkins Financial Advisors website, mobile banking applications, Tompkins’ social media sites or pages and content provided through one of Tompkins’ digital advertising campaigns (collectively, the “Services”).
Please read this policy carefully before you start to use our Services. By using the Services, you represent that you are of legal age to form a binding contract with us and agree to be bound by this policy. If you have entered into a specific agreement with us for certain services we provide, the terms of that agreement will control to the extent there is any conflict with these terms.
Our posted Consumer Privacy Notice supersedes this policy with respect to any personal information we collect or process in connection with financial products or services, and that notice provides additional information and choices with respect to the use and sharing of such personal information.
1. How We Collect Information
We may collect information about you through various means, including:
- Directly from you online (e.g., website, email);
- Through your use of our websites or related online services; and
- From other third party sources and social media platforms that you may use to engage with us, as well as to third parties for the purposes provided below, and/or to supplement information we already possess.
2. Types of Information We Collect
In order to provide you with our Services, we may collect the following categories of information:
- Profile information, such as name, address, phone number, email address, company, title, as well as billing, payment and other business information;
- Survey information in response to questions we may send you, including for inquiries, feedback and research purposes;
- System logs such as your account settings and use of our Services;
- Communications between you and us, such as via email or other electronic messages; and
- Online activity described in the next section.
3. Online Activity, Cookies and Information Collected by Other Automatic Means
Cookies are a commonly-used web technology that allows websites to store and retrieve certain information on a user’s system, and track user’s online activities. We, together with the vendors we use, may collect information about your use of our Services by such automated means, including but not limited to cookies, pixels and other similar technologies.
Cookies and similar technologies can help us automatically identify you when you return to our website. Cookies help us review traffic patterns, improve the website, and determine what Services are popular. We may also use such information to deliver customized content and advertising to users of the Services whose behavior indicates that they are interested in a particular area.
When you use the Services, the information we may collect by automated means include, for example:
- Usage details about your interaction with our Services (such as date, time, and length of visits, and specific pages or content accessed during the visits, search terms, frequency of the visits, referring website addresses);
- Device information, including the IP address and other details of a device that you use to connect with our Services (such as device type and unique device identifier, operating system, browser type, mobile network information, and the device’s telephone number); and
- Location information where you choose to provide the website with access to information about your device’s location.
We may also ask advertisers or other partners to serve ads or services to you, which may use cookies or similar technologies placed by us or the third party. If a user does not want information collected through the use of cookies, most browsers allow the visitor to reject cookies, but if you choose to decline cookies, you may not be able to fully experience the interactive features our Services provide. We may share non-personal information we obtained via cookies with our advertisers.
4. How We Use Information We Collect
We may use the information we obtain about you for purposes allowed by applicable laws including to:
- Provide our Services to you, including with respect to any business relationship, inquiries, and interactions;
- Monitor the performance of our Services including metrics such as total number of website visitors, traffic, and demographic patterns;
- Tailor the content we display to you in our Services and communications, including advertising that we believe may be of interest to you;
- Operate, evaluate, and improve our programs, websites, and other products and services we offer (including to develop new services) and diagnose or fix technology problems;
- Analyze and enhance our communications and strategies (including by identifying when emails sent to you have been received or read);
- Inform you about changes to our services, practices and policies; and
- Comply with and enforce as needed legal requirements, industry standards, our policies, and our contractual rights.
5. How We Share Your Information
We will not disclose your personal information to third parties without your consent, except in following circumstances:
- Limited information (e.g., IP address, pageview, etc.) may be collected through third party online tools such as cookies, as described above. As explained above, you can take certain steps to prevent such collection.
- We may share your personal information with service providers that we believe need the information to perform a technology, business, or other professional function for us (examples include IT services, maintenance and hosting of our Services, payment processors, and other service providers). We only provide such vendors with information so they can perform their required functions on our behalf.
- We may disclose information about you (i) if we are required to do so by law or a legal or regulatory process, (ii) when we believe disclosure is necessary to prevent harm or financial loss, (iii) in connection with an investigation or suspected or actual fraudulent or illegal activity, or (iv) under exigent circumstances to protect the personal safety of our staff, users, or the public.
- We reserve the right to transfer the information we maintain in the event we sell or transfer all or a portion of our business or assets. If we engage in such a sale or transfer, we will make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this policy.
6. Your Privacy Choices
We offer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you.
- Access and Correction: You may review or update certain account information by logging in to the various account portals on our website or by contacting us. Your account profile may also provide different options for the type of information you can provide as well as the types and methods of communication that you prefer.
- Marketing Emails: From time to time, we may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. You may choose not to receive marketing emails from us by clicking on the unsubscribe link in the marketing emails you receive from us. Even if you opt out of receiving such communications, we will continue sending you non-marketing email communications, such as business communications or administrative notices, when appropriate.
- Cookies: Web browsers may offer users the ability to disable certain cookies; however, if cookies are disabled, some features or functionality of our Services may not function correctly.
- Targeted Advertising: To the extent we work with advertising partners who collect information about your online activities, we will endeavor to provide you with choices regarding any such sharing or targeted advertising activities, as may be required by applicable laws.
Tompkins is a regulated financial institution. Personal information we collect from or about individuals in connection with any consumer banking activities is treated in accordance with applicable federal and state privacy laws, including the Gramm-Leach-Bliley Act (GLBA) and Fair Credit Reporting Act (FCRA), and we therefore use and share information we collect from or about consumers of our financial products or services consistent with the disclosures in our Consumer Privacy Notice.
We do not provide a financial incentive or a price or service difference to customers in exchange for the retention or sale of their personal information. We may send promotions or offers to customers or other individuals who subscribe to marketing communications, and unless a customer has opted out of such communications, the customer will continue to receive such notices irrespective of whether any information privacy request described here has been submitted. We do not offer financial incentives to deter customers from making such requests. We do not discriminate against any customer for exercising any privacy rights, including those provided by applicable laws.
We may advertise, through the Services or on unaffiliated websites, the products or services that are offered by us or third parties we work with, such as pre-screened offers of credit. These advertisements may be based on information about you that we or our service providers and other companies we work with have, including your existing relationship with us (e.g., location, types of account and transactional information). Our interest-based advertising may also be based on your web-browsing activities across our Services or non-affiliated websites over time in order to deliver advertisements that may be of particular interest to you. Certain companies we work with may set cookies and use related technologies in our Services or communications to facilitate these ads. However, to the extent we share your information with third parties or engage in third-party targeted advertising activities, we will provide you with an ability to opt-out of such activities as provided by applicable laws.
7. California Privacy Rights
We are not located in California, but recognize that California privacy rights generally apply to all California residents, including job applicants, current and former employees, commercial customers, contractors and business partners. The collection and use of personal information in such relationships can vary, but in general we collect contact information and other personal information reasonably necessary to reasonably facilitate the business relationship. All such individuals who are California residents can request additional information about our privacy practices with respect to their information, as well as make access, deletion, correction and opt-out requests (to the extent applicable by law) by contacting us as provided below.
Some browsers may include a "Do Not Track" (DNT) setting that can send a signal to the online services you visit indicating you do not wish to be tracked. Because there is not yet a consensus on how companies should respond to browser-based do-not-track (“DNT”) mechanisms, we do not respond to browser-based DNT signals at this time.
8. International Considerations
Our Services are intended for use in the United States. If you use our Services from outside the United States, you acknowledge and agree that we may transfer your information to and from the United States, including countries that may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your personal information in accordance with this policy regardless of where your personal information is stored or accessed. Notwithstanding the foregoing, we will endeavor to accommodate requests with respect to your information to the extent required by law and otherwise in our foreseeable discretion.
9. Links to Other Websites and Third-Party Content
Our Services may contain links to other websites or online services, including social media. Please be aware that we are not responsible for the content or privacy practices of such other websites or online services, and we encourage you to be aware when you leave our Services and to read the privacy statements of any other website or online service that collects personal information.
10. How We Protect Information
We endeavor to maintain reasonable administrative, technical and physical safeguards to protect the personal information we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, we cannot ensure the security of any information you transmit to us, or guarantee that this information will not be accessed, disclosed, altered, or destroyed. We will make any legally required disclosures in the event of any compromise of personal information. To the extent the law allows us to provide such notification via e-mail or conspicuous posting on the Services, you agree to accept notice in that form.
We will only retain personal information for as long as necessary to fulfill the purposes we collected it for, including for any business, legal, account or reporting requirements. To determine the appropriate retention period for such personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which process the information and whether we can achieve those purposes through other means, as well as all applicable legal requirements.
11. Children
We do not knowingly collect personal information from children under the age of 13 on our Services and will endeavor to promptly delete any information upon discovery.
12. Updates to Our Privacy Policy
We may revise or update this policy at any time. We will post the updated version on our websites, and may notify you of any significant changes to our Policy. We will indicate on our policy when it was most recently updated. Your continued use of our Services after such updates will constitute an acknowledgement of the change and agreement to abide and be bound by the updated policy.
13. Contacting Us
If you have any questions about this policy or our privacy practices, or requests with respect to your personal information, please contact us at directed at https://www.tompkinsfinancialadvisors.com/about-us/contact-us
This Privacy Policy was last updated on May 27, 2026.