If a bank uses a vendor for its internet banking product, and the vendor sends out emails to encourage the use of online billpay (for example), is that considered "sharing with a nonaffiliate"? I think we DO share and they CANNOT limit the sharing. On the 2nd page, is that considered a "formal agreement" between nonaffiliated financial companies? I do not believe so....since the vendor is not a financial company.

Also.........must we give the customer a chance to "opt out" of this type of email marketing of a product? If we do, this would also affect our privacy notice by adding those features.

Could someone please help with this?

Could someone at least give an opinion of what they would do on their privacy notices under these circumstances?

Internet vendor send email about online billpay to internet banking customers. Is the internet vendor a non-affiliate? I believe so. So....we DO share and customer CANNOT limit it.

2nd page of privacy notice - I do NOT believe this relationship is a "formal agreement" between nonaffiliated companies. Is this correct?

Does this trigger an opt-out option on our privacy notice? I don't think so because they cannot limit the sharing. Each email, however, has opt-out instructions.

Our service provider would like to market billpay for us as well. However, we stated we do not share for "our marketing purposes."

Would our internet provider/billpay provider be considered a 3rd party if they are selling our billpay product?

Does anyone know where I could find a definition of "everyday business purposes"? The model form states "such as to process your transactions, maintain your account(s), respond to court orders..."

Are there more examples of everyday business purposes somewhere?