Good morning BOL! Our vendor that is creating a landing page (hosted by them) that displays our logo seems to think that our bank privacy policy should be the one associated with the link at the bottom of the landing page. Thinking back to "speed bumps" on our website that would be taking users to other pages hosted by a different privacy notice, I was under the impression the vendor's privacy policy would be the appropriate one... am I misunderstanding? I tend to overthink situations but I don't really know where to start looking for verification.

Note - this page is online applications, obtaining personal identifying information.

Bump - all input appreciated!

Can you clarify that a little bit? So it's your bank's application site, but just being designed by a vendor for you? I'm under the impression that it'd be your privacy notice.

For example, our online banking is hosted by our data processor, a third party vendor for us. We don't have that warning pop up since it's something "for" the bank (if that makes any sense?). I'd think an online application falls into the same category.

MS, that makes sense with the comparison to online banking, I hadn't considered that at all! Yes, they will be on our website and click "apply now", which will take them to the landing page our vendor has created. They will then fill out all of their information on the vendor's webpage which will send notification to us.

IMO, it'd be your privacy notice. Although, if there's a way to have both (but make it clear which is which and why you have both) that'd be great.

We didn't do the speed bump for the online banking link, so we wouldn't do it for an online application, either. From my perspective as a consumer, I'd be concerned if an application for my bank told me I was going to a different website.

MS - thank you so much for clearing this up! Apparently, as usual, I was overthinking. Appreciate your input!

Anytime! I'm always overthinking, too

Agreed. While it is true that your vendor is collecting information on your behalf, their handling of your customer's information should be governed by your vendor contract and your vendor management program should have already verified that they have the same limitations on sharing your customer information in the contract as you do in your privacy notice.

Thank you Brian! I need to learn to refocus my thinking patterns.