By viewing or using our Online Services, you consent to this Notice which includes your consent to disclose and use information about you in the manner detailed in the Notice. Depending upon your relationship with us, you may receive other Wilmington Trust privacy notices providing additional detail about our privacy practices.

We collect two kinds of information through Online Services: non-personal information and personal information.

The non-personal information we collect includes information about your use of Online Services and other information including: the visitor's browser type, device type and operating system, area(s) of Online Services site visited, date and time of access, host or Internet Service Provider (ISP) information, and identity of the referring site (any site from which the visitor accessed Online Services).

Personal Information means personally identifiable information such as information you provide via forms, surveys, applications or other fields including name, postal or email addresses, national identification number, telephone, fax or mobile numbers, or account numbers.

We also collect personal information that can identify a visitor, user or customer, including but not limited to name, address or other contact information, visitor interactions with or viewing of video content, or other information that you may choose to provide to us. If you apply for a job, we may collect personal information about your work and educational history.

We may offer you the ability to register and access your accounts via Online Services. When you access your accounts via Online Services, we may also collect and analyze the following (in addition to the other types of information discussed in this Notice):

We may collect information about your device such as your phone number, the device model, installed applications, identity of the carrier and the name and version of the operating system.

There may be certain information transmitted to us regarding your location when you log in or request information through Online Services. We collect the Internet Protocol (IP) address of the device to determine your physical location for Online Services. We also collect precise geolocation information from your mobile device, including GPS coordinates and device-derived location data, to support fraud prevention, security monitoring, and sanctions compliance. Your location data will be retained by Wilmington Trust for as long as needed to fulfill business purposes but will only be used for the limited purposes stated within this Notice.

We may collect information when you initiate a transaction. This information will be used or shared in order to provide the service that you requested.

This information is also collected and analyzed to assist us with fraud detection and for other security purposes, and to enhance our ability to optimize your experience while on our site. It will only be used for the purpose(s) stated within this Notice and retained by Wilmington Trust for only as long as needed to fulfill the business purpose(s).

We may collect certain behavioral biometrics such as mouse movements and patterns, touch screen interactions and movements, keyboard interactions, typing cadence, and navigation patterns. This information is collected and analyzed to assist us with fraud detection and for security purposes.

We may use the information we collect through Online Services for several purposes including:

• to provide you with, renew, or modify products and services; 
• to provide you with the information and documents you request and for other customer service purposes; 
• to provide you with information about Online Services or required notices; to allow you to participate in digital surveys and other forms of market research; 
• to deliver affiliate marketing communications or promotional materials that may be of interest to you, and to assist us in determining relevant advertising; 
• to improve the services we provide and the usefulness of Online Services; 
• to customize your experience when using Online Services; 
• to comply with applicable laws; 
• to perform research; 
• and to prevent and detect fraud, infringement and other potential misuse.

We also may anonymize, combine or aggregate any of the information we collect through the Online Services or elsewhere for any of these purposes or for analyzing usage statistics and trends.

We may share the information identified in the Types of Information we Collect section with affiliates and third parties described below:

• Our affiliates and third party service providers, who provide services to us or help us provide services to you, including for marketing purposes;
• Other companies to bring you products and services that you have requested;
• Other companies or affiliates in connection with a merger, consolidation, acquisition, divestiture or other corporate restructuring;
• Other third parties for complying with legal obligations, such as responding to subpoenas or court orders, tackling fraud, security or technical challenges, enforcing terms of use, or to safeguard the rights, property, and security of our customers or third parties.

Where applicable, we will limit our sharing of your information in accordance with the choices you have made.

We may share anonymous or aggregated information with our third parties for analytics, product improvement, performance tracking, and other purposes.

Cookies and Visitor Tags. To better serve you and to provide more effective Online Services, we use "Cookies" as part of our interaction with the device you are using. Cookies are small data files that are placed on your web browser when you visit a website. In addition to Cookies, we may use other devices such as visitor tags, including those sometimes referred to as web beacons or pixels. These are similar small files on our Wilmington Trust websites, not the user’s browser, that use a unique identifier enabling us to recognize when someone has visited our websites or opened an e-mail that we have sent them. Information collected with these tools can include pages and content viewed, including text, image, and video content, time and duration of visits, search queries entered into search fields, and whether a user clicked on an advertisement. We may also use other technologies, such as the real time capture of screenshots, commonly known as session replay, while you are using our Online Services, to understand how you navigate and use the Services.

You can find more information about these data collection tools, as well as descriptions of how we use them, in the Wilmington Trust Cookie Notice. 

You can refuse to accept certain Cookies by using the Manage Cookies link on our website.

You can also visit the "Help" section of your browser for how to manage your cookie settings, or follow the links below:

• Google Chrome
• Mozilla Firefox
• Safari
• Microsoft Edge

For further general information on Cookies and more detailed advice on how to disable and enable them, please visit allaboutcookies.org.

While, as described above, you may have the ability to control the use of Cookies through your web browser, unless the browser settings block our data collection, we do not currently respond to "Do Not Track" signals or other mechanisms. The available settings vary greatly by browser; please refer to your Internet browser settings for more information. For more information about Do Not Track, please visit allaboutdnt.com.

We recognize that protecting children's identities and privacy online is important and that the responsibility to do so resides with both the business and the parents. We do not knowingly solicit data from children under the age of 13, and we do not knowingly market through our website to such children.

Our legal basis for collecting and using personal information depends on the type of information and the context in which it is collected. We generally process personal information where it is necessary to perform a contract with you, to comply with a legal obligation, where it is in our legitimate interests (provided those interests are not overridden by your rights), or where we have your consent. Where we rely on legitimate interests, this typically includes operating and improving our Online Services, communicating with you, marketing, and detecting or preventing illegal activity. If we request personal information to meet a legal requirement or perform a contract, we will indicate whether providing it is mandatory and explain the consequences of not doing so. If you have questions about the legal basis for processing your personal information, please contact us using the details provided under the “How to contact us” heading below.

From time to time, Wilmington Trust may establish a relationship with other companies and vendors who provide us with the tools used to collect and analyze the aforementioned data that is used to improve the operation of our Online Services or for marketing purposes.

Wilmington Trust offers access to other websites either using hyperlinks or through "co-branded" sites in which both Wilmington Trust and the other company share the same URL, domain name or pages within a domain name on the Internet. In some cases, the other site will also collect information from you. This information may include, but is not limited to, name, address, national identification number, account numbers and date of birth. Prior to providing any information to any third party, review their privacy policy to determine the extent to which they may disclose your information.

It is important for us to have your most accurate and up-to-date contact information. If any of your contact information has changed, please call or write us at the proper telephone number or address located within the Help page.  You may also call or write us at the telephone number or mailing address located on your account statements or other records as indicated.

We protect information you provide us online in several ways. Wilmington Trust Online Services leverages multiple layers of security, including password protection and the SSL (Secure Sockets Layer) communication protocol, which employs 256-bit encryption to ensure information is passed to Wilmington Trust without being intercepted by third parties. As always, we strongly encourage you to assist us in that effort by not sharing your Wilmington Trust User ID or Password with anyone. For more information about Online Services security, please visit the Wilmington Trust Privacy/Security page.

Please use caution when using aggregation websites. Aggregation websites offer the ability to access all your financial account information on one website. To do this, an aggregation provider may request access to your User IDs and Passwords. You should use caution and ensure that the aggregator company has appropriate policies and practices to protect the privacy and security of any information you provide or to which they are gaining access. We are not responsible for the use or disclosure of any Personal Information accessed by any other company or person to whom you provide your User ID and Password.

All transactions initiated by an aggregation website, using access information you provide are considered to be authorized by you, whether or not you were aware of the specific transaction. If you decide to revoke the authority you have given to an aggregation website, we strongly recommend that you change your User ID and Password to ensure that the aggregation website cannot continue to access your account.

We may transfer your personal information to, and process it in, countries other than the country where you live. The data protection laws in those countries may differ from the laws that apply in your country.

For example, we may share your personal information with our group companies, third-party service providers, and business partners located around the world, including in countries outside the UK and the European Economic Area, such as the United States. As a result, when we collect your personal information, it may be processed in any of these countries.

We implement appropriate safeguards to ensure your personal information remains protected in line with this Notice. This includes using the European Commission’s Standard Contractual Clauses (SCCs) for transfers between our group companies, requiring them to protect UK and EEA personal data in accordance with applicable data protection laws. We apply similar safeguards when working with third-party service providers and partners, including relying on their adherence to approved data transfer frameworks or equivalent protections.

We retain your personal information for as long as we have an ongoing business need to do so, such as to provide services you’ve requested or to comply with legal, tax, or accounting requirements. When we no longer need your information, we will delete or anonymize it. If that is not immediately possible (for example, due to backup storage), we will securely store and restrict further use until deletion is possible. In general, we retain your information for the duration of your customer relationship and, afterward, only as long as necessary for the purposes described in this Notice and as permitted by applicable law.

You may exercise your data protection rights by contacting us using the details provided under the “How to contact us” heading below. These rights include access, rectification, erasure, restriction of processing, objection to processing, and data portability, as well as the right to opt out of marketing communications. Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of prior processing or processing based on other legal grounds. You also have the right to lodge a complaint with a competent data protection authority. We respond to all requests in accordance with applicable data protection laws.

This Notice should be reviewed periodically as it is subject to change from time to time. When a change has been made, we will post the revised Notice on this page with a new "Last Updated" date at the top of the page. All changes will become effective when posted unless indicated otherwise.

Your continued use of any of our Services following the posting of a revised version of this Digital Privacy Notice will constitute your acceptance of the revised Notice. If you do not agree with the revised Digital Privacy Notice, do not use any of our Online Services.

This Privacy Notice is issued by the entities listed below, who are responsible for handling your personal data (“Controllers”). If you have any questions or concerns about how we manage your data, please contact our designated representative using the details provided below.

Name of Controller:

• Wilmington Trust SP Services (London) Limited
• Wilmington Trust (London) Limited
• Wilmington Trust SP Services (Dublin) Limited
• Wilmington Trust SP Services (Frankfurt) GmbH
• Wilmington Trust S.A.S.
• Wilmington Trust (Milano) S.r.l.

Controller Contact Information:

• GDPR Office
  Wilmington Trust SP Services (London) Limited
  Third Floor, 1 King's Arms Yard
  London, EC2R 7AF
• gdproffice@wilmingtontrust.com